ML20150B045
| ML20150B045 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/05/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8807110237 | |
| Download: ML20150B045 (33) | |
Text
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B ALTIMORE i
GAS AND J
ELECTRIC i
CHARLES CENTER P. O. BOX 1475 BALTIMORE. MARYLAND 21203 JOSEPH A.TaERNAN Vict PatssoENT NucLEAn ENERGY July 5,1988 9
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Emposed Pumo and Valve Inservice Test (IST) ProRram REFFRENCE:
(a) Letter from hir. S. A. hicNeil (NRC) to hir. J. A. Tiernan (BG&E),
dated April 19,
- 1938, Request for Additional Information (TACS 64976 and 64977)
(b) Letter from hir. S. A. hicNeil (NRC) to hit. J. A. Tiernan (DG&E),
dated November 13, 1987, Request for Additional Information Gentlemen:
Please find attached our responses to questions on the ash 1E Section XI Second 10-year interval IST program. This letter constitutes our reply to Reference (a).
We have reviewed the trip report enclosed in Reference (a). Except for the questions we have responded to in the attached, we concur with the discussions as represented for the meeting on February 18 and 19, 1988. Our attached response covers those questions that are identified as open items or that require some action. The combination of the trip report and the attached responses fully address the questions in Reference (b).
The attached responses and associated Relief Requests, once approved, will be fully incorporated in a new revision of the Calvert Cliffs Nuclear Power Plant Units I and 2 Second 10-Year ash 1E Section XI Pump and Valve Test Program. All respective line-by-line changes based on these responses will also be incorporated at that time.
Once final disposition of these responses is received, the new revision of the Pump and Valve Test Program will be submitted.
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l 8807110237 880705 PDR ADOCK 05000317 P
4 Document Control Desk July 5,1988 Page 2 Should you have any further ' questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, we JAT/SRC/ GDS / dim Attachment I
cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC D. C.Trimble, NRC T. Magette, DNR i
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i BALTIMORE GAS & ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANTP UNITS 1 AND 2 RESPONSES TO NRC QUESTIONS ON THE ASME SECTION XI SECOND TEN-YEAR INTERVAL l
PUMP AND VALVE TEST PROGRAM l
June 1988 i
Prepared with General Physics Corporation l
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GENERAL _QUESI1ONS_AND_C0ttiENIS 2.
The NRC has concluded that the applicab1E leak test procedures and requirements for containment isolation valees are determined by 10CFR50, Appendix J.
Relief from paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety problem siace the intent of IWV-3421~
through 3425 is met by Appendix J requirements. However, the licensee shall comply with Paragraphs IWV-3426 and 3427. See section 3.1, page 3. of the Calvert Cliffs IST program discussion of "Category.% Valves."
Response
For Containment Isolation Yalves, no testing will be perfoteed via IWV-3400.
However, both IWV-3426 ( Analysis of Leakage Rates) and IWV-3427(a) (Corrective Action) will be complied with for all valves. Regarding IWV-3427(b). Calvert Cliffs feels that the leakage rates for valves 6 inches and larger do rot show enough consistency in the level of degradation prior to reaching the maximum leakage limit to justify maintaining these additional corrective action and trending requirements, and therefore would request relief from following IWV-3427(b). This is in Keeping with the current philosophy identified in the recently ASME-approved OH-10 on Inservice Testing of Valves, which does not require trending of leakage rates. See the attached Request for Relief A-3 i
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GENEBAL_QUESI1ONS aEE..C0ttiENIS RELIEF REQUEST NUMBER A-3 System:
Various PEIDs:
Various Valves:
All those identified with "CIV" in the Remarks column of the associated Valve Test Program.
Class:
Various Impractical Test Requirements:
a.
IWV-3421 through 3425 regarding leak rate test methodology.
b.
IWV-3427(b) regarding leak rate trending requirements.
In keeping w8th NRC Staff positioa all CIV testing Basis for Relief:
a.
shall be performed under 10CFR50 Appendix J in addition to IWV-3426 and IWV-3427(a). Testing per 10CFR50 Appendix J mests the intent of leak rate testing per Section XI. but will be contcolled via the Local Leak Rate Testing trogram.
b.
