ML17333A470
| ML17333A470 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/08/1996 |
| From: | AMERICAN ELECTRIC POWER CO., INC. |
| To: | |
| Shared Package | |
| ML17333A469 | List: |
| References | |
| AEP:NRC:0969AM, AEP:NRC:969AM, PROC-960208, NUDOCS 9606200173 | |
| Download: ML17333A470 (23) | |
Text
ATTACHMENT 2 TO AEP:NRC:0969AM IN-SERVICE PUMP TEST PLAN 9'606200f73 9606f2 lf PDR ADQCK 050003i5)
P r Da~~
DONALD C. COOK NUCLEAR PLANT-UNIT 1 ASME OMa-1988 Addenda Part 6 Pump In-service Test Program The pump test program was developed using ASME OMa-1988 Part 6 including clarifications contained in NUREG-1482 ("Guidelines for In-service Testing at Nuclear Power Plants," April 1995) and later editions of ASME/ANSI OM Part 6 and OM Code Subsection ISTB, except for specific code relief requested in accordance with 10CFR50.55a(f)(5)(iii).
This program is for the 3rd ten year inspection/test interval; commencing July 1, 1996 for Unit 1.
The program was developed employing the classification guidelines contained in Regulatory Guide 1.26, Revision 2 for Quality Groups B and C, and the definition of the reactor coolant system boundary contained -in 10CFR50.2(v) for Group A. (Quality Groups A, B, and C are the same as ASME Class 1, 2, and 3, respectively) . Table A identifies the following:
The pump number and service it pexforms along with the identification number of the drawing on which it is found.
II. The applicable test parameters:
Speed, for variable speed pumps only.
Discharge Pressure, for positive displacement pumps only.
Differential Pressure-determined as the difference between discharge and suction pressure.
4 ~ Flow rate.
- 5. Vibration amplitude.
III. The test frequency required The Emergency Diesel Generator Fuel Oil Transfer Pumps and the Emergency Diesel Generator Jacket Water Cooling pumps are outside the ASME Code Boundary. In accordance with NUREG 1482 Section 3.4, GL 89-04 Attachment 1, and 10CFR50 Appendix A and Appendix B, these pumps perform a function that is important to safety of the plant. Due to this importance to safety, these pumps will be subjected to periodic testing.
Revision 0 Page l of 9 02/08/96
DONALD C. COOK NUCLEAR PLANT - UNIT I PUMP INSERVICE TEST PROGRAM TABLE A PROGRAM
SUMMARY
TEST PARAMETERS Discharge Differential Flow Vibration Pump Speed Pressure Pressure Rate Amplitude Test Pump Service Number (N) (P) (~P) (Q) (V) Frequency (Drawing No.)
Auxiliary Feedwater PP-3W No No Yes Yes Yes Quarterly
'1-5106A)
PP-3E No No Yes Yes Yes Quarterly PP-4 Yes No Yes Yes Yes Quarterly Essential Service Water PP-7W No No Yes Yes Yes Quarterly (1-5113) PP-7E No No Yes Yes Yes Quarterly Centrifugal Charging PP-50W No, No Yes Yes Yes Quarterly (1-5129) PP-50E No No Yes Yes Yes Quarterly Boric Acid Transfer PP-46-1 No No Yes Yes Quarterly (12-5131) PP-46-2 No No Yes Yes Yes'es'es Quarterly
'o Component Cooling Water PP-10W No Yes Yes Quarterly (1-5135A)
Safety injection PP-10E PP-26N PP-26S No No No No Yes Yes Yes Yes Yes Yes Quarterly Quarterly 4
'1-5142)
No No Yes Yes Yes Quarterly Residual I leat Removal PP-35W No No Yes Yes Yes Quarterly
