ML17055D318
| ML17055D318 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/29/1987 |
| From: | Haughey M Office of Nuclear Reactor Regulation |
| To: | Mcknight J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711020137 | |
| Download: ML17055D318 (36) | |
Text
C yh CO(
UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 C4r n4>> >9 F5'g P Docket No. 50-410 NOTE TO:
Jim McKnight, Document Control FROM:
Mary Haughey, Project Manager for Nine Mile Point, Unit 2 Project Directorate I-l Division of Reactor Projects I/II SljBJECT:
DRAFT INFORMATION PROVIDED TO NIAhARA MOHAWK POMER CORPORATION ON NINE MILE POINT, UNIT 2 The enclosed information was provided to Niagara Mohawk on Oct.29;lg87to assist them in responding to NRC concerns on Nine Mile Point, Unit 2.
By copy of this note the enclosed information should be placed in the PDR and the LPDR.
Mary Ha gh
.'t M
aqer Project Directorate I-l Division of Reactor Projects I/II cc:
PDR LPDR 8711020137 87102'P PDR ADOCK 05000410 P
l I
18.r2&87
'5 16: 27 EGKG jD.
TSAR B 883 NINE MILE POINT NUCLEAR STATION, UNIT 2 PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS ANQ COMMENTS 1.
VALVE TESTING PROGRAM A.
General ues i If a manual operator is used to full-stroke exercise check valves that cannot be full-stroke exercised with flow, is the force or torque that is applied to the mechanical exerc1ser measured to assure compliance with IWV-3522(b)2 2.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by IOCFRSO, Appendix J.
Relief from paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety problem since the intent of IWV-3421 through 3425 is met by Appendix J requirements,
- however, the licensee shall comply with Paragraphs IWV-3426 and 3427.
General Re1ief Request GVRR-1 does not comply with this staff position.
3.
Provide a listing of all valves that are Appendix J, Type C; leak rate tested wh1ch are not included 1n the IST program and Categorized A or ACT 4.
The NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or less.
Relief may be obtained from the trending requirements of Section XI, Paragraph IHV-3417(a), however, in order to obtain this Code relief the staff does requ1re that the licensee assign a maximum limiting stroke time of 2 seconds to these valves and comply with the requirements of IWV-3417(b) when the 2 second limit is exceeded.
General valve relief request GVRR-3 does not comply w1th this staff position.
18i26r87 s6:27 1
HO. GP 5.
Provide the limiting values of full-stroke times for the power operated valves in the Nine Mile Point Nuclear Station, Unit 2, IST program for our review.
What are the bases used to assign the limiting values of full-stroke time for these valves?
6.
'Hhen flow through a check va1ve is used to indicate a fu11-stroke exercise of the valve disk, the NRC staff position is that verification of the maximum flow rate 'identified in any oF the plant's safety analyses through the valve would be an adequate demonstration of the full-stroke requirement.
Any Flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve.
Does the Nine Mile Point Nuclear Station, Unit 2, IST program conform to this staff position2 7.
The relief request and cold shutdown justification bases should indicate the negative consequences that make testing at the Code required frequency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.
8.
Which valves at Nine Mile Point Nuc1ear Station, Unit 2, are currently leak rate tested to verify a pressure boundary isolation function2 9.
Provide a more detailed technical justification for not testing the excess flow check valves quarterly during power operations and during cold shutdowns (refer to General Relief Request GVRR-2).
10.
How are the remote position indicators being verified for solenoid operated valves in the Nine Mile Point Nuclear Station, Unit 2, IST program2 ll.
Section 1.3.2 on page 1-3 states that "certain components" may be upgraded to later editions and addenda of the Code.
The NRC staff position is that individual components cannot be upgraded by
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TSAR.B I
NO. 8 themselves, the entire pump program and or the entire valve program should be based on the same edition and addenda of the Code.
12.
Provide P8 IDs 52A AND 52G For our rev1ew.
B.
Reactor 8 ildin Cl e
11 S ste 1.
How are valves 2CCP~V143, V148, V161, and V277 verified to full-stroke during quarterly exercising?
