ML19294B328
| ML19294B328 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/21/1979 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19294B325 | List: |
| References | |
| NUDOCS 8002280193 | |
| Download: ML19294B328 (3) | |
Text
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PHILADELPHI A ELECTRIC COMPANY 23O1 M ARKET STREET F.O. BOX 8699 PHILADELPHI A. PA.19101 (215) 841 5001 se
.L.oAtynopp ELESta c OoN"cnom December 21, 1979 Re:
Docket Nos.:
50-277 50-278 Inspection No.:
50-277/79-19 50-278/79-21 Mr. Eldon J.
Brunner, Chief Reactor Operations and Nuclear Support Branch U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Brunner:
Your letter of D e c e mb e r 5, 1979, f orwarded combined Inspection Report 50-277/79-19 and 50-278/79-21.
Appendix A to your letter addresses one item which did not appear t o be in full compliance with Nuclear Regulatory Commission requirements.
The item is categorized as an infraction and is restated below with our response.
Based on the results of the NRC inspection conducted on August 29-31, 1979, it appears that certain of your activities were not conducted in f ull compliance with conditions of your NRC Facility License No. DPR-44/56 as indicated below.
This item is an infraction.
10 CFR 50.55 a (g)(4) states, in part, that: "i
'ou gh ou t the nuclear p ower f acility, c omp on en t s service life of a...
set forth in Section XI of sc.all meet the requirements ei.i t i on s of the ASME Boiler and Pressure Vess.al Code Section XI of the ASME B&PV Code, paragraph IWP-3100, Inservice Test Procedure, states, in part, that:
8 0 0 2 2 8 0l13
Mr. Eldon J.
Brunner Page 2 "An inservice test shall be conducted with the pump
... at a speed adjusted to the reference operating speed f or variable speed drives."
"In variable resistance systems, the resistance of the system shall be varied until either the measured differential pressure or the measured flow rate shall equal the corresponding reference value."
" Test quantities shown in Table IWP-3100-1 shall then be measured."
"Each measured test quantity shall then be compared to the reference value of the same quantity.
Any deviations determined shall be compared to the limits given in Table IWP-3100-2..."
Section II of the ASME B&PV Code, paragraph IWP-3500, Duration of Tests, states, in part, that:
"... each pump shall be run f or at least five minutes under conditions as stable as the system permits.
At the end of this time of each of the quantities specified shall be measurement...
made and recorded."
Contrary to the above specific requirements, as of August 31, 1979, required surveillance tests were performed using procedures which did not conf orm to Section XI of the ASME Boiler and Pressure Vessel Code.
Test records reviewed indicated that the latest surveillance tests performed using procedures ST - 6.5, 6.7, and 6.11 were July 25, 1979, August 29, 1979, and August 13, 1979, respectively.
retails are as follows:
1.
The High Pressure Coolant Injection and Reactor Core Isolation Cooling Pumps have variable speed drives and Surveillance Test Procedures ST-6.5 and 6.11 do not establish a reference speed as required by IWP-3100.
Response
Surveillance Tests ST-6.5 and ST-6.11 have been revised to establish a reference speed f or the HPCI and RCIC turbines when taking flow and p ressure data for ISI purposes.
2.
The HPCI, RCIC, and Core Spray are variable resistance systems and Surveillance Test Procedures ST-6.5, 6.11 and 6 7 do not specify that the resistance be varied to equal an established reference value for dif f erential pressure or flow rate as required by IWP-3100.
Additionally, these Surveillance Test Procedures do not identify all test quantities to be
M r'.
Eldon J.
Brunner Page 3 measured and evaluated or establish reference values f or comparis on as required by Tables IWP-3100-1 and IWP-3100-2.
Response
The Surveillance Tests for HPCI, RCIC, and Core Spray (ST-6.5, ST-6 7, and ST-6.11) will be revised to include the testing requirements of Tables IWP-3100-1 and IWP-3100-2 of Section II as modified by the Peach B ottom Atomic Power S tation Inservice Inspection Program.
These revisions will be completed by February 15, 1980.
3.
None of the f ollowing monthly pump surveillance test procedures specifies a minimum run time of five minutes as required by IWF-3500.
(ST-6.1, 3,
6, 7,
8, 9,
10, 11, and 13.21).
Response
The f ollowing Surveillance Tests have been revis ed to require a minimum run time of five minutes as specified by IWP-3500: SI-6.1, ST-6 3, ST-6.6. ST-6 7, ST-6.8, ST-6 9, ST-6.10, SP-6.11, and ST-13.21.
The three items in this infraction concern deficient Surveillance Test procedures.
The writers of the p rocedures f ailed te incorp orate all of the requirements in Section II of the ASME Boiler and Pressure Vessel Code as modified by the PBAPS ISI Program.
However, all necessary revisions to items 1 and 3 have been completed and item 2 revisions will be completed by February 15, 1980.
Very truly yours,
)/ f'pa7