The attached data shows that the variability of leak rates for valves 6 inches and larger is excessive.
CCNPP feels that this excessive variability shows the relative independence of one leak rate test to another.
The tendency towards random leak rate data would cause unnecessary testing per IWV-3427(b), with no l
identifiable increase in benefit to public health and safety. The worth of performing this additional trending is also called inte question by the recent ASME approval of OH-10 ("Inservice Testing of Valves"), which is the planned replacement to Section XI testing rules.
OM-10 does not tequire trending of valve leak rates.
l Alternative Testing a.
CCNPP shall test all CIVs under the requirements of i
10CFR50 Appendix J, in addition to IWV-3426 and IWV-3427(a).
b.
CCNPP shall perform no alternative testing in keeping with OM-10 guidance.
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GENERAL _QUESIIONS_AND_CQHbENIS CCHEE_ Unit _i_ Leak _ Rate _ Data Lin_SCCHI TEST DATE Pen Yaixe_Not Noi 6182 12183 IIBA SIB 5 12185 12186 5188 SI-340 9(1) 40 6 1272 136.3.
804 65 7 952*
842 SI-326 9(2) 19.5 1090 92.4 440 60.8 993 977 SI-330 10(1) 2.1 745 18.7 436 746 1778.
369 SI-316 10(2) 210 1558 414 208 280 895 329 CV 3832 16 11.3 110 1060 201 59 62.4 224 CV-3833 18 33.27 110 5.0 24.9 2.5
-392 26 2 FP-141A 44(1) 107 0 1094 751*
36.2 445 902 999 FP_141B 44(2) 102.3 24.7 155 468 1890 994 52 2 MOV-6200 44(3) 35 8 108.4 138.3 819 726 32.4 104.9 HOV-651/2 41 715 2 1430 2446 2376 1716 3338*
7629.
-SFP-170/1 59 40.7 47.8 140 50 9 58 94 8 06 SFP-VLVS 61 1.04 410*
139.2 336 462 760 643 (172, 174 176, 189)
- Post Maintenance data 3
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GENERAL _QUESIIDHS_AND.COHHEHIS CCNEE_ Unit 2 Leak _ Rata _ Data fin _SCCM1 TEST DATE Pen Yalve_ Hot Hot 12L13 3181 12182 IL8k 12185 AL82 SI-340 9(1) 310 1903 240.
136.3*
65 7*
1331 SI-326 9(2) 120 50 5 100 1 92 4 60.9 99.6 SI_330 10(1) 204 330 1776 18.7*
746*
1299 SI-316 10(2) 112 6 28 4 258 414 280 210 CV_3832 16 0 66 164.4 47 6*
1060 5.9 57.5 CV-3833 18 0.42 94 921*
50 25 57.2 FP-145A 44(1) 43.2 400 1.92*
751*
445 114.1 FP-145B 44(2) 0 1370 716 155 1890 326 MOV-6200 44(3) 3800*
3367 4*
87 8 138.3 726 7.58 HOV-651/2 41 1290 10,730 2384*
2446.3 1716 5*
238 3*
SFP_170/1 59 5.96 3 97 0.6 140 58 4.2 SFP-VLVS 61 8.49 17.2 12 6 139.2 462-208 (172, 174 176, 189)
- Post Maintenance data 4
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GENERAL _QUESIlONS_AND_C0tti;HIS t.
The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them during plant operation. These valves must be specifically identified by the licensee and are full-stroke exercised during cold shu' downs. The PutC requires that the licensee provide a technical justification for each valve that cannot be exercised quarterly during power operations that clearly explains the difficulties or hazards encountered during that tecting. The NRC staff will then verify that it is not practical to exercise those valves and that the testing chould be performed during cold shutdowns. The cold shutdown justifications in the Calvert Cliffs IST program need to include more detailed information.
Response
See attached Appendix E.