C.
~H1 h Pressure Core S rs S stem 1.
P~ovide a more detailed technical Justification that explains why valve 2CSH~AOV108 cannot be exercised utilizing system flow quarterly during power operations (refer to cold shutdown test justification CSH-VCS-I).
2.
Qo valves 2CSH~V17 and VSS perform a safety-related funct1on 1n the closed position?
If so, how is the reverse flow closure of these valves 1ndividually verified?
3.
Re11ef Request No.
CSH-VRR-I refers to IE Bulletin 83-03 for valve 2CSH*V59, however, th1s bullet1n does not apply to this valve, but only to check valves 1n raw water cooling systems of diesel generators.
Valve disassembly and inspection is an acceptable method to verify the reverse flow closure of a check valve, but this is not the preferred method.
Mhat other test methods have been considered for this valve?
4.
How is valve 2CSH*V7 verified to full-stroke exercise open during quarterly test1ng?
0.
1.
Provide a more deta1led technical Justification that explains why valve 2CSL*AOV101 cannot be exerc1sed utilizing system flow
I
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k
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TSA8B NO. 6 quarterly during power operations (refer to cold shutdown test justificati on CSL-VCS-1).
2.
Provide a more detailed technical Justification for not exercising valve 2CSL*NOV104 quarterly during power operations (refer to cold shutdown test Justification CSL-VCS-2).
3.
Do valves 2CSL~VI4 and V21 perform a safety-related function in the closed position?
If so, how is the reverse flow closure of these valves individually verified?
4.
How is the reverse flow closure verified for valve 2CSL"V9 during quarterly testing?
5.
Does valve 2CSL*V4 perform a safety-related function in the closed position?
If so, how is the reverse flow closure oF this valve verified?
E.
Sta d
Generator S t 1,
How would testing valves 2FGA+V62A, V628, V63A, and V638 as a unit on the standby diesel generator skid individually verify their reverse flow closure capability>
2.
Review the safety-related function of the emergency diesel generator air start valves (2EGA*PCV25A, PCV258,
- PCV26A, PCV268, AOV323A, and AOV3238) and the associated in-line check valves (2EGA*V12A, V128, V14A, and V148) to determine if they should be included in the IST program.
Protectio r S st 1-Are the valves on either side of containment penetration l-46C (PAID No. 43G-6 coordinates H-4) Appendix J, Type C, leak rate tested as containment isolation valves?
IF so they should be included in the IST program and tested to the Code requirements.
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TSA&B NO. E I.
~Fd t 1.
What type of leak test do valves 2FMS*HOV21A and V218 receiveg The leak test type is not specified in the NHP-2 IST program valve
- tables, 2.
Provide a more detailed technical justification for not verifying the reverse flow closure of valves 2FWS*VIZA and V128 during cold shutdowns.
H.
Nitro en I.
What is the safety-related function of valves 2GSN*RV32A, RV32B, RV34A, RV34B, V70A, and V'JOB?
I.
nstru e t Air S m
Provide a more deta1led technical justification for not ver1fy1ng reverse flow closure for the valves ident1fied 1n relief request No.
IAS-VRR-2 quarterly and during cold shutdowns.
Identify the specific concerns that make this test1ng impractical to perform quarterly and during cold shutdowns.
2.
If credit is taken in acc1dent analysis for the a1r supply to the main steam safety rel1ef valve accumulators TK-14 thru 31, then their associated supply line check valves perform a safety-related function and should be included in the IST program and tested to the Code requirements.
3.
Now are valves ZIAS"RV33A, RV33B, RV34A, RV34B, RV35A, RV35B,
- RV36A, and RV36B ver1fied to full-stroke exercise quarterly?
J.
eac ore Is n Coo 5 ste 1.
Prov1de a mor e detailed technical justification that expla1ns why valves 2ICS~AOV156 and AOVl57 cannot be exercised open utilizing
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TSA&B HO.t I
system flow quarterly during power operations.
How is the reverse flow closure of these valves being verified during testing at cold shutdowns (refer to cold shutdown test )ustification ICS-VCS-2)?