'1-5143)
PP-35E No No Yes Yes Yes Quarterly Revision 0 Page 2 of 9 02/08/96
DONALD C. COOK NUCLEAR PLANT - UNIT I PUMP INSERVICE TEST PROGRAM TABLE A PROGRAM
SUMMARY
TEST PARAMETERS Discharge Differential Flow Vibratton Pump Service Pump Speed Pressure Pressure Rate Amplitude Test (Drawing No.) Number (N) (P) (h,P) (Q) (V) Frequency I
Containment Spray PP-9W No No Yes Yes Yes4 Quarterly
'1-5144)
PP-9E No No Yes Yes Yes4 Quarterly Diesel Fuel Oil fransfer QT-106-AB1 No Yes 'o Yes Yes Quarterly QT-106-A 82 No Yes No Yes Yes Quarterly
'1-5151A
& C) QT-106-CD I No Yes No Yes Yes Quarterly QT-106-CD2 No Yes 'o. Yes Yes Quarterly Spent Fuel Pit Cooling 12-PP-31N No No Yes Yes Yes 'Quarterly (12-5136)I Jacket Water QT-130-AB1 No No Ycs Yes Ycs Quarterly (1-51518 & D) QT-130-AB2 No No Yes Ycs Yes Quarterly QT-130-CD I No No Yes Yes Yes Quarterly QT-130-CD2 No No Yes Yes Yes Quarterly a RR These pumps arc tested on test, bypass, or minimum Aow loops per ASMH OMA-1988 Part 6, $ 3.2.
b Refer to Comment 1.
Refer to Comment 2.
Refer to Code Relief Request 1.
Refer to Code Relief Request 2.
f xa Refer to Code Relief Request 3.
g Only North Spent Fuel Pit Pump shown here due to the alignment of its cooling train to Unit I Component Cooling Water.
Revision.0 Page 3 of 9 02/08/96
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DONALD C. COOK NUCLEAR PLANT - UNIT 1 PUMP INSERVICE TEST PROGRAM COMMENT 1 Emergency Diesel Generator FOTP The duration of pump operation for testing, per ASME OMa-1988 Part 6, Subsection 5, Paragraph 5.6; "Duration of Tests", will be amended for the Diesel Fuel Oil Transfer pumps.
These pumps supply the diesel generator fuel oil day tank. A conservative level is maintained in the tank to meet the minimum capacity per Technical Specification requirements. Due to the limited capacity of this tank, the pump operating test range is limited to the time required to fillthe tank.
Therefore, test parameters willbe recorded immediately after pump operation has stabilized.
Revision 0 Page 4 of 9 02/08/96
DONALD C. COOK NUCLEAR PLANT - UNIT 1 PUMP INSERVICE TEST PROGRAM COMMENT 2 EDG FOTP Vibration Data Points Vibration measurement requirements, per ASME OMa-1988 Part 6, Subsection 4, paragraph 4.6.4, Vibration Measurements, will be amended for the rotary positive displacement Emergency Diesel Generator Fuel Oil Transfer Pumps. Vibration measurement will be taken at a single point on the gear box adjacent to all four gear shaft bearings. Due to the limited capacity of the tank to which the pump discharges to (EDG Day Tank), the pump operating time is limited and would prohibit recording multiple vibration readings.
Revision 0 Page 5 of 9 02/08/96
COOK NUCLEAR PLANT PUMP IST PROGRAH REL'IEF REQUEST NO. 1 TITLE: Containment S ra Pum Vibr ation Limits General O Specific X
Unit Applicability: 1 2 X 1 and 2 PUMP NAME: Containment S ra PUMP NUMBER(S): PP-009 SYSTEM: Containment S ra CTS FLOW DIAGRAM: 5144 ASHE CLASS: 2 PUHP FUNCTION: Provide cool water flow to s ra the containment atmos here in a LOCA or steamline break.