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APPENDIX E VALVES TESTED DURING COLD SHUTDOWN l
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i APPENDIX E VALVES TESTED DURINC COLD Shit!DOWN System Unit Yalva_Humber Justification o
1/2 2-CV-4043 Valves cannot be full stroke Reheat 2-CV-4048 tested during plant operation 1-CV.4043 without causing major plant 1-CV 4048 transients / plant shutdown.
Valves are part-stroked per manufacturers recommendations only. Valves are full stroke tested at Cold Shutdown at 3 month intervals as allowed by Section XI.
Condensate &
1/2 1-FW-133 Exercising these normally open Feedwater 2-FW-133 valves would require a 1-FW-130 cessation of feedwater flow to 2-FW_130 the steam generator. This 1_HOV-4516 would cause transients leading 2 MOV-4516 to shutdown. Valve logic and 1.MOV-4517 system c'.ifiguration prevent 2-MOV.4517 any part_ stroke testing of MOVs. Therefore, the valves are full stroke tested at Cold Shutdown at 3 month intervals as allowed by Section XI.
Service Water 1/2 1.CV-1600 Exercising these valves during Cooling System 1-CV 1637 operation would stop cooling 1-CV_1638 water flow to the main turbine 1-CV-1639 auxiliaries and other vital 1-SRW-323 secondary plant equipment 1-SRW-324 necessary for power operation, 1-SRW-325 causing plant shutdown. System 2-CV-1600 configuration prevents Air 2-CV.1637 Operated Valve part stroke 2-CV-1638 testing during power operation.
2-CV-1639 Valves are full stroke 2 SRW-323 exercised at Cold Shutdown at 3 2_SRW.324 month intervals as allowed by 2-SRW_325 Section XI.
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s System Unit Yalre_Humber Justification.
Component Cooling 1/2 1.CV.3832 Exercising these val'ves during 1-CV.3833 operation would stop cooling 2-CV-3832 water flow to the reactor 2_CV_3833 coolant pumps and other vital equipment necessary for power operation causing equipment dansEe or plant shutdown.
Valve logic prevents part-stroke testing of Air Operated Valves during power operation.
Valves bre full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
Compressed Air 1/2 2 HOV-2080 Exercising these valves Plant &
2-IA-175 requires isolating instrument Instrumee.t 1_IA-337 air to the containment thereby 1 MOV-2080 failing numerous air operated valves. Although control of these valves is not required during an accident it is required for normal reactor operation. Systea configuration and valve logic prevents part stroke testing these valves during power operation. Therefore, these valves are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
l Vintilation System 1/2 1-HP_6900 Valves are required by Tech.
1-HP-690 Spec. to be maintained closed l
2-HP-690' during Power Operation. Valves l
2_HP-6901 are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
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Syntaa Unit Yalve_Humbec Justification Reactor Coolant 1/2 1_SV-103 Stroking valves during plant System 2.SV.103 operation could cause failure 1-SV.104 to reseat properly thus 2.SV-104 reducing plant reliability.
1-SV-105 Failure to reseat could cause 2-SV-105 system / equipment damage, there-1-SV.106 fore no full-or part-stroking 2-SV.106 of valves is possible. Valves are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
CVCS 1/2 1-CVC-162 Valves cannot be st:oked during 2-CVC-162 operation without stopping all 1.CVC.184 charging pumpc. This would 2-CVC-184 place excessive thermal cycles 1.CVC-435 on system equipment due to 2-CVC-435 starting and stopping charging and letdown. Therefore, valves are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
s CVCS 1/2 1-CVC-235 Exercising these valves 2-CVC-235 requires injecting concentrated 1-CVC.228 boric acid directly into the 2-CVC_228 recctor coolant system. The resulting rapid power decrease and reactor water chemistry change would cause plant shutdown. Flow is verified by measurir.g tank level change or i
flow through the changing pumps I
which is not possible during power operation. Therefore, the valves are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
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' u System Unit Yalva_ Number Justification CVCS 1/2 1-MOV-501 Valvea cannot be stroked during 2 MOV-501 operation without stopping all 1-CV-515 charging pumps. This would 1-CV-516 place excessive cycles on 2-CV-515 starting and stopping charging i
2_CV-516 and letdown which are required to operate. This would also place unnecessary cycles on a limited cycle life Regen. Heat Exchanger, decreasing component available lifetime. Therefore, valves are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
CVCS 1/2 1-CV-517 Valves cannot be stroked 2-CV.517 during plant operation due to 1 CVC_185 (open) the resultant thermal stress to 2_CVC_185 (open) to the spray line and spray nozzle. Valves will be full-stroke exercised at Cold Shutdown at 3 month intervals a_ allowed by Section XI.
