ML20033F105
| ML20033F105 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/02/1990 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-90-018, CON-NRC-90-18 GL-89-04, GL-89-4, VPNPD-90-01, VPNPD-90-1, NUDOCS 9003160024 | |
| Download: ML20033F105 (8) | |
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WISCONSIN Electnc POWER COMPANY 231 W IAchgak Po box 2046. Mhookee. VA 53201 (410 221 2345 r
VPNPD-90-101 j
NRC-90-018 March 2, 1990 t
U.
S. NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station P1-137 Washington, D.
C.
20555 l
Gentlemen
- DOCKETS 50-266 AND 50-301
+
GUIDANCE ON IST PROGRAMS i
GENERIC LETTER 89-04 FOLLOW-UP POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 As part of our October 3, 1989 response to Generic Letter 89-04, we committed to complete some specific testing by December 31, 1989.
Following this testing, based on the results, we would identify our course of action on the areas of containment spray pumps and the service water system.
Containment Sorav Pumos Generic Letter 89-04, Item 9.
Our special testing indicated that we could utilize a mini recire flow path that contains flow i
indication.
This method of testing is, however, operationally I
undesirable.
First, it provides only single valve isolation between pump discharge pressure and the containment spray i
nozzles.
The resultant potential for inadvertently spraying of containment is a risk we choose not to assume.
Secondly, a portion of.the piping can become filled with borated water and remain in this condition for extended time periods.
This also is t
a condition we want to avoid.
In order to comply with the requirements of Generic Letter 89-04, Item 9, we will make physical modifications to the containment spray. systems of Units 1 and 2.
Piping systems will be installed which will allow pump full-flow testing on a routine basis during operation.
Flow instrumentation will be installed.
These system modifications will be installed during each unit's 1991 refueling outage.
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4 NRC Document Control Desk March 2, 1990 Page 2 Service Water System Generic Letter 89-04, Item 1, requires full-flow testing of pump discharge check valves.
Item 3 requires check valve back-leakage testing (not specifically identified in the October 3, 1989 response, but tested for).
Item 9 requires pump testing at full or substantial flow and obtaining required test quantitles.
The results of our December 12, 1989 testing were inconclusivo as to whether or not we can comply with Generic Letter 89-04, Items 1,
3, and 9 relative to the service water system.
We plan to rescope our testing to ensure that routine testing, in accordance with Items 1, 3,
and 9, can be done.
We will complete this testing by April 1, 1990.
Recuested Relief We request relief from two ASME Code requirements that we are meeting.
These two areas are (1) the use of amplitude as units of vibration measurement for pumps and (2) taking pump bearing measurements.
Relief requests for these two items, as they will be inserted into our IST program, are attached.
As these relief requests are not addressed in Generic Letter 89-04, and in keeping with the guidance provided therein, we will not implement the alternate testing described until we receive NRC approval.
We believe these requests are technically well supported and are generally accepted practices throughout the nuclear industry.
Further, the relief described will cause the test run times of safety-related pumps to be reduced.
For the reasons given, we request approval of these relief requests as soon as possible.
Fuel Oil Transfer System. Addition to IST Procram In the near future, we will add the fuel oil transfer system pumps and valves to the IST program.
Initially, testing will not be in compliance with Section XI codes due to the current system-configuration.
Modifications to upgrade the configuration to that required to satisfy testing are being developed.
Rather than delaying testing to wait for modifications to be completed or relief request approval, we plan to begin testing with the system as it is.
When physical modifications are completed, we will test according to ASME Section XI.
The physical modifications needed will be completed by January 1991,
o NRC Document Control Desk i
March 2, 1990 Page 3 Because we will be submitting a complete IST program rewrite for the next ten-year interval before January 1, 1991, we do not intend to submit the program changes for fuel oil transfer system inclusion to you prior to January 1, 1991.
We will be updating our IST program to reflect the addition of the fuel oil transfer system.
Cgpoliance Status Summary Attached is a Compliance Status Summary revised to indicate the information on the containment spray pumps and service water system.
Changes are indicated by bars in the right margin.
The summary has been given a revision number and date.
Very truly yours, 0
de v,i I
C. W.'Fa Vice president j
Nuclear Power l
Attachments Copies to NRC Regional Administrator, Region III NRc Resident Inspector
f a. =-
i RESPONSE TO GENERIC LETTER 89-04 Revision 1
' ATTACHMENT February 27, 1990 l
COMPLIANCE STATUS
SUMMARY
i GL 89-04 Item Compliance / Status i
1 No Additional special testing required, to be completed by April 1, 1990.
f 2
Yes Except alternate testing per page 3 of GL 89-04 was selected for some valves.
3 No Physical modifications required 4
Yes t
5 No Following the corrective actions described compliance will be achieved.
6 Yes 7
(Not applicable to PWRs) 8 Yes 9
No a.
Containment spray system of both units to be-modified to allow full flow testing.
Completion by January 1992.
b.
Service water system implementing.
procedures changed by August 1990.
'10 Yes Except that limits apply by penetration which may be more than one valve.
11 No Scope review to be completed as part of our next 10-year IST cycle, December 1990.
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PUMP RELIEF REQUEST NO. 11 Systems.
