ML20059L491

Comment on Draft NUREG-1482, Guidelines for Inservice Testing at Npp. Recommends That Engineering Analysis Be Performed to Determine Acceptability of Pump or Valve for Continued Operation Re Frequency Testing for Pumps & Valves

ML20059L491
Person / Time
Site:	Nine Mile Point
Issue date:	01/28/1994
From:	Terry C NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-58FR65738, RTR-NUREG-1482 58FR65738-00002, 58FR65738-2, GL-89-04, GL-89-4, NMP1L-0799, NMP1L-799, NUDOCS 9402070055
Download: ML20059L491 (3)

Text

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January 28,1994 -~ i NMPIL 0799 732 Id/lG/93 U. S. Nuclear Regulatory Commission Chief, Rules Review and Directives Branch Q

Division of Freedom of Information and Publications Services Mail Stop P-223 Washington, D.C. 20555 Re: Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69 Ladies and Gentlemen:

SUBJECT:

Comments on Dmft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants" Attachment I contains Niagara Mohawk's comments on draft NUREG-1482. If you have any questions regarding our comments, please contact Mr. Ali Egap at 315-428-7314.

Very truly yours,

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<. C. D. Terry Vice President Nuclear Engineering l

j- MJJ/ksj 0046470G Attachments pc: Ms. Patricia Campell, NRR Regional Administrator, Region I Mr. B. S. Norris,. Senior Resident Inspector Mr. R. A. Capra, Director, Project Directorate I-1, NRR Mr. D. S. Brinkman, Senior Project Manager, NRR Mr. J. E. Menning, Project Manager, NRR Records Management

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9402070055 940128 PDR NUREG 1482 C PDR l

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ATTACIIMENT 1 - Page l'of 2 Comments on Draft NUREG-1482

" Guidelines for Inservice Testing at Nuclear Power Plants" Section 4.2.1

Subject:

Increased frequency of testing for valves and pumps that can only be tested during cold shutdown.

Discussion: Section 4.2.1 contains an NRC recommendation that exception from increased cold shutdown testing be submitted to the NRC.

for approval.

There is no advance notice which valve (s) or pump (s) tested at cold shutdown will fail, thus requiring corrective action as specified in IWV-3417(b). Since a cold shutdown justification has demonstrated that the test can only be performed at cold shutdown, it is not practical to prepare a relief request, submit the request to the NRC -

for evaluation and obtain approval within 30' days.

Alternative: Niagara Mohawk recommends that:

1) an engineering analysis be performed to determine the acceptability of the pump or valve for continued operation, and,

2) pumps or valves with cold shutdown test results in the " Alert-Range" be scheduled such that testing is performed during a subsequent cold shutdown if the drywell is de-inerted and the test has not been performed during the previous 45 days.

Section 4.3.1

Subject:

laclusion of. overpressure protection relief valves'that do not perform safety-related functions in the IST Program Plan.

Discussion: Section 4.3.1 contains the NRC proposal that licensees include in the IST program plan nonsafety-related pressure relief valves designed to function as over-pressure protection components.

The IST program plan should be limited to pumps and valves which perform safety-related functions for safe shutdown, maintaining safe shutdown or mitigating the consequences of an accident (Ref. IWV-1100).

Alternative: Niagara Mohawk recommends that overpressure protection relief valves that do not perform safety-related functions be included in the preventive maintenance program of the plant.

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. ATTACIIMENT 1- Page 2 of 2 Comments on Draft NUREG-1482  !

." Guidelines for Inservice Testing at Nuclear Power Plants"- -

1

- (continued) -

Section 5.4 ,

Subject:

Frequency Response Range - .

Discussion: Section 5.4 discusses the OM-6 requirement that the frequency?

response range of the vibration measuring transducers and their readout system be from one-third minimum pump shaft rotational- i speed to at least 1000 Hz. i The minimum speed for the liquid poison pumps at NMP1 and NMP2 is 360 RPM, or 6 Hz. Obtaining certifiable calibrations at pump shaft rotational speeds of 2 Hz using the 'more up-to-date equipment currently available can be difficult. Therefore, to obtain a certifiable calibration as prescribed by OM-6 requires the use of- .,

less up-to-date and more time and labor intensive equipment.- l Alternative: Niagara Mohawk recommends that the NRC allow relief to limit the f frequency response range for low speed pumps to a range of 3 Hz to l

1000 Hz. This would allow the use of more up-to-date and

• economical equipment currently available to the industry. ,

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