RELIEF TYPE D X COMPLIANCE WITH CODE REQUIREMENTS ASHE CODE TEST REQUIREMENT
REFERENCE:
IS IMPRACTICAL OMa-1988, Part 6. Table 3a Ranges for vibration test parameters CODE REQUIREMENT DESCRIPTION: (for centrifugal pumps >600 rpm)
Acceptable range <2.5 vibration reference value (V)
Alert range >2.5 V to 6 V or >0.325 in/sec Required action range >6 V or >0.70 in/sec BASIS THAT COMPLIANCE WITH CODE REQUIREMENTS IS IHPRACTICAL:
The design of the CTS pumps utilizes a. four vane impeller in a double volute casing. This combination of an impeller with an even number of vanes operating in a casing with two volutes creates a high, reinforced vibration response at the vane passing frequency (7200 cpm). This condition is further compounded by the fact that the quarterly IST tests are performed at only 25X of the pump's design flow. This results in the discharge angle of the impeller flow -not matching the stationary volute angle, producing high interaction forces between the impeller and the volutes. This high vane pass frequency amplitude is the major component of'verall amplitude and is not indicative of overall pump condition. On this basis, compliance with the referenced acceptance criteria would be impractical due to the burden created by unnecessary repair and replacement of otherwise suitable pump components.
PROPOSED ALTERNATE TESTING:
Acceptable range <2.0 V Alert range >2.0 V to 4.0 V or 1.2 in/sec Required action range >4 V or 2.0 in/sec BASIS A!TERNATE TESTING YIELDS ACCEPTABLE LEVELS OF QUALITY AND SAFETY:
Although the overall vibration amplitude is increased over the alert and required action limits of ASME OHa-1988, Part 6, Table 3a, the proposed alternate values
.are based upon our review of past operating data for these pumps. The values are a more representative basis for trending performance of the containment spray um s; and,as such rovide an acce table level of uality and safety.
'OOK NUCLEAR PLANT PUMP IST PROGRAM RELIEF REQUEST NO. 2 TITLE: ricAcidTr n ferP m ialVi rai n e ure ent General H Specific Unit Applicability: I + 2 H I and 2 PUMP NAME: 8 ric c'd Transfer Pum PUMP NUMBER(S): 1- 2 2-PP 4 SYSTE<M: VC - ake SLAW DIASSAM: ~l- I ASMS CLASS: S PUMP FUNCTION: Transfer ric cid I i rom tora etankt char in um ucti eader RELIEF TYPE COMPLIANCE WITH CODE REQUIREMENTS IS IMPRACTICAL ASME CODE TE<ST REQUIREMENT
REFERENCE:
OMa-1 988, Part 6, Paragraph 4.6.4(a)
CODE REQUIREMENT DESCRIPTION:
On centrifugal pumps, measurements shall be taken in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each accessible pump bearing housing. Measurement also shall be taken in the axial direction on each accessible pump thrust bearing housing.
BASIS THAT COMPLIANCE WITH CODE REQUIREMENTS IS IMPRACTICAL:
The pump thrust bearing housing is inaccessible. It is very close to the coupling, and safety considerations prevent placement of the probe. In addition, the housing is partially blocked by the impeller adjustment nuts.
PROPOSED ALTERNATETESTING:
Take measurements in a plane approximately perpendicular to the shaft in two orthogonal directions on each accessible pump bearing housing.
BASIS ALTERNATETESTING YIELDS ACCEPTABLE LEVELS OF QUALITYAND SAFETY:
Measurements taken in planes perpendicular to the shaft in two orthogonal directions have provided adequate data to evaluate pump performance and condition.
Revision 0 Page 7 of 9 02/08/96
COOK NUCLEAR PLANT PUMP IST PROGRAM RELIEF REQUEST NO. 3 TITLE: Su ersede OMa-1988 Corrective Action Part 6 Para ra h 6.1 X General Unit Applicability:
1 2 X 1 and 2 PUHP NAME:Various PUHP NUMBER(S):PP-03 07 46 26 -35.-09 -31 T-106 -130 SYSTEM:All IST Pum in S stems in Table A FLOW DIAGRAM:See Table A ASHE CLASS:2&3 PUMP FUNCTION: As listed in Table A RELIEF TYPE ASME CODE TEST REQUIREMENT
REFERENCE:
OMa-1988. Part 6. Subsection 6. 1 Acceptance Criteria CODE REQUIREMENT DESCRIPTION:
OMa-1988, Part 6 Subsection 6.1 First Paragraph, Second Sentence Relative to Action Range. If deviations fall within the required action range of Table 3. the
~ ~
pump shall be declared inoperable until the cause of the deviation has been determined and the condition corrected.