Safety Related, Unit I and Unit 2 component:
All pumps in the program class:
All Function:
To provide flow to safety systems Test To measure vibration in units of displacement.
(IWP 3210, Requirements:
IWP 4500 and any other sections)
Basis for The state of the art of vibration testing has improved Reliefs dramatically over several years. Experiente has shown that i
vibration testing can be a primary indicator of pump perfor-mance and degradation so long as proper units are measured and analyzed. This is documented in the current ASME Section XI code in that OH-6, which allows the use of vibration velocity, is crossreferenced.
Alternate The use of velocity as our vibration units and to use Testing:
OM-b - 1989, Part 6, Tables 3 and 3a (attached) to define our vibration acceptance criteria.
1 Status:
' Document
PART 6 OMt>1989 i _.
TABLE S (b)
RANCES FOR 1EST PARAMETERS 105 5
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104 i
J P
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6 2
ny l
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5 2
l 102 to2 5
2 101 5
2 100 5
2 10 1 v, miti, p k.to+eek e
i TABLE 3a' ump Pump Test Acceptable Alert Required Type Speed Parameter Range Range Action dange Centrifugal and
< 600 rpm V, or V, s 2.5 V,
> 2.5 V, to 6 V, or
> 6 V, or scrticalline
>10.5 mits
>22 mils shaft [ Note (2))
Centrifugal and a 600 rpm V, or V, s2.5 V,
>2.5 V, to 6 V, or
> 6 V, or i
vertical line
> 0.325 inisec
> 0.70 inJsec shaft [ Note (2)]
Reciprocating V, or V, s 2.5 V,
> 2.5 V, to 6 V,
> 6 V, (Table 3 continues on next page)
(Notes follow at end of table) l' l
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s PARt 6 OMb.1989 TABLE 3b Required Alert Range Action Range Acteptable Test Parameter Range low High Low High P (Positive displacement 0.93 to 1.10P, 0.90 to <.93P,
<0.90P,
> 1.10P, pumps) af (Vertical line shatt 0.95 to 1.10aP, 0.93 to <.954P,
<0.93aP,
> 1.10a P, pumps)
Q (Positive displacement 0.95 to 1.100,
- 93 to <.950,
< 0.93Q,
> 1.10Q, vertical hne shaft pumpsi JP (Centntugal pumps) 0.90 to 1.10ar,
< 0.90a P,
>t.10aP,
[
. Q (Centrifugal pumps) 0.90 to 1.100,
< 0.900,
> t.10Q, CINERAL NOf t: The subscript r denotes reference value.
NOTES:
(1) Vibration parameter per Table 2. V,is vibration reference salue in the selected units.
(2) Refer to Tig.1 to estabhsh displacement limats for pumps with speeds a 600 rpm or velocity hmits for pumps with speeds 600 rpm.
6.2 Time Allowed for Analysis of Tests 7.3 Record of Tests All test data shall be analyzed within 96 hr after The Owner shall maintain a record of each test completion of a test.
which shall include the following:
(a) pump identification; (b) date of test; 7 RECORDS AND REPORTS (c) reason for test (e.g., post maintenance, rou-tine inservice test, establishing reference values);
7.1 Pump Records (d) values of measured parameters:
The Owner shall maintain a record which shall (e) identification of instruments used; include the following for each pump covered by
(/) comparisons with allowable ranges of test this Part:
values and analysis of deviations; (a) the manufacturer and the manufacturer's (g) requirement for corrective action; model and serial or other identification number; th) evaluation and justification for changes to (b) a copyor summary of the manufacturer's ac-reference values; ceptance test report if available; (i) signature of the person or persons respon.
(c) a copy of the pump manufacturer's operat-sible for conducting and analyzing the test.
Ing limits.
7.2 Inservice Test Plans The Owner shall maintain a record of test plans 7.4 Record of Corrective Action and procedures which shall,nclude the following:
i (a) the hydraulic circuit to be used; The Owner shall maintain records of corrective (b) thelocation and type of measurement for the action which shall include a summary of the cor, required test parameters; rections made, the subsequent inservice tests and (c) the reference values; confirmation of operational adequacy (see para.
(d) the method of determining reference values 4.4), and the signature of the individual respon-which are not directly measured by instrumenta-sible for corrective action and verification of re-tion.
sults.
120
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PUMP RELIEF REQUEST NO. 12 System:
Safety Related,-Unit 1 and Unit 2
' Component:
All pumps in the program L
class:
All Function:
To provide flow to safety systems Test To measure each test quantity in Table IWP-3100-1; this Requirements:
includes bearing temperatures.
Basis for Almost all pumps are designed such that temperature at the Relief:
bearing itself cannot be obtained. The temperature which is actually monitored is bearing housing temperature or cooling /
lubricant temperatures. Such temperatures are not representative of what is actually occurring at the bearing.
Due to-the failure mechanisms of bearings, it is unlikely that occasional, periodic temperature monitoring will indicate impending failures.
Alternate To perform vibration monitoring, usir.g the units of velocity, Testing:
via state-of-the-art data analysis equipment provided pump relief request 11 is granted. Such vibration monitoring can indicate bearing performance and degradation.
Status:
Document:
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