2, Is design accident flow verified through valve 2ICS~V29 during quarterly valve testing?
If not, how is this valve full-stroke exercised (refer to the comment in Item A.6)?
3.
How is it verified that valve 2ICS*V38 is full-stroke exercised during the quarterly valve testing?
4.
Provide a more detailed technical justification that explains why it is not possible to perform the special air test to verify the forward flow capability of valves 2ICS+V39 and V40 either quarterly during power operations or during cold shutdowns (refer to Relief Request Ho. ICS-VRR-1).
5.
Does valve 2ICS*PCV115 have a re~Luu+ fail-safe position? If so, in addition to testing its fail-safe function, this valve must be exercised and have its full-stroke time measured in accordance with the Code.
6.
Review the safety-related function of valve 2ICS*FY108 (PAID PIO-35D-3 coordinates 0-2) to determine if it should be included in the IST program.
7.
How is the reverse flow closure verified for valve 2ICS~V27 during quarterly testing?
8.
Provide a more detailed technical Justification for not full-stroke exercising the RCIC turbine trip throttle valve 2ICS*HOV150 quarterly during power operations (refer to Relief Request No, ICS-VRR-2),
This valve was deleted from the IST program in the July l987 revision.
18~26r87 16: ='8 l.
If valves ZHSS*SOV97A,
- SOV978, SOV97C, and SOV97D have fail-safe actuators then they should be included in the IST program and tested in accordance with the Code requirements.
2.
Provide a more detailed technical )ustification that explains why repeatable test conditions cannot be established when testing the ADS valves during reactor refueling outages to allow measurement of meaningful valve stroke times in order to provide a means to detect valve degradation (refer to Relief Request No. HSS-VRR-l).
3.
Are the ADS and main steam safety relief discharge line vacuum breakers actually relief valves as shown on the PKIDs or are they simple check valves?
If they are check valves, they should be exercised as Category C valves in accordance with the requirements of IQV-3520, L
IUL I.
Provide a more detailed technical Justification for not exercising the following valves during cold shutdowns (refer to Relief Request No. RCS-VRR-Z).
2RCS*SOV6SA ZRCS*SOV658 2RCS*SOV79A 2RCS*SOV798 2RCS*SOV66A 2RCS*SOV668 2RCS*SOVBOA ZRCS~SOV808 2RCS*SOV67A 2RCS*SOV67B ZRCS*SOV8IA 2RCS*SOVBIB 2RCS*SOV68A 2RCS*SOV688 2RCSASOV82A 2RCS*SOV828 H.
C Rod ve lic te l.
Provide a discussion that explains how it was determined that "the technical specification for control rod scram insertion time testing meets the intent of Section XI testing requirements" (refer to Relief Request No. RDS-VRR-l).
2.
Hhat is the frequency for scram testing the control rods at Nine Nile Point, Unit 2 (how many rods are tested at what interval)7
18/2~87 16: 31 EGRG ID.
Tc~AEB 3.
Provide a more detailed technical justification for not exercising the 2RDS*115 valves during cold shutdowns (refer to Relief Request No. RDS-VRR-2).
4.
Provide a more detailed discussion about the alternate testing being performed to verify the reverse flow closure of the 2RDS*138 valves (refer to Relief Request No.
RDS-VRR-3).
N.
es Keat val S st 1.
Provide a more detailed technical justification that explains why valves 2RHS*AOVlSA, AOV16B, and AOV16C cannot be exercised utilizing system flow quarterly during power operations (refer to cold shutdown test justification RHS-VCS-1).
2.
Provide a more detailed techn1cal justification that explains why valves 2RHS*AOV39A and AOV39B cannot be exercised utilizing system flow quarterly dur1ng power operations (refer to cold shutdown test justification RHS-VCS-3).
3.
Provide a more detailed technical justificat1on for not exercising valves 2RHS*HOV24A, NV24B, and HOV24C quarterly during power operations (refer to cold shutdown test justification RHS-VCS-2).
4.
The cold shutdown testing section of cold shutdown test justification RHS-VCS-8 implies that valves 2RHSOOV67A and HOV678 are not exercised during each cold shutdown but only during those cold shutdowns when certain conditions are met.