CVCS 1/2 1.CVC-186 (shut)
Exercising these valves 2-CVC-186 (shut) requires personnel access to 2-CVC-187 (shut) high radiation areas within the 1-CVC-187 (shut) containment during plant 1-CVC-185 (shut) operation. Man rem exposure if 1-CVC-185 (shut) the valves were stroked during operation would be greater than 100 arem gamma and 50 mrem neutron. Therefore, the valves are full stroke exercised at Cold shutdown at 3 month intervals as allowed by Section XI.
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i System Unit Yalve Humber
, Justification.
CVCS 1/2 1-CVC-505 Valves cannot be stroked during 2-CVC-505 plant operation without 1-CVC-506 stopping RCP seal bleed off 2.
2-CVC-506 flow reducing RCP schl re11ahf.lity, causing possible RCP failure. Valve logic prevents part stroking these valves during power operations.
Valves are full str6ke tested at Cold Shutdown at 3 month intervals as allowed by Section XI.
Safety Injection 1/2 1-SI-446 Valves cannot be full or part-Containment Spray 2-SI-446 stroked during operation System 1-SI-434 because normal RCS pressure is 2-SI-434 above the shutof f head of the LPSI Pumps. This would require depressurizing the reactor coolant systeu, causing plant shutdown. Valves will be full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
Safety Injection 1/2 1-SI-427 Valves cannot be full-stroked Containment Spray 2-SI-427 during power operation because System 1-SI-414 normal RCS pressure is above 2-SI-414 the shutoff head of the HPSI l_SI-405 pumps. Depressurizing the 2-SI-405 react r coolant system would be 1-SI-401 required, forcing plant, shut-2-SI-401 down. Valves voi:1d be part 1-SI 410 stroked whenever the associated 2-SI-410 HPSI pumps are run to fill l
Safety Inspection Tanks. The valves are full stroke exercised at Cold Shutdown at 3 I
month intervals as allowed by Section XI.
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1 o-Syalam Unit Yalva.Humber Justli1 cation Safety Injection 1/2 1.SI-118 Valves cannot be full stroked Containment Spray 2-SI-118 dur3ng operation because RCS System 1-SI-128 pressure is above shutoff 2-SI-128 head of the HPSI pumps.
1-SI-138 Valves will be part-2-SI.138 stroked whenever the SI tanks 1-SI.148 are filled and full-stroked at 2-SI-148 Cold Shutdown at 3 month intervals as allowed by Section XI.
The test conditions are established to prevent Low
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Temperature Overpressurization.
Safety Injection 1/2 1.SI.114 Valves cannot be stroke tested Containment Spray 2-SI.114 during power operation due to System 1-SI-124
. the head of the LPSI. pumps being 2-SI-124 less than the required pressure 1-SI-134 to overcome the effect of 2-SI-134 Safety Injection Tanks Presstire 1-SI-144 on these valves. Valves will 2-SI-144 be full stroke exercised at Cold Bhutdown at 3 month intervals as allowed by Section XI.
Safety Injection 1/2 1-SI-313 Valves cannot be stroke tested Containment Spray 2-SI.313 during power operation as this System 1-SI-323 may cause borated water to 2-SI.323 deluge the containment resulting in equipment.. damage and plant shutdown. See Relief Pequest SI-6.
.__..... ____________._..___..__..._____..__________. ; C__.-..._____
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.i System Unit Yalve_Humber Justificatio5 l
. Safety Injection 1/2 l_HOV-651 Valves are interlocked on Containment Spray 2_HOV-651 reactor coolant system System 1-HOV-652 pressure.and cannot,be tested 2_HOV 652 st power. This is'to provide overpressure protection of the downstream piping.
the valves are full stroke exercised at Cold Shutdown at 3 month intervals as allowed by Section XI.
