ML20127D650
| ML20127D650 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Cook |
| Issue date: | 03/29/1985 |
| From: | Rubenstein L Office of Nuclear Reactor Regulation |
| To: | Lainas G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082410334 | List: |
| References | |
| FOIA-85-243 TAC-56427, NUDOCS 8504300120 | |
| Download: ML20127D650 (3) | |
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MAR 2 91985 MEMORANDUM FOR: Gus C. Lainas, Assistant Director for Operating Reactors, Division of Licensing FROM:
L. S. Rubenstein, Assistant Director for Core and Plant Systems, Division of Systems Integration
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SUBJECT:
AFW PUMP TEST SURVEILLANCE REQUIREMENT FLOW INTERPRETATION, COOK 1 AND 2 (TACS 56427/8)
In accordance with TACs 56427 and 56428, the Auxiliary Systems Branch has reviewed the licensee's November 28, 1984 letter which requests NRR inter-pretation as to whether the method of performing the monthly pump test required by Technical Specification 4.7.1.2.a.2.b for the turbine driven pump for D. C. Cook, Units 1 and 2 properly implements the Technical Specification requirements. The subject specification requires that the turbine driven pump be demonstrated operable every 31 days by verifying that "the stean turbine driven pump develops a discharge pressure of t 1285 psig at a flow of E 700 gpm when the secondary steam pressure is greater than 310 psig." The plant procedures for perfonning this test provide for adjusting the turbine speed to 4350 rpm and establishing a flow of 700 gpm. The pump discharge pressure is then recorded and compared to the 1285 psig (corrected for temperature) minimum requirement of the specification.
Region 3 (refer to Inspection Reports 50-315/84-13 and 50-316/84-15) expressed a concerv that the pressure, when corrected for temperature, allows the test to be found acceptable when the pressure is less than that stated in the sur-veillance requirement (1285 psig). While we agree with the licensee's philo-.
sophy for correcting the discharge pressure for temperature and with the correction factors identified in the procedures, we question the methods identified in the procedure for measuring the pumped fluid temperatures. The applicant's procedures for determining condensate temperature call fnr placing a handheld pyremeter against the suction piping. We co not believe this is an accurate method of determining condensate temperature.
Further, since the correction factors involved with the range of temperatures expected in the condensate tank (40'F/+ 1 psig - 100*F/-8 psig) are small, and may be no greater than inherent instrument errors and reading inaccuracies, the correc-tion factor appears unwarranted and unnecessary.
Hcwever, we do agree with the licensee that a temperature correction factor for determining the required discharge pressure during the surveillance testing procedure does not invalidate the test results on a technical basis. We also agree that this is not necessarily an item of noncompliance but a matter of interpretation.
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2 MAR 2 91985 Based on our review, we conclude that the licensee should take one of two actions:
1.
Revise the, specification to identify that the 1285 psig acceptance pressure is based on a fluid temperature of 60*F and develop a more accurate method of determining the temperature of the pump fluid, or 2.
Delete the correction factor from the surveillance procedure.
Since the temperature correction factor is relatively inconsequential and to our knowledge is not used at other' facilities, we suggest the 1.icensee delete it from the procedures as this would not involve a revision to the technical specification.
This completes our effort on TACs 56427/8. We have also enclosed our SALP input.
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L. S. Rubenstein, Assistant Director for Core and Plant Systems Division of Systems Integration cc:
R. Bernero H. Thompson O. Parr S. Varga D. Wigginton E. Butcher D. Brinkman J. Wermiel W. LeFave
SALP INPUT Plant: D. C. Cook 1 & 2 (TACs 56427/8) 1.
Management Involvement and Control in Assuring Quality: Not Applicable
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2.
Approach to Resolution of Technical Issues from a Safety Standpoint:
Category 2 3.
Responsiveness to NRC Initiatives: Not Applicable
- 4. ; Enforcement History: Not Applicable 5.
Reporting and Analysis of Reportable Events: Not Applicable 6.
Staff (Including Management):
Not Appli. cable 7.
Training and Qualification Effectiveness: Not Applicable The following is the narrative for Items 2 and 3 above.
The licensee provided sufficient technical information to support its position
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with the initial submittal. However, the usefulnsss of the temperature cor-N.
rection factor in the test procedure is questionable.
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