Clarify this paragraph to ind1cate the test1ng that is actually performed on these valves.
5.
How is it verified that valves 2RKS*V7, VS, and V9 are full-stroke exercised during quarterly testing2 6.
Mhat percent of a full-stroke 1s possible using the air operator when exerc1s1ng testable check valve 2RKS*AOV1507
18r26r87 16:31 EG8,6 ID.
TSRS,B NO. Bt r
7.
Review the safety related function of valves 2RHS*NOV26A, NOV26B, NOV27A, and NOV278 to determine if the Category A classification is appropriate.
If this categorization is correct, these valves should be leak tested to verify their leak tight capability.
8.
What testing is performed on valves 2RHS*V117, V118, V19, and V20?
The testing method is not clear from the valve listing table.
9.
Review the safety-related function of valves 2RHS*LV17A and LV178 (PKIDs PIO-31D-1 and -31E-1 coordinates G-5 and D-6 respectively) to determine if they should be included in the IST program.
10, Are 2RHS*RVV3SA, RVV35B, RVV36A, and RVV36B relief valves as shown on the PKIOs or simple check valves as indicated in the valve table?
If they are check valves, they should be exercised as Category C valves in accordance with the requirements of IWV-3520, 11.
Why are the following valves not setpoint tested in accordance with the Code requirements?
Is their only function to provide thermal expansion overpressurization protection?
2RHS~RV61A 2RHS*RV110 2RHS*RV618 2RHS*RV139 2RHS*RV61C 12, If valves 2RHS*V47, V48, V60, and V61 perform a safety-related function in the closed position as identified in the IST program valve table, then their reverse flow closure should be individually verified during quarterly valve testing.
13.
Provide a more detailed technical Justification for not full-stroke exercising valves 2RHS*NOV22A, NOV228, NOV80A, and NOVBOB quarterly during power operations (refer to cold shutdown justification RHS-VCS-10).
dy
1826z87 16:32 EGS,G ID.
TSA8B NO.8 14.
Oo valves 2RHS*Y17 and V18 perform a safety-related function in the closed position?
If so, reverse flow closure should be verified for~ of these check valves in accordance with the Code requirements, 15.
Review the safety-related function of valves 2RHS~PY21A and PV21B (PBIDs PIO-310-1 and
-31G-1 coord1nates D-9 and J-2 respectfvely) to determine if they should be included fn the IST program.
16.
There are several valves 1n the RHS that are Categorized 'A'r
'AC'nd identif1ed in the valve tables to be leak tested,
- however, no leak test type or frequency has been specified 1n the test interval column.
'Hhat testing is befng performed on these valves to ver1fy their leak tight integrity?
17.
Does valve 2RHS*Y3 perform a safety-related function 1n the closed position? If so, reverse flow closure should be verified fn accordance with the Code requirements.
18.
Do any Nine bafle Point, Unit 2, accident analyses take credit for the operatfon of the steam condensing mode of the residual heat removal system?
If so, valves 2RHS*V13 and V14 (PAID PID-31D-4 coordinates H-5 and H-2 respectively) should be included fn the IST program and tested in accordance with the Code.
0.
1.
How are the following valves full-stroke exercised quarterly?
2SFC*V300A 2SFC*V3008 2SFC*V301A 2SFC*V3018 2SFCAV302 2SFC1 V303 f:
2.
Review the safety-related function of valves 2SFC*HV35A, HV358, HV54A, and HV548 (PHDs PID-38A-1 and -38B-1) to determine if they should be included in the IST program, Do these valves have Zp~iliir,g fail-safe posit1ons?
10
18i26i87 16: 33 EGKG ID.
TSA8B NO. 8 813 4
3.
Nhat safety-re'lated systems provide cooling to the spent fuel pool?
Are all of the safety-related pumps and valves fn these systems included in the IST program and tested to the Code requirements?
P.
ta d
i ui rol S
1.
Provide a more detailed technical justification for not verifying forward flow operability of valves 2SLS*MOV5A, HOV5B, and V10 during cold shutdowns (refer to Relief Request No. SLS-VRR-1).