Safety Injection 1/2 1-MOV-659 Failure of these valves in the Containment Spray 2-HOV-659 closed position during System 1-MOV.660 operttion would cause an entire 2-MOV_660 safety system to become inoperable. Valve logic prevents a part-stroke of these valves. Therefore, these valves will be full-stroke exercised at Cold Shutdown as allowed by Section XI.
Auxiliary Feed-1/2 2-AFW-129 Exercising these valves full water System 1-AFW-129 or part-stroke during plant 2-AFW-130 operation would require 1-AFW-130 feeding hot steam generators 1-AFW-102 with cold feedwater thereby 2-AFW.102 thermally shocking the l_AFW-ll6 auxiliary feedwater ring within 2-AFW-ll6 the steam generator. Therefore 1-AFW-193 the valves are full stroke 2-AFW.193 exercised at Cold Shutdown at 1-ATW-199 3 month' intervals as allowed 2-AFW-199 by Section XI.
1-AFW-194 2-AFW-194 1-AFW-200 2-AFW-200 1-AFW-183 2-AFW-183 1-AFW-190 2-AFW-190 7
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. linit Yalva_tiumbar Jus 1111 cation Auxiliary Feed-1/2 1-MS-103 (shut)
Testing these valves during water System 1-MS-106 (shut) power operation requires 2-MS-103 (shut) filling the downstream pipe 2-MS-106 (shut) with water. Pump damage could occur if the pumps were started N
in this configuration.-
Therefore, the' valves are
' tested closed at Cold-Shutdowns only, as allowed by Section XI.
Auxiliary Feed-1/2 1-MS-108 Valves will be part-stroked water System 2_MS_108 quarterly during power 1-MS-110 operation and full stroked at 2-MS-110 Cold Shutdown as allowed by 1-MS_103 (open)
Section XI.
Full stroking 2-MS-103 (open) these valves during power 1-MS-106 (open) operation would require 2-MS-106 (open) feeding hot steam generators with cold feedwater thereby thermally shocking the AFW ring within the S/C.
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GENEEALQUESIl0NS_AND_C0tftdENIS s
8.
The NRC staff's position is that emergency diesel generators perform a safety-related function and therefore, the appropriate valves in the emergency diesel generator air start system should be included in the IST program and tested in accordance with the Code requirements.
Response
After further review of the NRC request, BC&E has evaluated that the Diesel Generator (DC) start system components should be excluded from the IST Program for the following reasons:
1 As discussed in Reg. Guide 1 26, this system does not fall within the secpe of-ASME XI.
2 The original design code utilized for this system te B31 1 BC&E's Responsible Design Organization has categorized the air start piping as ASME XI non-class.
3 BC&E shares the same concern as the NRC staff with regard to maintaining high reliability of our emergency DCs and their support systems. We feel that any anticipated improvement in reliability would be redundant with the attributes of BC&E's ongoing implementation of Reg. Guide 1.108.
A Reg. Guide 1.108 required tes program is incorporated into our emergency DC Surveillance Test program and is called "The Diesel Generator Reliability Program."
Reg. Guide 1.108 ensures that diesel electric power systems and components "perform satisfactorily and that the test program include operational tests during nuclear power plant operation." Our goal, and that of Reg. Guide 1.108, is to ensure that the diesel electric power systems meet their availability requirements.
BC&E also performs air start system preventive maintenance and performance evaluations to ensure continued reliability of the system.
Therefore BC&E proposes to test the IU cod associated support systems in accordance with Reg. Guide 1 108 and good maintenance practices, in lieu of any testing in accordance with ASME Section XI.
BC&E feels that no overall component or system benefit will be achieved by the additional cost of testing and recordkeeping per Section XI.
In addition, since the active components within the air-start system consist solely of solenoid valves and check valves, the testing required by Section XI will serve no purpose related to measuring equipment degradattor., since the testing of rapid-a-ting valves and check valves only assures component operability.
