ML20058P459
| ML20058P459 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/16/1990 |
| From: | Marsh L Office of Nuclear Reactor Regulation |
| To: | Eaton R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20058P462 | List: |
| References | |
| GL-89-04, GL-89-4, TAC-74785, NUDOCS 9008170074 | |
| Download: ML20058P459 (13) | |
Text
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ENCLOSURE
'ok UNITED sThTES o
8-NUCLEAR REGULATORY COMMISSION i
-g WASHINGTON, D. C. 20666 -
j AUG 181990 Docket No.:
50-293 MEMORANDUM FOR:
Ron Eaton Project Manager Project Directorate'l-3 Division of Reactor Projects - I/II FROM:
Ledyard B. Marsh, Chief l
Mechanical Engineering Branch l
Division of Engineering & Systems Technology 1
SUBJECT:
MEETING MINUTES 0F THE INSERVICE TESTING PROGRAM REVIEW WITH PILGRIM NUCLEAR POWER STATION ON AUGUST 7, 1990 I
(TAC N0. 74785)
A Pilgrim Nuclear Power Station IST Program' review meeting was held on August.
7,1990, in Braintree, Massachusetts. -There were ~ representatives from the licensee, EG&G-Idaho, and the NRR present.
The meeting agenda was prepared from a review of the Pilgrim Nuclear Power Station IST Program submitted January 4, 1990. The meeting agenda is included as Enclosure-l -
j Each item in the meeting agenda was discussed, and the resulting comments and i
action plans agreed upon by the attendees dre. included in the meeting minutes (Enclosure 2). :In order to expedite our review, the licensee should-address i
the items in the meeting minutes by incorporating their responses in a program revision and resubmitting the entire program.
These minutes-should be provided to the licensee with a request that they provide the submittal by -
September 30, 1990.
b ch M % v h
%N Ledyard B. Marsh, Chief-Mechanical Engineering Branch-Division of Engineering Technology l
Contact:
A. Keller, EMEB/DET
-j Ext. 20725
Enclosures:
As stated t
cc:
R. Wessman R. Eaton C. Ransom, EG&G age-
ATTACHMENT-1
~
I-SUP91ARY OF THE REVIEW OF RELIEF REQUESTS FROM THE
-PILGRIM POWER STATION PUMP AND VALVE INSERVICE TESTING PROGRAM a
Relief System and Reauest Component Licensee's Position EG&G Reviewer's Comments RP-1 RBCC Pumps-
.Added requirement.to Licensee's proposed alternate testing, to perform measure -individual pump a quarterly dead-head pressure test 1using only low flow rate and pressures values of the acceptance criteria of Table 3100-2 each refueling outage.
may not be acceptable.
Approved by GL 89-04.
RP-2 General Minor wording changes, Agree approved by GL 89-04.
l RP-3 SBLC Pumps Added flow instrument.
Licensee added a request for relief from the deviation from IWP-4600,
' flowrate. measurement requirements of IWP-4600 to 5
flow rate measurement.
the relief.. request.: Since the relief request has Basis and alternatef been expanded, this change constitutes more than a testing wording minor change. The accuracy ofEthis measurement; i
clarification. Approved-method is unknown, otherwise the relief request by GL.89-04 appears to t* r.cceptable.
~
]
1
'RP-4 SSW Pumps Relief request unchanged,
. Agree i
approved by GL 89-04.
RP-5 SSW Pumps Added requirement to Licencee's proposed alternate testing, to perfom I
measure individual pump
.a' quarterly dead-head pressure test using only low i
flow rate and pressures
- values of the acceptance criteria of Table 3100-2 i
each refueling.' Basis -
may not be acceptable.
and alternate testing
-wording clarification.-
Approved by GL-89-04. -
1 e
1 RP-6 SSW Pumps Relief request unchanged, Agree approved by GL 89-04.
1.
.l i
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1 Relief
. System and Reauest-
' Component Licensee's Position EG8G Reviewer's Comments l
RP-7 DF0 Pumps Reduced (made mere.
The licensee reduced the proposed acceptance range.
{
conservative) allowable.
acceptance criteria from 50% degradation'for.the i
corrective action ranges.
required action range and 25% for the alert range Approved by GL 89-04. '
to 25% and 15% resoactively, which is.still unacceptable. This relief request was denied in-
'the March 1987 TER.-
i
- RP-8 General New relief request per
' Relief request'is acceptabic.
j RP-9 General New relief request.
Further information necessary, but relief
- requiring NRC review.
~ request-appears to be' acceptable..