2.
Provide a more detailed technical justiffcatfon for not verifying reverse flow closure of valves 2SLS"V12 and V14 during cold shutdowns (refer to Relief Request No. SLS-VRR-2).
How is forward flow operability of these valves veriffed during testing?
3.
Review the safety-related function of valve 2SLS*HCV116 (PAID PID-36A-6 coordinates I-3) to determine if ft should be included in the IST program and tested to the Code requirements.
g.
erv Mate te 1.
Provide a more detailed technical justification for not exercising the following valves during cold shutdowns (refer to Relief. Request Ho. SIP-VRR-3).
2SMP*HOV3A ZSMP~HOV38 2SMPSOV599 2SQP HOV19A 2SQP*HOVSOA 2SMP%0V93A 2SM~OY198 2SMP*HOVSOB 2SMP*HOV93B 2SMPV202B 2.
Provfde a more detailed technical justfffcatfon for not exercising valves 2SMP*V202A, V1024, V1025, and V1027 during cold shutdowns (refer to Relief Request No. SMP-VRR-4).
How fs reverse flow closure verified for these valves?
11
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TSASB NO. 8 814 Review the safety-related function of valves 2SWP+NOVIA, NOVlB, HOVIC, HOYIO, MOVIE, and MOVIF (P810s PIG-llR-7 and -llB-5) to determine if they should be included in the IST program and tested to the Code requirements.
4.
Valve sample disassembly and inspection utiliz1ng a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capability, This program involves grouping similar valves together and testing one valve in each group during each refueling outage.
The sampl1ng technique requires that each valve in the group be of the same des1gn (manufacturer,
- size, model number and materials of construction) and have the same service conditions.
Add1tionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A different valve of each group is required to be disassembled, inspected and manually full-stroke exercised at each refueling outage, until the entire group has been tested.
If it is found that the disassembled valve's full-stroke capability is 1n
- question, the remainder of the valves in that group must also be disassembled, inspected and manually full-stroke exercised during the same outage.
Ooes the Nine Nile Po1nt Nuclear Stat1on, Unit 2, disassembly and inspection program for valves 2SWP~V201A,
- V201B, VBOOA, VSOOB, V802A, and V802B conform to this staff pos1tion (refer to Relief Request No.
SWP-VRR-1)V 5.
Provide a more detailed technical justification for not exercis1ng valves 2SWP*FV47A, FV478, FV54A, and FVS4B during cold shutdowns (refer to Rel1ef Request No.
SWP-VRR-5).
The Nine Nile Point, Unit 2 IST program valve table does not indicate that remote valve posit1on ind1cation verificat1on is 12
1Q/26/87 16: 34 EG8G 1D.
TSAS,B
~ ~
815 performed for valves 2SWP*AOV78A and AOV78B.
Are these valves equipped with remote valve position indication?
If so, this indication should be verified 1n accordance with the Code requirements.
7.
Where "periodic testing" is ident1fied in the remarks section for service water system valves, 1f this testing Frequency is less than quarterly then a cold shutdown justification or relief request must be provided for the increased interval.
8.
Provide a more detailed technical justification for not exercising valves 2SWP*MOV77A and MOV77B during cold shutdowns (r efer to Rel1ef Request No, SWP-VRR-Z).
9.
Review the safety-related funct1on of valves 2SWP*MOV15A and MOV15B (PLIDs PID-11G-4 and 11P-5, coordinates B-7 and G-2 respectively) to determine if they should be included in the IST program and tested to the Code requ1rements.
10.
.How is the reverse flow closure of valves 2SWP*V219A and V219B verified during quarterly testing?
11.
Do valves 2SP'TV35A and TV35B (PKIO PID-118-6, coordinates G-6 and B-6) have ~u~ fail-safe positions?
If so, they should be included in the IST program and tested in accordance with the Code requirements.
12, How is the reverse flow closure of valves ZSWP*V75A and V75B verified during quarterly testing?
