ML20116N410
| ML20116N410 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/16/1992 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-92-135 VPNPD-92-355, NUDOCS 9211240004 | |
| Download: ML20116N410 (4) | |
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! Electnc POWER COMPANY 231 W McNgon, Ro. Box 2046. Mitwouke+e W153201 (4141 221-2345 VPNPD-92-355 NRC 135 November 16, 1992 Docurint Control Desk U.S.
NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:
DOCKETS 50-266 AND 50-301 PUMP AND VALVE INSERVICE TEST PROGRAM PUMP RELIEF REOUESTS POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 Enclosed is a requ'ast for relief (PRR-21) from certain ASME Section XI Code requirements applicable to the inservice testing of our fuel oil transfer pumps, P-070h and P-070B.
As a result of a recent telephone conversation on October 7, 1992, between members of our engineering staff and Patricia L. Campbell of NEP we believe that this request is acceptable.
The first part of our request, seeking relief from ASME Section XI-1986, IWP-3100, " Inservice Test ~ Procedure," stems from that article's lack of discrimination between the test parameters useful for testing centrifugal pumps and the test parameters useful for testing positive displacement pumps.
In more recent versions of the Code, this has been corrected.
- Thus, use of a more recent version or the Code, such as ASME OMb-1989, Part 6, is preferable ~and serves as an acceptable alternative for the inservice testing of Positive Displacement Pumps P-070A and P-070B.
The second part of our request, seeking relief from ASME Section XI-1986, IWP-4110, " Quality," with respect to P-070A and P-070B flow. rate instrumentation, follows from your Safety Evaluation Report.(SER) of April 17, 1992, on the Point Beach-Inservice Test (IST) Program.
The SER Technical Evaluation Report (TER), Section 2.1.6, evaluated a previous request (PRR-10) seeking relief from the requirements of IWP-4110, and granted only interim relief for a period of one year.
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Document Control Desk l
Nov, ember 16, 1992 Page 2 We have completed a review of the instrumentation covered under Relief Request PRR-10, and find that it may be formally withdrawn when relief is granted for P-070A and P-070B flow rate instru-mentation.
As discussed in our enclosed request, PRR-21, the currently installed flow rate instrumentation for'P-070A and P-070B is sufficient to ensure pump operational readiness, and is an 9
acceptable alternative, in this instance, to instrumentation which would meet the requiremente of IWP-4110.
Upon receipt of approval for Relief Request PRR-21, we will formally withdraw Relief Request PRR-10.
Additionally, in evaluating PPR-21, we believe you should take into consideration our plans to remove Fuel Oil Transfer Pumps P-070A and P-070B from our IST Program in the future.
With the current 1.y planned installation of tNo new emergency diesel generators (EDGs),
as discussed in our August 3, 1990, " Response tr Inspection Reports 50-266/90-201 and 50-301/90-201," the fuel o
iransfer system is expected to undergo extensive redification t.ad upgrade.
The.
function of Fuel Oil Transfer Pumps P-070A anc1 P-070B to supply fuel oil for EDG use will be performed by four new pumps, planned for installation in conjunction with the ad/.ition of our two new EDGs.
P-070A and P-070B will be removed f*om the IST Program at the same time as the four new fuel oil tr.:sfer pumps are incor-
)
porated into the program.
At that time, the enclosed relief' request, PRR-21, will no longer be necessary and will be formally withdrawn.
Should you have any questions or require any additional infor-mation, please do not hesitate to contact us.
Sincerely, N
B o' Link Vice President Nuclear Power jg Enclosures.
cc:
NRC Resident Inspector NRC Regional Administrator, Region III Adele DiBiasio, Brookhaven National Laboratory A
W_
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RELIEF REQUEST NO. PRR-21 SYSTEM:
Fuel Oil Transfer (M-219)
COMPONENTS:
Fuel 013 Transfer Pumps, P-070A & P-070B FUNCTION:
P-070A and P-070B are non-unit specific pumps which transfer fuel s
oil, as required for emergency diesel generator (EDG) operction, from the emergency fuel tank to the individual diesel fuel il day tarks.
SECTION XI REOUIREMENTS:
1)
An inservice test shall be conducted with-the pump operating at nominal motor nameplate speed for constant speed drives, and at a speed adjusted to the reference speed.for variable speed drives. -The resistance of the system shall be varied until either the measured differential pressure or the measured flow rate equals the corre ponding reference value.
The test quantities shown in Table IWP-3100-1-shall then be measured or observed and recorded as directed in this t
subsection.
Each measured test quantity shall then be compared with the reference value of the same quantity.
Any 7
deviations aetermined shall be compared with the limits given in Table IWP-3100-2 and specified corrective action taken-(IWP-3100, " Inservice Test Procedure").
2)
Instrument accuracy shall be within the limits of Table IWP-4110-1.
Station instruments meeting these requirements shall be acceptable.
NOTE:- Table IWP 4110-1, dAcceptable Instrument Accuracy," delineates an acceptable accuracy of 12% of full scale for flow rate insi.ruments (IWP-4110, " Quality").
ALTERNATE TESTING:
1)
P-070A and P-070B are both Crane-Deming gear driven, single speed, rotary gear _ type positive displacement pumps.- For pumps of this-type, discharge pressure is independent of suction: pressure and is a function only of the pump design.
4 Measuring pump inlet and differential pressure does not provide any meaningful information for evaluating pump i
r performance.
Consequently. later editions of the Code do-nct require the measurement of either inlet or differential
-pressure for positive displacement pumps.
J
As opposed to ASME Section XI-1986, IWP-3100, which does not differentiate between positive displacement and centrifugal pumps, the more recent ASME OMb-1989, Part 6, Subsection 5.2,
" Test Procedure," shall be used for inservice testing of P-070A and P-070B.
2)
Instrument accuracy for the measurement of flow rate during inservice testing of P-070A and ?-070B shall be within 13%
of full scale, as opposed to i2% of full scale required by IWP-4110.
BASIS FOR RELIEF:
1)
As discussed in the Alternate Testing section above, ASME Section XI-1986 does not differentiate betwe*n positive displacement and centrifugal pumps when delineating test procedures.
Measurement of suction and differential pressures does not provide any meaningful information for evaluating positive displacement pump performance.
As discussed above, use of the test procedures outlined in the more recent ASMc OMb-1989, Part 6, correctly differentiates between different types of pumps and provides an acceptable alternative to the Section XI Code requirements for assuring pump operational readiness.
Therefore, relief may be granted in accordance with 10 CFR 50.55a(a) (3) (3 ).
2)
The flow rate instruments used for P-070A and P-070B inservice testing have a range of 0-15 GPM, which ideally places pump referenes flew at approximately two-thirds of full scale (approximately 10 GPM).
An accuracy of i3% of full scale translates to 10.45 GPM for these instruments, uhereas an acer any of 12% of full acale, as called out in IWP-4110, woulo cranslate to 10.30 GPM.
The difference of 0.15 GPM is not significant, especially when considering i
that since these are positive displacement pumps flow rate does not vary.
The installed instruments with an accuracy of i3% of full scale are sufficient in this application to assure pump operational readiness and, thus, relief may be granted in accordance with 10 CFR 50.55a(a) (3) (i).
STATUS:
Submitted to the NRC for review and approval November 16, 1992.
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