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GENEEA1._QUESIIDHS_AND Cot 2iENIS 9.
Identify the valves which are full-stroke exercised on a cold shutdown
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frequency and not partial-stroke exercised quarterly during power operation as required by Section XI, subsections IWV-3412 and 3522.
Response
Revised Appendix E (see Response to 1.A.6) details the apccific testing requirements committed to under Section XI guidelines for those valves not full-stroke tested during power operation.
Part-stroke testing of power-operated valves is generally not possible, due to valve logic circuitry which only allows full-open or full-closed valve movement. Moreover, the intent of Section XI is to assess valve operability through inservice testingt a part-stroke exercise does provide a reasonable measure of confidence in valve operability when full-stroke testing cannot be performed. However, a part-stroke of a power-operated valve has the possibility, through human or mechanical error, to cause adverse plant consequences (isolation of cooling water, plant transients, etc.) via an inadvertent full-stroke. Based on the above and the guidance stated by the NRC in the first-ten year interval (attached), Calvert Cliffs will full-stroke test power-operated valves in accordance with the Valve Test Program (with associated relief requests as appropriate).
Check valves whose safety function is to open will be full-stroked when possible. Since disk position is not always observable, the NRC staff has stated that "verification of the plant's safety analysis flow rate through the check valve would be an adequate demonstration of full-stroke requirement. Any flow rate less than safety analysis will be considered part-stroke exercising unless it is equivalent to or greater than the safety analysis flow rate through the valve."
Based on this position, check valves within the scope of this test program will be at least part-stroke exercised whenever any flow is passed through the valve. Check valves are considered to be full-stroke tested on at least the Code-required frequency unless identified by Relief Request. Check valves for which a full-stroke exercise can not be confirmed, therefore, will be l
identified by an appropriate relief request. Calvert Cliffs feels that this position meets the intent of IWV-3522(b) regarding exercising of check valves.
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GENERAL._QUESIIONSED_ Cote!ENIS STROKE TESTING OF MOTOR-OPERATED YALVES The licensee has requested relief from the part-stroke requirement of
-Section XI for all power-operated valves. The licensee has stated that none of the Category A or B power-operated valves identified can be part-stroked because of the design logic of the operating circuits. These circuits are such that when an open or close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction. We find that the above relief request from part-stroking is warranted because it is impractical to part-stroke and should be granted because the required function of the valves involves only full-open or full-closed positions. Therefore, we conclude that granting this relief does not endanger public health and safety.
- From Clark to Lundvall, Feb. 8. 1982 (First 10-Year Program Safety Evaluation Report) 8
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GENERAL _QUESIl0NS AND.COMMENIS 10.
Review the safety-related function of the spent fuel cooling system to determine if'it should be included in the IST program with the applicable system components tested in accordance with the requirements of Section XI.
Provide justification for those not included and tested per Section XI.
Response
The Spent Fuel Pool Cooling system performs no ASME Section XI safety function. The system design requires no Technical Specification ~to ensure design margins are maintained.
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GENERAL _QUESIIONS_AND_CQtt!ENIS 12.
What alternate testing has been considered for verifying that the remote position indication accurately reflects the actual valve position for the valves affected by valve relief request number A-27 Responsa:
CCNPP will verify the position of these solenoid operated valves in accordance with Code requirements, either during Local Leak Rate Testing or via system functional operation by observation of appropriate system parameters at least every two years. Relief Request A-2 will be withdrawn.
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C0tiIAINHEHI.YENIILAIIDH_SYSIIH 1.
Provide a more detailed technical justification for not full-stroke.
. exercising valves 1(2)-CV-1410. 1411, 1412, and 1413 on a cold shutdown frequency.
Responas:
See VS-1 (attached).
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CONIAlHHINI_YINIILAI1ON_SISIIH Unit 1 RELIEF REQUEST NUMBER YS-1
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t System:
Ventilation System PEID:
OH-63. SH 1 Valves:
1-CV-1410, 1-CV-1411, 1-CV-1412, 1-CV-1413 Category:
A-1 Class:
2-Function:
Containment Isolation Impractical Test Requirement: IWV-3400 requirement to stroke test the valves quarterly.
