ML17319A765
| ML17319A765 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/23/1981 |
| From: | Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17319A764 | List: |
| References | |
| 810312, AEP:NRC:0516, AEP:NRC:516, NUDOCS 8103180123 | |
| Download: ML17319A765 (8) | |
Text
1 INDIANA L MICHIGAN ELECTRIC COMPANY P. O. BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 1000i February 23, 1981 AEP:NRC:0516 Donald C.
Cook Nuclear Plant Unit Nos.
1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-.74 Mr. James G. Keppler, Regional Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III Glen Ellyn, Illinois 60137
Reference:
NRC IE Inspection Reports Nos. 50-315/80-20 and 50-316/80-16 Dated January 23, 1981
Dear Mr. Keppler:
This letter and the enclosed attachment are in response to the NRC IE Inspection report referenced above and addresses the two action items noted in Appendix A to the Inspection Report.
Following the telephone conversation between our Mr. Castresana and your. Mr'. Heishman on February 17, 1981, an extension of one week was granted to us to respond to the referenced Inspection Report.
Very truly yours,
'nter Vice President cc:
R.
C. Callen G. Charnoff John E.
Dolan - Columbus R.
M. Jurgensen D. V. Shaller - Bridgman (w/attachment)
Region III Resident Inspector at Cook Plant - Bridgman (w/attachment)
~09gae 0>
FE8 2 7. 19ul
STATE OF NEW YORK
)
)
COUNTY OF NEW YORK )
R.
S. Hunter, being duly sworn, deposes and says that he is a
Vice President of licensee Indiana 8 Michigan Electric Company, that he has read the foregoing response to IE Inspection Reports Nos. 50-315/80-20 and 50-316/80-16 and knows the contents thereof; and that said contents are true to the best of his knowledge and
~
~
~
belief.
Sworn and subscribed to before me this wS -day of February, 1981 M~~A7~ /
Notary Public yp
~y>gl
~ /T',)p
'I I'
ATTACNENT TO AEP: NRC:0516 The following is our response to the items noted in Appendix
'A'f the subject NRC IE Inspection Report.
A endix A Item 1.
Under the direction of the Plant Operations Superintendent, all proce"ures relative to safety-related pump operability were reviewed to verify inclusion bf the 15 minute criterion on the pump operation.
As a result of this revic:;,
eight procedures were identified which did not specifically note the 15 minute criterion.
Temporary change sheets to these procedures were initiated, and reviewed by the Plant Nuclear Safety Review Cormittee and approved by Plant Manager on February 10, 1981.
Full compliance has been achieved as of the date of this letter.
A endix A
Item 2.
This item of non-compliance states that, "...the licensee's ISI pump operability test program did not establish reference values for pump inlet pressure as required by AS."iE Section XI Article Il!P-3110."
Indiana 5 Hichiaan Electric Company agrees that proper pump inlet pressure is critical for determining pump operability.
Plant procedure 12-THP-4030-STP-222, "ISI Pump Test Progam" requires inlet pressure be measured before and after pump sta! tup and during testing.
- However, we do not agree with the, Inspection Report con-clusion that reference values be set for inlet pressure for the following reasons.
Article IWP-3110 of AS,"lE Section XI states that the test quantities stated in Table IWP-3100-1 shall be measured and compared with the reference values.
Any deviations determined shall be compared with the limits given in Table IWP-3100-2 and, if necessary, specified corrective action must be taken.
Table IWP-3100-2 specifies no limits to the test quantity Pi (inlet pressure).
However, footnote (1) to the table states that the measured value of the inlet pressure Pi shall be within the limits specified by the owner in the pump record.
Our Plant Procedure No. 12-THP-4030-STP-222, "ISI Pump Test Program," requires that inlet pressure be measured before and after pump startup and during test.
In particular, Article IWP-3110, "Reference Values," states in its entirety:
"Reference values are defined as one or more fixed sets of values of the quantities shown in Table IWP-3100-1 as measured or observed when the equipment is known to be operating acceptably.
All subsequent test results shall be compared to these reference values or to new reference values established in accordance with paragraphs IWP-3111 and IWP-3112.
Reference values shall be deter-mined from the results of an inservice test which may be run during preoperational testing or from the results of the first inservice test run during power operation.
Reference values shall be at points of operation readily duplicated during subsequent inservice testing."
Our interpretation of the last sentence in the above article requires that reference values must be duplicated during all subsequent pump tests.
Below are possible suction sources for the subject pumps tested per ASNE Section XI:
Refueling Water Storage Tank Condensa'te Storage Tank Screenhouse Forebay Reactor Coolant System Volume Control Tank Boric Acid Storage Tank Component Cooling Water Surge Tank The inlet pressure parameter for all these sources is a function of system conditions at the time of the test.
To change the system condition" to produce a duplicate suction pressure for each pump test would not be practical or possible.
Reference values for pump inlet pressure, as described in ASl1E Section XI, Article IWP, do not provide any useful info)'-
mation with regard to pump performance.
Section XI Article IWP is only cori-cerned with degradation in pump performance.
Pump performance is properly indicated byDP, provided the inlet pressure is maintained at or above the NPSHR*.
Therefore, in this regard, the only value that need be set for pump suction pressure is the NPSHR which is the base limit below which the pump could not operate properly.
The NPSHR value is already incorporated in all of the p'lant pump test procedures.
The&P values measured in each test are documented and compared with&P f values obtained during normal operation.
ref Plant procedure 12-THP-4030-STP-222, "ISI Pump Test Program" specifies reference values be obtained by one of three methods:
1) preoperational testing
- 2) first inservice run during power operation 3) after a
pump has been replaced, a
new set or sets of reference values shall be determined from the results of the first inset vice test run after the pump is put into service (reference IWP-3111).
It is our concern as well as that of the NRC inspector's that subsequent pump data be accurate in identifying degrading trends based on the reference values.
It is the NRC inspector's interpretation that measurement accuracy is assured by establishment of reference
- values, although the code does not state this.
The plant procedure for ISI Pump Testing relies on the stated requirements of IWP-4113 in ASNE Section XI, "Calibration."
This article states:
"All instruments, together with their transmitters where used, shall be calibrated prior to the establish-ment of reference quantities.
All new or repaired instruments shall be calibrated prior to test use..
A system of calibration records shall be used to identify each instrument and its date of calibration, or alter-natively each instrument may contain an attached tag
- NPSHR - Net positive suction head required.
l
or sticker that records the date of last calibration.
Except as required above, all instruments used for these tests shall be verified for calibration validity on a regular basis as established by the Owner'ABLE IltP-4110-1 NONIHAL NAXINUN INSTRUNEHT ERRORS Pressure Differential pressure Flowrate Speed Temperature Vibration amplitude
+ 2/ of full
+ 2/ of full
+ 2N of full
+
2".. of full
+ 5~ of full
+ 5X of full scale scale scale scale scale scale Indiana 8 Yiichigan Electric as the Owner has established a pro-gram to verify calibration validity on a regular basis by plant procedure 12 THP 6030 INP.045, 'nstrument Calibration System'.
The objective of this procedure is to ensure routine instrumentation measuring, and test instru-ments are routinely calibrated.
ISI instruments are classified 'Priority B'er the plant procedure, Priority B states:
'Priority B shall include the instrumentation and controls from which indication is required by the Technical Specifications but a channel calibration is not specified.
The calibration frequency of priori,ty B Instrumentation and Controls shall be 18 months with an allowable extension not to exceed 25%
(i.e. 4.5 months).'ased on the above technical reasons we strongly feel that reference value for the inlet pressure is not the critical test quantity to accurately identify degrading trends in the pump operability.