BASIS THAT COMPLIANCE WITH CODE REQUIREMENTS IS IMPRACTICAL:
Compliance with the required acceptance criteria will impose a significant burden if test data cannot be analyzed to determine if a pump is still capable of performing its safety function. Past experience evaluating pump test data clearly indicates a burden will be created by unnecessary extension of Technical Specification LCO durations. unnecessary reportabi lity submittals, unnecessary repai rs and replacements of otherwise suitable equipment, and unnecessary component wear due to accelerated testing frequencies.
PROPOSED ALTERNATE TESTING:
OH-1995, Subsection ISTB 6.2.2, Action Range. If the measured test parameter values fall within the required action range of Table ISTB 5.2. 1-1 or Table ISTB 5.2. 1-2, as applicable, the pump shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established in accordance with paragraph ISTB 4.6.
Revision 0 Page 8 of 9
~ BASIS ALTERNATETESTING YIELDS ACCEPTABLE LEVELS OF QUALITYAND SAFETY:
It is requested that the corrective action requirements, per ASME OMa-19SS, Part 6, Subsection 6.1; be superseded for all pumps included in the IST program. The proposed alternative is to follow subsection ISTB 6.2.2 of ASME OM-1995, "Action Range." When applying the requireinents of ISTB 6.2.2, Tables 5.2.1-1 and ISTB 5.2.1-2, the Group A test hydraulic acceptance criteria will be used since all pumps are treated as Group A pumps by ASME OMa-1988.
The current pump IST program trends the test results and replaces the pumps as they approach the 137-lower limits. The trending allows for evaluations of system conditions ifthe test point deviates from the trend path. At that time, the pump is retested or the system conditions are reviewed to determine the cause of the deviation. This type of evaluation is consistent with the current code and is consistent with the 1995 code. On this basis, we are requesting that the corrective actions be established per ASME OM-1995 requirements since the OMa-198S code does not allow evaluation of test conditions.
Revision 0 Page 9 of 9 02/08/96
DONALD C. COOK NUCLEAR PLANT-UNIT 2 ASME OMa-1988 Addenda Part 6 Pump In-service Test Program The pump test program was developed using ASME OMa-1988 Part 6 including clarifications contained in NUREG-1482 ("Guidelines for In-service Testing at Nuclear Power Plants," April 1995) and later editions of ASME/ANSI OM Part 6 and OM Code Subsection ZSTB, except for specific code relief requested in accordance with 10CFR50.55a(f)(5)(iii).
This program is for the 3rd ten year inspection/test interval; commencing July 1, 1996 for Unit 2.
The program was developed employing the classification guidelines contained in Regulatory Guide 1.26, Revision 2 for Quality Groups B and C, and the definition of the reactor coolant system boundary contained in 10CFR50.2(v) for Group A. (Quality Groups A, B, and C are the same as ASME Class 1, 2, and 3, respectively). Table A identifies the following:
I. The pump number and service it performs along with the identification number of the drawing on which it is found.
II. The applicable test parameters:
- 1. Speed, for variable speed pumps only.
- 2. Discharge Pressure, for positive displacement pumps only.
Differential Pressure-determined as the difference between discharge and suction pressure.
- 4. Flow rate.
- 5. Vibration amplitude.
IIZ. The test frequency required The Emergency Diesel Generator Fuel Oil Transfer Pumps and the Emergency Diesel Generator Jacket Water Cooling pumps are outside the ASME Code Boundary. In accordance with NUREG 1482 Section 3.4, GL 89-04 Attachment 1, and 10CFR50 Appendix A and Appendix B, these pumps perform a function that is important to safety of the plant. Due to this importance to safety, these pumps will be subjected to periodic testing.