RP-10 HPCI Pump New relief request-We don't normally see the'HPCI gland seal
' requiring NRC review.
condenser condensate pumps in the IST program..
t Further information necessary.
l s
RV-1 RBCC' header-Minor wording change,
-Agree l
l RV-2' CA header
' Minor wording change, Agree CIV approved by GL 89-04 i
RV-3
- CAC, New relief request Relief request is essentially unchanged except for suppression requiring NRC review.
- the addition of the request for relief from
- the l
chamber Basis wording clarification.
position indication verification requirements of vacuum Added request for relief -
the Code. However, since the valve position f
breakers
' for position-indication indication'is required to be verified only once i
verification every every two years, relief to perform this testing
~
- refueling.
during refueling outages is not required.
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4 Rellef System and-Reouest Comoonent Licensee's Position EG&G Reviewer's Comments RV-4 General Minor wording change, Agree approved by GL 89-04.
RV-5
- TIP, Minor wording change,.
Agree Nitrogen approved by GL 89-04.
. purge checks RV-6 CS,.
Relief request unchanged...
Agree PIVs approved by GL-89-04.
RV-7
- HPCI, Minor wording change,
' Agree throttle approved by GL 89-04.
valve RV SBLC, Minor wording-change, Licensee added justification for not testing at injection approved by GL 89-04.
cold shutdowns. Relief request otherwise checks unchanged. We agree that this relief request is grand-fathered RV-9
- CRDH,
-Minor wording change,
-This relief-request is the same as the one in
-discharge changed basis due.to, _
Specification change which affects the testing-program revision 18 except for the' Technical-header check, Technical Specification accumulator amendment which affects frequency. However, the proposed alternate supply check,
.. testing frequency.
. testing ir the accumulator supply check valve
. scram inlet-Approved by GL 89-04.-
will not verify the reverse flow closure of this
-and outlet valve.
valves ~
RV-10
- CROH, Minor' basis wording f
Agree cooling clarification.- Approved water supply.
by.GL 89-04.
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^
.Re1lef System and Reauest
' Component licensee's Position EG&G Reviewer's Comments-RV-Il ADS valves
- Minor basis and alternate Licensee added request for relief from the testing wording changes.
_ fail-safe testing requirements of IWV-3415.-
i Approved by GL 89-04..
This request is not addressed in the licensee's i
basis for regeesting relief.
i 1
-RV-12 FW, Minor basis and alternate Agree-
' inlet check testing wording valves
.c1arification. Approved
--by GL 89-04.
i RV-13 Recirculation Minor function, basis, and Agree
]
pump seal alternate testing wording.-
water CIVs clarification. Approved by GL 89-04.
~!
RV-14
.SSW, Relief request unchanged, Agree
'~
screen wash approved by GL 89-04.;
}
isolation valves i
i i
RV-15
- DF0, Changed Code Class.from 3 Agree pump _
to NC. Approved by i
discharge-GL'89-04..
isolation i
valves i
-RV-16
- RCIC, Minor basis wording Agree 3
turbine c1arification. Approved 1
governor by GL 89-04..
valve s
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4 I
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I Relief System and Reauest Comoonent Licensee's Position EG&G Reviewer's Comments i
RV-17
- CRDH, New relief request per Normal motion control rod drive hydraulic valves i
1 normal GL 89-04.
are not covered-in the generic. letter and need-not-
' insertion be included in the IST program.. Therefore, and removal relief is not required.
~
1 valves RV-18
-NB-CA, Changed Code Class from 3 This relief request'.is essentially unchanced from
. isolation to NC. Approved by
. program revision 18. However, the licensee has i
proposed verifying a forward flow' exercise test -
--i te MSIV Ly stroking the MSIVs. Since the accumulators _
.I accumulators are sized so that the MSIVs will still cycle on a loss of control air, the_ proposed testing will not necessarily verify ~a full-stroke of the air J
l supply check' valves.
l i
i RV-19 Diesel air Changed Code Class from 3
. Agree f
start valves to NC.. Approved by l
l RV-20 RHR-CS, Minor changes, changed These changes are major, not minor. The licensee keep fill valves from normally open has substantially changed the basis' for relief and check valves to normally closed, wording has' proposed a different alternative to the Code-l changes-in basis and testing requirements.
Further, the licensee's new I
alternate testing.
proposed alternative may not.be~ acceptable.
' Approved by GL 89-04.
RV-21
- RWCll, New relief' request _
Further information necessary. Relief request-return header requiring NRC review.
- does. not _t.ontain justification for not testing check valve during cold shutdowns and the basis for relief.
' lacks details necessary for evaluation.