R.
eac t
eau s
Provide a more detailed technical Justification for not exercising valve 2WCS~V112 quarterly in accordance w1th the Code requirements (refer to cold shutdown test Justification WCS-VCS-1).
c 13
18/26/87 16: M EGS,G I D.
TSAEB
~ ~
NO.I Z.
Review the safety-related function of valves 2WCS*MOV128 and HOV129 (P8ID PID-67A-6, coordinates E-9) to determine if they should be included in the IST program and tested to the Code requirements.
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TSA8B 817 2.
PUHP TESTING PROGRAM 1.
Provide a more detailed justification for not using vibration monitoring instrumentation that meets the accuracy requirements of Section XI IMP-4110 to measure pump bearing vibration at N1ne Mile Point Nuclear Station, Un1t 2, (refer to General Pump Relief Request No. GPRR-2).
2.
Provide a more detailed justification for not measur1ng the pump bearing temperatures of the spent Fuel pool cooling pumps yearly (refer to Relief Request No. SFC-PRR-1).
Lack of installed instrumentation is not an acceptable )ustification for not measuring this Code required parameter.
3.
What is the technical basis for the allowable vibration velocity ranges identified in General Pump Relief Request No.
GPRR-1?
Are the indicated ranges based on peak vibration readings or on RHS values?
4, The Nine Mile Point Nuclear Station, Unit 2 pump inservice testing program does not address the observation of pump lubricant level or pressure.
Describe how th1s IST test quantity is observed as required by Section XI, IWP-3100.
The Nine Hile Point Nuclear Station, Unit 2 pump inservice testing program indicates that pump bearing temperature is not an appl1cable test parameter for 13 of the 27 pumps listed.
Identify the reasons that this test quantity is not appl1cable for these safety related pumps.
6.
Relief Request No.
EGF-PRR-1 for the diesel fuel oil transfer pumps indicates that flow rate 1s determined by measuring day tank level versus time during pump quarterly test1ng.
The system PtLID shows a
flow instrument in the normal flow path to the day tank, why 1sn't this 1nstrument used to perform this testing?
If the change in day tank level versus time method is utilized, does it meet the accuracy requirements of IWP-4110?
15
1gi26r87 16: ='5 818 T.
How are pump inlet pressure, differential pressure, and flow rate measured for the ICS system pressure pump (2ICS*P2) during quarterly pump testing?
8.
Lack of adequate 1nstrumentation is not an acceptable justification for not measuring standby liqu1d control pump flow rates to the Code required accuracies dur1ng pump quarterly testing (refer to Relief Request No. SLS-PRR-I).
Can new instrumentation be obtained or the existing instrumentation be calibrated differently such that the measured pump flow rates meet the requirements of IWP-4110?
9.
The Nine Mile Point Nuclear Station, Unit 2 pump inservice testing program indicates that pump bearing temperature is not an applicable test parameter for the standby liquid control pumps (2SLS~PIA and PlB), however, Relief Request Ho.
SLS-PRR-2 was provided requesting relief from measuring th1s Code parameter.
Clarify this inconsistency 1n the IST program.
l0.
Lack of adequate instrumentation is not an acceptable justificat1on for not measuring the flow rates for condenser water pumps 2SWP*P2A and P2B to the Code required accuracies during pump quarterly testing (refer to Relief Request No. SWP-PRR-I).
Can new instrumentation be obtained or the existing instrumentation be calibrated differently such that the measured pump flow rates meet the requirements of IMP-41IO?
11.
Lack of installed instrumentation is not an acceptable justification for not measuring the pump bearing temperatures for the service water pumps (refer to Relief Request No.
SWP-PRR-2).
Also, the pumps 11sted on this relief request are not the same pumps that reference this relief request in the pump test1ng por t1on of the IST program.
~ '
1~26~87 16: Z6 c4
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NO.Bt 12.
Lack of adequate instrumentation is not an acceptable justification for not measuring and trending pump differential pressures for condenser water pumps 2SWP~P2A and P2B in accordance with the Code.
The proposed testing does not provide sufficient information to determine pump hydraulic condition and to detect hydraulic degradation (refer to Relief Request No.
SWP-PRR-3).
'What is the safety function of these pumps?
17
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