Revision 0 Page 1 of 9 02/08/96
DONALD C. COOK NUCLEAR PLANT - UNIT 2 PUMP INSERVICE TEST PROGRAM TABLE A .
PROGRAM
SUMMARY
TEST PARAMETERS Discharge Differential Flow Vibration Pump Speed Pressure . Pressure Rate Amplitude Test Punlp Service Number (N) (P) (A.P) (Q) (V) Frequency (Drawing No.)
Auxiliary Feedwater PP-3W No No. Yes Yes Yes Quarterly
'2-5106A)
PP-3E No No Yes Yes Yes Quarterly PP-4 Yes No Yes Yes Yes Quarterly Essential Service Water PP-7W No No Yes Yes Yes Quarterly (2-5113) PP-7E No No Yes. Yes Yes Quarterly Centri fugal Charging PP-50W No No Yes Yes Yes Quarterly (2-5129) PP-50E '.
No No Yes Yes Yes Quarterly Doric Acid Transfer PP-46-3 No No Yes Yes Quarterly (12-5131) PP-46-4 No No Yes Yes Yes'cs'cs Quarterly Component Cooling Water PP-10W No No Yes Yes Quarterly (2-5135A) PP-10E No No Yes Yes Yes Quarterly Safety Injection '2 PP-26N .
~
No No . Yes Yes Yes Quarterly
-5142) PP-26S No No Yes Yes Yes Quarterly Residual I lent Removal PP-35W No No Yes Yes Yes Quarterly
'2-5143)
PP-35E No No Yes Yes Yes Quarterly Revision 0 page 2 of 9 02/08/96
I l l ~
DONALD C. COOK NUCLEAR PLANT - UNIT 2 PUMP INSERVICE TEST PROGRAM TABLE A PROGRAM
SUMMARY
TEST PARAMETERS'ump Discharge Differential Flow Vibration Service Pump Speed Pressure Pressure Rate Amplitude 'I'est (Drawing No.) Number (N) (P) (AP) (Q) (V) Frequency Containtnent Spray PP-9W No No Yes Yes Quarterly
'2-5144)
PP-9E No No Yes Yes Yes'es'es Quarterly Diesel Fuel Oil QT-106-AB 1 No Yes No Yes Quarterly Transfer QT-106-A 82 No Yes No Yes Yes Quarterly b'2-5151A
& C) QT-106-CD1 No Yes No Yes Yes Quarterly QT-106-CD2 No Yes 'No Yes Yes Quarterly Spent Fuel Pit Cooling 12-PP-31S No No Yes Yes Yes Quarterly (12 5136)I Jacket Water QT-130-AB1 No No Yes Yes Yes Quarterly (2-51510 & D) QT-130-AB2 No No Ycs Ycs Yes Quarterly QT-130-CD1 No No Yes Yes Yes Quarterly QT-130-CD2 No No Ycs Yes Ycs Quarterly These pumps arc tested on test, bypass, or mlnlmum flow loops pcr ASMH OMA-1988 Part 6, $ 3.2, Refer to Comment 1. \
Refer to Comtnent 2.
Refer to Code Relief Request 1.
Refer to Code Relief Request 2.
Refer to Code Relief Request 3.
Only South Spent Fuel Pit Pump shown here due to the alignment of its cooling train to Unit 2 Component Cooling Nater.
Revision 0 page 3 of9 02/08/96
DONALD C. COOK NUCLEAR PLANT - UNIT 2 PUMP INSERVICE TEST PROGRAM COMMENT 1 Emergency Diesel Generator FOTP The duration of pump operation for testing, per ASME OMa-1988 Part 6, Subsection 5, Paragraph 5.6; "Duration of Tests", will be amended for the Diesel Fuel Oil Transfer pumps.
These pumps supply the diesel generator fuel oil day tank. A conservative level is maintained in the tank to meet the minimum capacity per Technical Specification requirements. Due to the limited capacity of this tank, the pump operating test range is limited to the time required to fillthe tank.
Therefore, test parameters will be recorded immediately after pump operation has stabilized.
