ML17333B007
| ML17333B007 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/19/1997 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:0969BE, AEP:NRC:969BE, NUDOCS 9708250107 | |
| Download: ML17333B007 (9) | |
Text
CATEGORY 1
,I,:
REGULATOR INFORMATION DISTRIBUTION'STEM (RIDE j ACCESSION NBR:9708250107 DOC.DATE: 97/08/19 NOTARIZED:
NO FACI :50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
50-3416 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
AUTH;ÃAAkr AUTHOR AFFILIATION FITZPATRICK,E.
American Electric Power Co., Inc.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000315 05000316
SUBJECT:
Forwards revised relief requests for REL-126 REL-13.Revised relief request P-2 contained jn Attachment 2.Rev to relief request P-1 previously submit)ed in,ltr dtd 970627.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR i
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TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-89-04 NOTES:
E, RECIPIENT ID CODE/NAME PD3-3 LA HICKMAN,J INTERNAL: AEOD/SPD/RAB NRR/DE/EMEB OGC/HDS2 RES/DET/EMMEB EXTERNAL: LITCO ANDERSON NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME PD3-3 PD FIL CENTER NUDOCS-ABSTRACT RES/DET/EIB NOAC COPIES LTTR ENCL 1
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N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 13 ENCL 12
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Indiana Michigan Power Company 500 Circle Drive Buchanan, Mi 491071395 INSIANA NfCNl6dRN PQSlfJFR August 19, 1997 Docket Nos.:
50-315 50-316 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
AEP:NRC:0969BE Donald C.
Cook Nuclear Plant Units 1 and 2
RELIEF REQUESTS FOR THE THIRD TEN-YEAR PUMP AND VALVE IN-SERVZCE TEST PLANS
References:
1.
Letter AEP:NRC:0969AM, "Donald C. Cook Nuclear Plant Units 1 and 2, RELIEF REQUESTS FOR THE THZRD TEN-YEAR PUMP ZN-SERVICE TEST PLAN", dated June 12, 1996.
2.
Letter AEP:NRC:0969AN, "Donald C. Cook Nuclear Plant Units 1 and 2,
RELIEF REQUESTS FOR THE THIRD TEN-YEAR VALVE IN-SERVZCE TEST PLAN", dated April 24, 1996.
3.
- Letter, G.
H.
Marcus (NRC) to E.
E.
Fitzpatrick (I&M),
-"EVALUATIONOF THIRD 10-YEAR INTERVAL FOR THE PUMP AND VALVE IN-SERVICE -TESTING PROGRAM FOR DONALD C.
COOK NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M95721, M95722, M95890, AND M95981) '
dated May 27, 1997.
Letter AEP:NRC:0969BD, "Donald C.
Cook Nuclear Plant Units 1 and 2,
REQUEST NO.
1 REVISED RELIEF REQUEST FOR THE THIRD TEN YEAR ZNTERVAL PUMP IN-SERVICE TEST PLAN", dated June 27, 1997.
The third ten year in-service testing program for pumps and valves was submitted in references 1 and 2, respectively.
As part of these submittals, we submitted relief requests for code requirements that we had determined were impractical to meet.
In the NRC response to our relief requests, reference 3, relief requests P-1 (containment spray pump vibration limits),
REL-12 (valve SI-189 test frequency),
and REL-13 (valves CS-328L1, L4, CS-
- 329L1, L4 test frequency and exercise requirements) were denied.
Additionally, relief request, P-2 (boric acid transfer pump axial vibration measurements) was granted on an interim basis for ninety days.
Revised relief requests for REL-12 and REL-13 are contained in attachment 1.
Revised relief request P-2 is contained in attachment 2.
The revision to relief request P-1 was previously submitted in reference 4.
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U. S. Nuclear Regulatory Commission Page 2
AEP:NRC:0969BE Relief request REL-12 has been revised to require disassembly, manual full-stroke exercising, and visual examination at a
refueling frequency.
Testing at this frequency willbegin with the next scheduled outage.
Should it be determined that this frequency of testing presents an extreme hardship, a revised relief request will be submitted at a later date.
Relief request REL-13 has been revised to state there is no upstream instrumentation that would provide an indication the valves have returned to their fully closed position after exercising.
- Thus, disassembly is the only means of verifying closure.
The revised relief request still contains the proposal to perform the disassembly and inspection on a sample basis (1 of 4) during each refueling outage.
- However, as an interim measure, all four valves will be included in the outage scope for disassembly and inspection during the next outage.
Relief request P-2 has been revised to provide more detailed information about the impractability of obtaining the code-required measurements.
Sincerely, CC+)w E.
E. Fitzpatrick Vice President vlb Attachments A. A. Blind A. B. Beach MDEQ -
DW Ec RPD NRC Resident Inspector J.
