ML20008G331
| ML20008G331 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/22/1981 |
| From: | Finfrock I JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20008G330 | List: |
| References | |
| NUDOCS 8107070324 | |
| Download: ML20008G331 (6) | |
Text
.'
s OYSTER CREEK
[
NUCLEAR GENERATING STAYiON JCP&L GPU w conna g m g,sE T.'
(609)693-6000 P.O. BOX 388
- FORKED RIVER
- 08731 Nato'c utmees system May 22, 1981 Mr. Boyce H. Grier Office of Inspection and Enforcement Region I United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Grier:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inservice Testing of Safety Related Pumps l
In accordance with the discussions with Mr.
W.
Rekito and i
Mr. T. Martin on April 3, 1981 and April 7, 1981 respectively, j
the enclosed is being forwarded as indicated in your letter of l
April 8, 1981.
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Specifically, the enclosed report presents the results of l
our review of all safety-related pump operability test proce-l dures for conformance with 10 CFR 50.55a (g) and the commit-ments deliniated in our September 8, 1980 submittal.
Addi-tionally, the enclosure provides a discussion of our plans and current schedule for achieving total conformance with the aforementioned criteria to the extent practicable (design con-figuration and access permitting).
Should you have any additional questions please contact Mr.
Michael Laggart at (609) 693-6932.
Very truly
- ours, G
AM f
Fin hoc [ Jr.
Ivan R.
Vice President - JCP&L Director - Oyster Creek L
cc:
NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 07070324 810624 3 a aoocx 0300021, o
PDR pg a
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.Mr. Boyco k. Grier May 22, 1981 ENCLOSURE
References:
(1)
Letter to I.
R. Finfrock, Jr. from Boyce H.
Grier-(NRC) dated April 8, 1981.
(2) 10 CFR 50.55 a (g) and ASME B & PV Code,Section XI 1974 Edition through summer 1975 addenda.
(3)
Inservice Inspection Program for the Oyster Creek Nuclear Generating Station, Revision 3.
(4)
I.E.
Inspection No. 81-05.
Per the direction of reference one (1) the existing procedures for the purpose of satisfying Inservice Testing require-ments were compared against the requirements of the ASME B&PV Code section IWP.
This comparison was made with the use of a checklist developed utilizing the code as the reference.
Each procedure was compared against the checklist and the deficiencies noted.
The re-view encompassed not only the software aspects related to pump testing but also hardware requirements.
Several areas were iden-tified in various procedures to be shortcomings.
These were:
(1) IWP-3100 requires pump testing to be performed such that either pump differential or flow be specified and the other variable measured to determine pump condition for variable resistant systems.
Contrary to the above, one variable resistance system, core spray was not to be~ tested in complete compliance.
Even though the valve used to vary resistance was controlled to one position by limit switches, no controls existed to control switch position or cal-ibration.
Another variable resistance system, ser-vice water, could not be tested for compliance because of the lack of flow instrumentation.
The test procedures were revised to specify the system flows at which the tests are to be conducted.
Ser-vice water will be tested when ultrasonic flow measuring equipment it available.
(2) IWP-3100 requires measuring pump suction pressure before and after pump start.
Contrary to the above, procedures did not specify recording of suction pressure before and after pump start.
Additionally, it was identified not all pumps had suttion pressure instrumentation.
Where proper piping and valving existed for instrumentation, test instrumentation was installed to comply with cede requirements.
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Mr. Boyca H. Grier -
May 22, 1981 Where' instrumentation was available, respective pump test procedures were revised to include the reading of the suction pressure prior to and during pump operation.
Where proper piping does not exist, a determination of the possibility of installing such instrumentation will be made.
This determination will take into consideration the program (references (2) and (3)) as submitted.
The review of such program by the NRC did not prevent-the use of the vessel level from which the pump takes suction as a substitute for suction pressure.
.Therefore, if vessel level is justified,
'the IWP requirements of measuring suction pressure before and during pump testing will be satisfied by measuring vessel level.
(3) IWP-4100 requires instruments utilized to perform testing to have specific accuracy requirements, range requirements, and calibration frequency es-tablished.
Contrary to the above not all groups had been calibrated recently and were not on a schedule-to provide for calibration on a regular basis.