Revision 0 Page4of9 02/08/96
DONALD C. COOK NUCLEAR PLANT - UNIT 2 PUMP INSERVICE TEST PROGRAM COMMENT 2 EDG FOTP Vibration Data Points Vibration measurement requirements; per ASME OMa-1988 Part 6, Subsection 4, paragraph 4.6.4, Vibration Measurements, will be amended for the rotary positive displacement Emergency Diesel Generator Fuel Oil Transfer Pumps. Vibration measurement will be taken at a single point on the gear box adjacent to all four gear shaft bearings. Due to the limited capacity of the tank to which the pump discharges to (EDG Day Tank), the pump operating time is limited and would prohibit recording multiple vibration readings.
Revision 0 Page 5 of 9 02/08/96
\
f l ~ J
COOK NUCLEAR PLANT PUMP IST PROGRAM RELIEF REQUEST NO. 1 TITLE: Containment S ra Pum Vibration Limits O General X Specific Unit Applicability: 1 2 X 1 and 2 PUMP NAHE: Containment S ra PUMP NUMBER(S): PP-009 SYSTEM: Containment S ra CTS FLOW DIAGRAH: 5144 ASHE CLASS 2 PUHP FUNCTION: Provide cool water flow to s ra the containment atmos here in a LOCA or steamline break.
RELIEF TYPE D X COMPLIANCE WITH CODE REQUIREMENTS ASHE CODE TEST REQUIREMENT
REFERENCE:
IS IMPRACTICAL OMa-1988, Part 6, Table 3a Ranges for vibration test parameters CODE REQUIREMENT DESCRIPTION: (for centrifugal pumps >600 rpm)
Acceptable range <2.5 vibration reference value (V)
Alert range >2.5 V to 6 V or >0.325 in/sec Required action range >6 V, or >0.70 in/sec BASIS THAT COMPLIANCE WITH CODE REQUIREMENTS IS IMPRACTICAL:
The design of the CTS pumps utilizes a four vane impeller in a double volute casing. This combination of an impeller with an even number of vanes operating in a casing with two volutes creates a high, reinforced vibration response at the vane passing frequency (7200 cpm). This condition is further compounded by the fact that the quarterly IST tests are performed at only 25K of the pump's design flow. This results in the discharge angle of the impeller flow not matching the stationary volute angle, producing high interaction forces between the impeller and the volutes. This high vane pass frequency amplitude is the major component of overall amplitude and is not indicative of overall pump condition. On this basis, compliance with the referenced acceptance criteria would be impractical due to the burden created by unnecessary repair and replacement of otherwise suitable pump components.
PROPOSED ALTERNATE TESTING:
Acceptable range <2.0 V Alert range >2.0 V to 4.0 V or 1.2 in/sec Required action range >4 V, or 2.0 in/sec BASIS ALTERNATE TESTING YIELDS ACCEPTABLE LEVELS OF QUALITY AND SAFETY:
Although the overall vibration amplitude is increased over the alert and required action limits of ASME OHa-1988, Part 6. Table 3a, the proposed alternate values are based upon our review of past operating data for these pumps. The values are a more representative basis for trending performance of the containment spray um s. and as such rovide an acce table level of quality and safety.
evasion
' COOK NUCLEAR PLANT PUMP IST PROGRAM RELIEF REQUEST NO. 2 TITLE: ric cid Transfer Pum Axial Vi ration Measurement General ~ Specific Unit Applicability: I + 2 H I anti 2 PUMP NAME: ric cid Transfer Pum PUMP NUMBER(S): 1-PP-4 -1 2'-PP-4 - 4 SYSTEM: V - akeu PLOW DIAGRAM: ~IL ASME CLASS E PUMP FUNCTION: Transfer prie acid lution fr m st ra e tank to char in um suctio eader.