5' l.
' Relief System and
. Licensee's Position EG8G Reviewer's Comments Reouest'
'Comoonent i
.RV-22. General, New relief request Relief request is acceptable.
i excess flow requiring NRC review.
check valves RV-23 DF0, pump.
New relief request
-Further information necessary.~ The licensee discharge requiring NRC review.
proposes verifying check valve operability by check valves demonstrating proper operation of the diesels.
. Flow measurement for fuel oil pump-testing needs to be clarified.
RV-24
- RHR, New relief request Licensee has requested relief for leak rate
~~
header PIVs requiring NRC review.
testing the suction and discharge header
~
g and CIVs
. isolation valves at a refueling outage frequency instead of_every two. years. Therefore, relief is not required.
RV-25
- HPCI, New relief re;cest Further information necessary. The licensee has exhaust drain requiring NRC review.
requested relief from the Code strok( tOsing pot isolation requirements because the valves have cocmon valves.
remote valve position. indication.
It is not known i
whether'..the valves are capable'of.being. stroke timed using local indications.
RV-26
- CRDH, New relief request Relief request is acceptable.
seal flow requiring NRC review.
isolation and scram discharge volume drain valves 6
I a
=
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)'
Relief System and Request Comonent
__ Licensee's Position EGAG Reviewer's Comuments RV-27 General New relief request per
.This relief reonest is for disassembly atJ j
inspection of valves which cannot be verified to full-stroke by cther means. No specific valves cr i
systems are identified. This approach has cet been i
accepted in the past.
i
\\
RV-28 All CIVs New relief request per Licensee is requesting relief from the IW-3427(b)
corrective action r Nguirements and is acceptable.
RV-29 All power New relief request per Licensee is requesting relief frem the IWV-3417(a)
~!
i operated GL 89-04.
corrective action requirements. The licensee has i
valves proposed comparing stroke times to reference valve excluding based on stroke times when the valve is known to l
NOVs be in good operating condition, which-is
'o j
acceptable.. However, the licensee has also i
proposed that corrective action only be taken if stroke times deviate by greater than 1.5 x the i
reference val e plus.5 second for stroke times between I and 5 seconds.- This approach requires i-furtt.er justification.
i l
RV-30 "All valves New relief request The licensee is requesting relief from the within a requiring NRC review.
IWV-3420 leak rate testing requirements. The pressure licensee proposes using a system leakage rate I
boundary with criteria versus individual valve leak testing an**
l system proposes performing this testing in accordance integrity with the ASNT (American Society for leakage rate Non-destructive Testing) Test handbook, Volume 1.
i criteria."
Further justification is required concerning whether i
this testing is equivalent or superior to the individual I
i valve leak rate testing requirements of IWW-3420.
It is not known precisely which valves this relief request is applicable to.
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LEGEND FOR AB8REVIATIONS l
Abbreviation Meanina ADS Automatic depressurization system CA Control air CAC Containee.it atmosphere control j
CIV Containment isolation valve CRDH Control rod drive hydraulic CS Core spray
)
DFD Diesel fuel oil J
HPCI High pressure coolant injection j
FW Feedwater NB Nuclear boiler PIV Pressure isolation valve 4
RBCC Reactor building closed cooling RHR Resideal heat removal i
RWCU Reactor water clean up i-i SBLC Standby liquid control o
l SSW Salt service water l
TIP Traversing incere probe 4
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ATTACHMENT 2 l
i MEETING MINUTES PIIrRIM NUCLEAR POWER STATION.IST REVIEW AUGUST 8, 1990 1.
RV-3, RV-24 The licensee submitted relief for cases where the refueling cycle is greater than 24 months.
The licensee j
wants this for valves that can only be tested;during refueling outages.
During extended outages, the licensee will try to. test to maintain frequency as close as possible to the two year.
frequency.
The licensee should identify the specific compohntts affected by this relief request and the basis for the hardship or impracticality of meeting the code requirement.
2.
RP-1 The licensee stated that the differential pressure across the RBCCW pumps varise with small changes in suction pressure.
The licensee should identify the difficulty in contr-liing sGetion' pressure and why differential pressure goes high when suction pressure changer.. The licensee should add
'ards to relief request explainirg these problems and will gablish upper limits based on test data.
The licensee should
.so justify why the brer.dened limits and the potential data uncertainty in this test looli will not adversely affact.the ability to detect and trend pump degradation.
i 3.
RP-3 A new testing prceedure strictly-controls how this test is run.
The licensee is measuring change in tank level l
after a three minute run to calculate f)7w.
There has been good l
repeatability with the new procedare.
