ML20011E972
| ML20011E972 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/16/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9002230241 | |
| Download: ML20011E972 (7) | |
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BALTIMORE
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GAS AND i
CHARLES CENTER. P. O. BOX 1475. BALTIMORE, MARYLAND 21203 y c, p,h,,caccv February 16, 1990 Nucitan cN$hgY '
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- (300 eto mess U S. Nuclear Regulatory Commission Washington, DC 20555 L ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant' Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Second Ten-Year Inservice Test Program Plan
REFERENCES:
- (a) Letter to Mr. G. C. ' Creel (BG&E) from Mr. S. A. McNeil (NRC),
dated January 12,1990, same subject (b) Letter to - Document Control Desk (NRC) from Mr. J. A.. Tiernan (BG&E), dated October 18, 1988, ASME Section XI Pump :,nd Valve Inservice Test (IST) Program
- Gentlemen:
.i Reference (a). reported that the Nuclear Regulatory Commission (NRC) staff. has completed _ its initial review of our revised inservice test (IST) program plan for safety-related pumps and valves as provided in Reference (b). Reference (a) went on to say that.' additional information-is needed to support two ASME code relief requests, pump relief request number 6, and valve relief request number SI-4.
-The additional information requested is provided in Enclosure -(1) to this letter, if you have any further questions in this area we would be pleased to discuss them with
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Very truly yours, l
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D.' N. Brune, Esquire J. - E.
Silberg, - Esquire -
R. A.Capra,NRC :
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. D. G. Mer/onald, Jr., NRC
. W. T. F i e 11, NRC
' J. 2. b;ad, NRC T. Magette, DNR f -~
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m ENCLOSURE (1)
REQUEST FOR ADDITIONAL INFORM ATION
- i ASME SECTION XI PUMP AND VALVE INSERVICE TEST (IST) PROGR AM A.
PUMP RELIEF REQUIXr NUMBER 6 NRC 1.
Please provide a list of all pumps for which relief is requested and component and loop accuracy ascribed to the flow meters used to test each pump.
BG&E RESPONSE (Numbers in parentheses are for Unit 2) a.
II, 12, 13 (2), 22, 23) Salt Water Pumps Instrument Used:
Dietrich Standard Annubar and Transmitter Instrument Accuracy:
i 1 % of reading Loop Accuracy:
i 3.4 % of full scale b.
11, 12, 13 (21, 22, 23) Service Water Pumps r.
Instrument Used:
Controlotron Model 480 i
instrument Accuracy; i 1-3 % of reading Loop Accuracy:
1-3 % of reading c.
I1, 12, 13 (21, 22, 23) Component Cooling Water Pumps instrument Used:
Controlotron Model 480 Instrument Accuracy:
11-3 % of reading Loop Accuracy:
i 1-3 % of reading d.
11, 12, 13 (21, 22, 23) Charging Pumps l
Indicator Used:
Sigma 9222-20-ED (2 device level loop)
Indicator Accuracy:
0.5 % of span j
Loop Accuracy; i 3.4 % of span e,
11, 12 (21, 22) Low Pressure Safety injection Pumps Indicator Used:
Fischer 53EG3313 ;(4 device orifice plate flow loop)
Indicator Accura:v.
10.8 % of span Loop Accuracy:
12.94 % of span f.
11,12(21,22) Containment Sprey Pumps Indicator Used:
Fischer 53EG3313 (4 device orifice plate flow loop)
Indicator Accuracy:
1 0.8 % of span i
Loop Accuracy:
2.94 % of span g.
II, 12, 13 (21, 22, 23) High Pressure Safety injection Pumps indicator Used:
Sigma 9222-00-E (3 device orifice plate flow l
loop)
Indicator Accuracy:
1 0.52 % of span Loop Accuracy:
3.80 % of span l'
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I 1-i 1
ENCLOSURE (1)
REQUESTFOR ADDITIONALINFORMATION.
ASME SECTION XI PUMP AND VALVE INSERVICE TEST (IST) PROGRAM h.
II.-12, 13 (21, 22, 23) Auxiliary Feedwater Pumps Indicator Used:
Foxboro N2AX-Mill { (6 device orifice plate flow loop)
Indicator Accuracy:
2 % of span Loop Accuracy; i 4.0 % of span The alternative requirement we proposed to commit to for loop accuracy was i 4%.
NRC 2.
For flow instruments whose components are less accurate than i 2%, provide. a basis for your inability to provide a more accurate instrument.
BG&E RESPONSE Although not specifically stated in the code, BG&E interprets that the intent of the ASME code accuracy requirements is for total loop accuracy to be within i 2%, not component accuracy; hence we requested relief from the code requirements on this issue, proposing an alternative requirement of 14% BG&E takes a very conservative approach to instrument loop accuracy.
determination.
When determining the total flow error of a flow indicating loop we do not consider just basic instrument accuracy; we consider
- accuracy, drift, temperature, readability. - repeatability,- power supply and calibration procedure allowances.