RELIEF TYPE COMPLIANCE WITH CODE REQUIREMENTS IS IMPRACTICAL ASME CODE TEST REQUIREMENT REFE<RENCE:
OMa-1988, Part 6, Paragraph 4.6.4(a)
CODE REQUIREMENT DE<SCRIPTION:
On centrifugal pumps, measurements shall be taken in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each accessible pump bearing housing. Measurement also shall be taken in the axial direction on each accessible pump thrust bearing housing.
BASIS THAT COMPLIANCE WITH CODE REQUIRE<MENTS IS IMPRACTICAL:
The pump thrust bearing housing is inaccessible. It is very close to the coupling, and safety considerations prevent placement of the probe. In addition, the housing is partially blocked by the impeller adjustment nuts.
ALTERNATETESTING:
'ROPOSED Take measurements in a plane approximately perpendicular to the shaft in two orthogonal directions on each accessible pump bearing housing.
BASIS ALTERNATE< TESTING YIE<LDS ACCEPTABLE LEVELS OF QUALITYAND SAFETY:
Measurements taken in planes perpendicular to the shaft in two orthogonal directions have provided adequate data to evaluate pump performance and condition.
Revision 0 Page 7of9 02/08/96
COOK NUCLEAR PLANT PUMP IST PROGRAN RELIEF REQUEST NO. 3 TITLE: Su ersede OMa-1988 Corrective Action Part 6 Para ra h 6.1 X General Unit Applicability:
1 2 X 1 and 2 PUMP NAME:Various PUMP NUMBER(S):PP-03 07 46 -10.-26 09 -31 T-106 -130 SYSTEM:All IST Pum ina S stems in Table A FLOW DIAGRAM:See Table A ASHE CLASS:283 PUMP FUNCTION: As listed in Table A RELIEF TYPE ASHE CODE TEST REQUIREMENT
REFERENCE:
OMa-1988, Part 6, Subsection 6. 1 Acceptance Criteria CODE REQUIREMENT DESCRIPTION:
OHa-1988. Part 6. Subsection 6.1, First Paragraph, Second Sentence Relative to Action Range. If deviations fall within the required action range of Table 3, the pump shall be declared inoperable until the cause of the deviation has been determined and the condition corrected.
BASIS THAT COMPLIANCE WITH CODE REQUIREHENTS IS IMPRACTICAL:
Compliance with, the required acceptance criteria will impose a significant burden if test data cannot be analyzed to determine if a pump is still capable of performing its safety function. Past experience evaluating pump test data clearly indicates a burden will be created by unnecessary extension ot Technical Specification LCO durations, unnecessary reportabi lity submittals, unnecessary repairs and replacements of otherwise suitable equipment, and unnecessary component wear due to accelerated testing frequencies.
PROPOSED ALTERNATE TESTING:
OM-1995, Subsection ISTB 6.2.2. Action Range. If the measured test parameter values fall within the required 'action range of Table ISTB 5.2. 1-1 or Table ISTB 5.2. 1-2, as applicable. the pump shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established in accordance with paragraph ISTB 4.6.
" BASES ALTERNATETESTING YIELDS ACCEPTABLE LEVELS OF QUALITYAND SAFETY:
It is requested that the corrective action requirements, per ASME OMa-1988, Part 6, Subsection 6.1, .
be superseded for all pumps included in the IST program. The proposed alternative is to follow subsection ISTB 6.2.2 of ASME OM-1995, "Action Range." When applying the requirements of ISTB 6.2.2, Tables 5.2.1-1 and ISTB 5.2.1-2, the Group A test hydraulic acceptance criteria will be used since all pumps are treated as Group A pumps by ASME OMa-198S.
The current pump IST program trends the test results and replaces the pumps as they approach the IST-lower limits. The trending allows for evaluations of system conditions ifthe test point deviates from the trend path. At that time, the pump is retested or the system conditions are reviewed to determine the cause of the deviation. This type of evaluation is consistent with the current code and is consistent with the 1995 code. On this basis, we are requesting that the corrective actions be established per ASME OM-1995 requirements since the OMa-198S code does not allow evaluation of test conditions.
Revision 0 Page 9 of 9 02/08/96
I'