5 licensee will add words to relief about repeatability.
4.
RP-5 The licensee stated that the differential pressure across the SSW pumps varies with small changes in suction pressure due to tides.
The licensee should identify why-differential pressure goes high when suction pressure changes.
The licensee should add words to relief request explaining these problems and will establish upper limits based on test data.
The
?
licensee should also justify why the broadened limits and the potential data uncertainty in this test loop will not adversely affect the ability to detect and trend pump degradation.
2-1
~
5.
RP-7 that are based on data scatter of testdata repeatabi est that ultrasonic flow instruments cannot be restrictive limits s.
The licensee stated calibrated.
e more accurately 6.
RP-9 operators select the range that brings readinThe licensee has n the meter.
res to have request explaining the relection of instrument raThe licens possible improvements in instrument accuracyo the relief nges and 7.
RP-10 of these pumps as part of the HFCI skid mountedThe licensee ty unit.
8.
RV-9 verifyino closure of the 115 valves.The licenses will investigate how or if th information to the relief request They vill add this ey are 9.
RV-11 testing in their basis and alternate testiThe licensee will add a diac a
ng.
-safe 10.
RV-17 determine if they need to be included iThe licensee will evaluate these es to n the IST program.
11.
RV-18 will close using accumulator air only, but thThe licensee tested t not have sufficient air to reopen the MSIV's that they e accumulators do complete cycli exercise open.ng of MSIV's verifies that the, check valvestherefore, a relief request. The licensee will add this information to the 12.
RV-20 system during Refueling Outage RF-8The licensee will.cdd test connections will add the reverse flow closure testing to th i o the request.
(June 1991).
The licensee will be performed.They will also add a note about the modifi e r relief cations that 13.
RV-21 request for why these valves cannot be exerciThe licensee will ad shutdowns.
relief sed during cold 2-2
.. c a.
.s
i t
5.
RP-7 The licensee will provide information about test data repeatability and will establish more restrictive limits l
that are based on data scatter of tests.
The licensee stated that ultrasonic flow instruments cannot be more accurately calibrated.
j 6.
RP-9 The licensee has notes in their procedures to have operators select the range that brings reading to the middle of the meter.
The licensee will add more information 40 the relief o
request explaining the selection of instrument ranges and possible improvements in instrument accuracy.
7.
RP-10 The licensee will evaluate verifying operability of these punps as part of the HPCI skid mounted unit.
8.
RV-9 The licensee will investigate how or if they are verifying closure of the 115 valves.
They will add this information to the relief request.
9.
RV-11 The licensee vill add a discussion on fail-safe
. testing in their basis and alternate testing.
T 10.
RV-17 The licensee will evaluate these valves to determine if they need to be included in the IST program.
11.
RV-18 The licensee tested the MSIV's and found that they i
will close using accumulator air only, but the accumulators do not have sufficient air to reopen the KSIV's, therefore, a i
complete cycling of MSIV's verifies that the check valves exercise open.
The licensee will add this information to the relief request.
12.
RV-30 The licensee will add test connections to the system during Refueling Outage RF-8 (June 1991).
The' licensee will add the reverse flow closure testing to their relief request.
They will also add a note about the modifications that will be performed..
e 13.
RV-21 The licensee will' add a basis to their relief request for why these valves cannot be exercised during cold shutdowns.
2-2 i
., _ _,. _ ~. _
14.
RV-23 The monthly diesel generator test is a full-load test, therefore, these check valves ars full-stroke exercised open during this testing.
The licensee will add this information to the relief request.
15.
RV-27 The licensee will identify in their IST program the valves that are disassembled.
They will also identify the reasons that it is impractical to test these valves with flow or by other Lear =.
The valve groupings for disassembly will be iaentified.
The licensee will also investigate other means of verifying valve full-stroke capability.
16.
RV-29 The licensee will add information to their relief I
request on how they set the reference values.
They will also provide additional information on their proposed method of testing and will provide information to support the acceptability of the proposed alternate testing, including failure mechanisms of the valves.
17.
RV-30 This relief request does not apply to containment isolation valves, pressure boundary isolation valves, pr other valves that have component specific leak rate limits.
It only applies to valves that are in systems where the system has a leakage limit such as the ADS accumulator supply check valve where the pressure test involves more than the check valve.
The licensee will clarify the applicability of the relief request.
MEETING ATTENDEES l
NRC UTILITY R.
Li G. O'Connor l
R. Eaton J.
Bellefeuille A. Keller W. Carroll C.
Ransom (EG&G)
R.A. Haladyna B. Sullivan 2-3
.