All gauges not calibrated within the last year were calibrated prior to performance of pump testing during the April-May maintenance outage.
Because of non-availability, some gauges did not satisfy the less than four times the measured range requirement.
Gauges will be procured and installed when they become available.
All gauges existing or installed meet the gauge accuracy requirements of the Code.
(4) IWP-3100 specifies for fixed resistant systems either pump differential pressure or flow need be measured to monitor operational readir ess.
Contrary to the l
above, fixed resistant systems for which flow instru-mentation does not exist were not being tested in a manner by which pump degradation could be monitored.
These pumps are Fire Protection, RBCCW, and Conden-sate Transfer.
For two systems, Fire Protection and Condensate Transfer the test procedure was revised to specify a test method where a fixed resistance flow path is utilized.
Pump differential pressure will be utilized as a measure of continued satisfactory pump operation.
The RBCCW system, because of system configuration,
. = _ _
4 "Mr. Boyca H. Grier May 22, 1981
)
I did not permit testing in compliance to the code.
Inservice testing utilizing an ultrasonic flow
- measuring device to duplicate system flow from one test to another has been performed with RBCCW.
Fur-ther limitations exist which could prevent performing inservice testing during months of high intake tem-perature for which relief will be requested in the next revision to the ISI program.
(5) IWP-3100 requires observing lubrication during per-formance of testing.
Contrary to the above test procedures did not specify observation of pump lubri-cation during performance testing.
This requirement is redundant to the plants normal lubrication schedule.
Since all pumps' lubrication is checked according to this schedule on a more frequent basis than the per-formance of this test, this requirement may be dropped
- with request for relief or incorporated such that it also satisfies the requirements of the Preventative i
Maintenance Program.
(6) IWP-3200 specifies acceptance criteria to be used for monitoring the condition of pumps from one test to the next.
Contrary to the above, test acceptance criteria contained in the procedures did not comply with the required code acceptance criteria.
Test procedures were revised to include accpetance cri-l teria consistent with those specified in the code.
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' Utilizing the revised test procedures inservice tests were performed during the April-May maintenance outage.
These tests will be continued on.an accellerated schedule (monthly) until the next scheduled refueling outage in order to develop a sound statistical data base that will determine appropriate alert and action ranges.
Test procedures will then be revised to include the alert and re-
. quired action levels derived from the measured variables during this inservice test period.
' Future actions which are necessary to bring the Inser-vice Testing Program in conformance to IWP and IWV sections of the ASME B&PV code and/or the program as submitted to the NRC and desig-nated as' Revision 3 are tabluated below.
A schedule of completion of specific. actions necessary to achieve conformance follows:
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Mr. Boyco H. Grior May 22, 1?81 Actions necessary to resolve concerns related to the valve testing program are also included to resolve concerns of reference (4).
ACTIVITY IMPLEMENTATION DATE 1.
Test Service Water system when ultrasonic measuring equip-ment is available.
6-5-81 2.
Schedule accelerated test pro-gram.
6-5-81 3.
Write administrative procedure to implement program and main-tain necessary records.
6-30-81 4.
Schedule the pump inservice tests in accordance with the program.
6-5-81 5.
Submit Revision 4 of the program, encompassing those items dis-cussed during the 9-23-80, 9-24-80 meeting with the NRC.
6-30-81 6.
Develop a records system for pumps and file the necessary records for each pump.
8-1-81 7.
Review, revise, and write valve testing procedures.
9-30-81 8.
Perform inservice tests for valves required during operation.
10-15-81 9.
Perform inservice tests for valves required during cold shutdown.
first cold shutdown after 10-15-81 10.
Perform inservice tests for valves required during refueling outage.
during next re-fueling outage 11.
Schedule the valve inservice tests in accordance with the program.
10-15-81 12.
Develop a records system for valve testing and file the necessary records for each valve 1-1-82 13.
Seat leakage esting required by Dependent on review Revision 4 of IST Program against the Appendix J Leak Rate Testing Program
Mr. Boyco H. Grior May 22, 1981 4
.For those items identified during the reviews of pump and valve testing requirements which cannot ba tested in compliance with the program and/or the code, subsequent additional requests for relief will be requested.
After these requests have been reviewed and approved by the NRC the inservice testing program at Oyster Creek should be in compliance with the program and/or the code.
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