R. Padgett
ATTACHMENT 1 TO AEP:NRC:0969BE REVISED RELIEF REQUESTS REL-12 AND REL-13
Attachment 1 to AEP:NRC:0969BE Page 1
REVISED RELIEF REQUESTS REL-12 AND REL-13 Revised Relief Re est REL-12 SI-189:
This valve is located in the safety valves discharge (emergency core
- cooling, residual heat
- removal, centrifugal charging pump, etc.) collection header leading to the pressurizer relief tank.
Isolating this valve for testing would result in dead heading all safety valves in the above systems.
This would result in loss of over-pressurization protection and could put the plant in an unsafe condition.
Therefore, the valve will be part-stroke exercised to the open position using an external source via a test connection at a
cold shutdown frequency.
The valve will be disassembled, manually full-stroke exercised, and visually examined at refueling frequency.
Revised Relief Re est REL-13 CS-328L1,L4; CS-329L1,L4:
These check valves have a closed safety function and provide the interface point between the reactor coolant system (RCS) and the chemical and volume control system (CVCS)
Because the discharge piping of the CVCS is designed to a pressure rating higher than the RCS, these valves do not perform a pressure isolation function.
The high pressure to low pressure isolation is accomplished by other valves that are tested to category A requirements.
These 3" bolted bonnet swing check valves have no external position indication or means of exercising, and are located inside the crane wall in the reactor containment.
There is no upstream instrumentation that can be used to show that the valves return to the fully closed position after exercising.
In accordance with generic letter 89-04, attachment 1, position 2, the valves will be disassembled and inspected on a sample basis (1
of 4) during each refueling outage.
ATTACHMENT 2 TO AEP:NRC:0969BE REVISED RELIEF REQUEST P-2
Attachment 2 to AEP:NRC:0969BE Page 1
REQUEST NO.
2 - REVZSED RELIEF REQUEST THIRD TEN-YEAR INTERVAL PUMP ZN-SERVICE TEST PLAN TITLE:
Boric Acid Transfer Pump Axial Vibration Measurement UNIT APPLICABILITY: Units 1 and 2
PUMP NAME:
Boric Acid Transfer Pump PUMP NUMBERS:
1-PP-1, 2; 2-PP-46-3, 4
SYSTEM:
Chemical and Volume Control System (CVCS)
Makeup FLOW DIAGRAM:
12-5131 ASME CLASS:
2 PUMP FUNCTION:
Transfer boric acid solution from the storage tank to the charging pump suction header.
RELIEF TYPE:
Compliance with code requirements is impractical.
ASME CODE TEST REQUIREMENT
REFERENCE:
OMa-1988, Part 6, Paragraph 4.6.4(a)
CODE RE UIREMENT 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.
Measurements also shall be taken in the axial direction on each accessible pump thrust bearing.
BASIS FOR CODE COMPLIANCE RE UIREMENTS BEING IMPRACTICAL The boric acid transfer pumps are designed and manufactured by Gould Pumps.
The model installed at Cook Nuclear Plant is model 3196-STD.
They are single stage separately coupled machines equipped with a fully open face, overhung impeller with partial shrouds.
The pumps are supplied by end suction and generate totally radial flow.
The shearing action of the impeller vanes on the casing wall virtually eliminates axial thrust.
Both of the inboard and outboard bearings are located in one housing between the pump and its coupling.
Neither rolling element bears on a
plane perpendicular to the shaft; hence, mechanical degradation of this type of power train cannot be accurately measured by axial vibration.
This makes the burden of modifying the coupling shield such that the bearing housing flange becomes safely accessible, or taking axial measurements elsewhere, unwarranted.
Note that, by
- design, the only accessible axial vibration measurement available exists at the outboard end of the motor.
The motor is excluded by section 1.2(a) of the code;
- however, these measurements shall continue to be taken in support of predictive maintenance and reliability.
Because these bearings are angular contact rolling element
- bearings, the radial direction will provide ample indication of a possible degraded bearing.
Indications of inner race, outer race, and ball spin frequencies are capable of being monitored in the radial direction, and provide adequate information as to the health
Attachment 2 to AEP:NRC:0969BE Page 2
and condition of the thrust bearing.
Therefore, use of radial measurements on rolling element
- bearings, in-service as thrust
- bearings, provides adequate data to evaluate the mechanical operating condition of the pump.
PROPOSED ALTERNATE TESTING Measurements will be taken in a plane approximately perpendicular to the shaft in two orthogonal directions on each accessible pump bearing housing.
BASIS ALTERNATE TESTING YIELDS ACCEPTABLE LEVELS OF UALITY AND SAFETY Measurements taken in planes perpendicular to the shaft in two orthogonal directions have provided adequate data to evaluate pump performance and condition.