We do not feel our total loop accuracies are out of line with the rest of the -
industry. The accuracy - and repeatability of our instrumentation is adequate to detect pump degradation when our whole program is taken into account. Our program includes pump performance testing and an enhanced vibration monitoring program (see Pump Relief Request No. 3 of Reference (b)).
We are presently testing an improved ultrasonic flow instrument that will irnprove the accuracy and reliability of our non-obtrusive test instrumentation. We will continue to investigate ways to improve our pump and valve testing program.
H.
VALVE RELIEF REOUEST NUMBER SI-4 NRC 1.
Describe the test methodology used in conducting leak rate tests on 1(2)CV-618 (628, 638, and 648).
1)GAE RESPONSE Please refer to Figure 1, page 5, which shows one of the four Safety Injection Tanks, and associated piping....__......_ _ _ _ _
ENCLOSURE - (1)
REQUEST FOR ADDITIONALINFORMATION
' ASME SECHON XI PUMP AND VALVE INSERVICE TEST (IR) PROGRAM i
1 1
These valves are leak tested to assess maintensnce needs prior to going into a maintenance outage.
They are leak tested per Calvert Cliffs Operating instruction Number 3
" Safety injection, Shutdown Cooling, and Containment Spray,' Section _XXVill. The method employed is to line up a flow path to the reactor. coolant ' drain tank, pressurize the upstream side of the CV with a high pressure safety injection pump and look for leakage into the reactor coolant drain tank.
NRC 2.
Describe the surveillances, and their associated intervals including grace periods and allowable out-of-service
- times, for the pressure transmitters 1(2)PT-319 (329, 339, and 349) used to detect leakage past the safety injection pressure isolation valves from the reactor coolant loops 1(2)SI-217 (227, 237, and 247).
BG&E RESPONSE a.
These instruraents indicate and alarm in the control room and are constantly under surveillance by the licensed control room operators, b.
l(2)PT-319 (329, 339, and 349) are calibrated per PM's 1(2)-52-I-R-29, 1(2)-52-1-R-30, 1(2)-52-1-R-31, and 1(2)-52-1-R-32, respectively, c.
The frequency for these PM's is once per refueling shutdown, Per our control procedure for the PM program, we do not routinely apply grace periods to refueling interval PM's. On an exception basis, the system engineer is required by procedure to evaluate the impact of applying a grace period and based on that evaluation may allow up to a 25% schedule
- window, d.
These pressure transmitters are not required by our technical specifications so there is no specified allowable out-of-service time.
NRC 3.
Describe actions taken and operability restrictions imposed in the event that one of the aforementioned pressure transmitters is inoperable or oat-of-service, including mode applicability, i
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BGAE RESPONSE As stated in the previous question, these pressure transmitters, used for
. detecting check _ valve leakage, are not mentioned in our Technical Specifications.
These transmitters are part of our control room instrumentation and as such, if they are inoperable, the impact of the inoperability is evaluated by our licensed operators.
The impact is also evaluated by the IST group where the
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i-ENCLOSURE (11
,a REQUESTFOR ADDITIONAL,INFORMATION ASME SECTION XI PUMP AND VALVE INSERVICE TEST (IST) PROGR AM out-of-service date is considered to be the last test for the associated check.
valve and the ASME Section XI code requirements for that valve are then checked for compliance. There-is no mode applicability assigned to non Technical Specification requirements but we will consider MODES l-3 as applicable for this requirement.
NRC 4.
Please verify that no leakage paths exist that could mask pressure indications of primary leakage past the safety injection pressure isolation valves 1(2)SI-217 (227 237, and 247), including any paths on the nigh pressure safety injection side - of the containment isolation valves 1(2)SI-Il8 (128, 138, and 148).
BG&E RESPONSE Please refer to Figure.1, _ page 5, which shows one of the four Safety injection Tanks, and associated piping.
a.
The leakage path through 1(2)SI-618 (628, 638, and 648) CV's is tested as described in item B.I.
earlier, Any leakage past these valves will either go into the safety injection tank, which is evaluated every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for in-leakage, or to the reactor coolant drain tank, which is evaluated for in-leakage daily when gross reactor coolant system leakage is greater than Igpm.
b.
The leakage path through l(2)SI-215 (225, 235, and 245): These valves are type AC and tested accordingly in the IST program; additionally any leakage past these valves will go to the safety injection tank which is evaluated every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for in-leakage, c.
The leakage path through 1(2)SI-ll8 (128, 138, and 148): These valves are type AC valves and tested accordingly in the IST Program; any leakage past these valves will be contained by the check valves 1(2)SI-i l4 (124, 134, and 144) or 1(2)SI-l l3. (123, 133, and 143). Although these are not type "A"
valves they are part of the IST Program and tested for back leakage as the means for verifying valve closure in accordance with IWV-3410.
BG&E neneral comments concernine valve relief reauest number SI-4.
The. valves in question, 1(2)SI-217, 227, 237, and 247, are check valves between the reactor coolant system and the safety injection system (see Figure 1). Any i
back leakage thru these valves will be accounted for and detected as reactor coolant system leakage.
Per Technical Specifications, RCS leakage is l
determined at a minimum every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with limits of I gpm unidentified leakage.
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