Basis for Relief:
These valves are passive, normally locked shut with power removed at all times except in Modes 5 or 6 In Mode 5 they perform no safety function. They do provide a safety function in Mode 6 It is not desirable to stroke test these valves during each cold shutdown since unnecessary stroking could damage the sealing surf aces of these valves, causing degradation of the valve's leak-tight capability. This would result in an unnecessary increase in testing and valve maintenance. At any time the valves are stroked, a leak test is performed to verify condition.-
Alternative Testing:
The valves will be full stroke tested in Mode 6 on a refueling frequency prior to any core alterations.
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REACIOR_C00LAHI_AND_WAIER_EROCESS_SAHELE_SISIEH i
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Provide a more detailed technical justification for not full-stroke-
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exercising valves 1(2)-SV-6529-quarterly.
Responsa:
See Response as in I.N.I.
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REACIOR_C00LAHI_SISIIti E
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Provide a more detailed technical justification for not full-stsoke exercising valves 1(2)-ERV-402 and 404 quarterly (see relief request No. RC-1).
(The reference to RC-7 in the actual staff question is a typographical error.)
Responant See Relief Request Number RC-1 Attached.
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REACIOLCOOLANLSISIEH RELIEF REQUEST NUMBER RC-1 System:
P&ID:
OH-72 Valves:
1-ERV-402, 404 Category:
C-1 Class:
1 Function:
Relieve reactor coolant pressure.
Impractical Test Requirement: Full stroke at cold shutdnen every quarter.
Basis For Relief:
These valves are categorized per Calvert Cliffs Technical Specifications as ASME Section XI Category C-Active (relief valve). However, due to the unique valve design, these valves cannot be tested per Iwv-3510. since the valves are actuated as the result of an electric signal from a pressure measurement device.
Alternative Testing:
Valves are tested per Technical Epecifications at refueling intervals. The test includas a channel calibration of the actuation channel. A channel functional test, excluding valve operation. is performed within 31 days prior to entering a condition when this l
valve is required to serve as an MPT relief, and every i
31 days thereafter when the valves are required to be operable.
In addition. these valves will be function-elly tested each cold shutdown prior to placing them in service for Low Temperature Overpressurization Protection.
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CHEMACAL_AND_YOLilME_CONIROL_SISIEM 2.
How are valves 1(2)-CVC-228 and 235 verified to full-stroke open during enld shutdownst Provide e more detailed technical justification for not full-c stroke exercising these valves quarterly (see cold shutdown justification).
3 Provide a more detailed technical justification for not full-stroke exercising valves 1(2)-MOV-501 quarterly (see cold shutdown justification).
8.
Review the safety-related function of valves 1(2)-MOV-504 (P&ID No. M-73.
Sh. 1, Coords. F-3) to determine if they should be included in the IST program and tested in accordance with the Code requirements. Provide justification if not included and tested per Code requirements.
9.
Review the safety-related function of valves 1(2)-CVC-257 (P&ID No. M-73.
Sh.1. Coords. F-3) to determine if they should be included in the IST program and tested in accordance with the Code requiremente.
Provide justification if not included and tested per Code requirements.
Response
2.
See the Response to question I.A.6 (Appendix E).
3 See the. Response to question I.A.6 (Appendix E).
8 and 9.
MOV-504 is a normally shut valve in the backup supply line f rom the Refueltag Water Tank (RWT). The check valve downstream is CVC-257. CCNPP Technien1 Specifications require a minimum of one Boric Acid Storage Tank (BAST) and the RWT or two BAST's.
however BC&E has evaluated that neither valve should be in the IST Program.
The small-break LOCA is the only Chapter 14 accident that credits the minimum inventory in a BAST: only the cooling effect of the water is l
credited. The accident does not credit boron reactivity effects. With maximum charging flow and minimun BAST level, the BAST empties after clad l
temperature has peaked. Therefore. charging pump suction from the RWT via MOV-504 is not needed. This means there is no safety function for these valves and they need not be tested.
This information was given to the NRC during a teleconference conducted on April 15, 1985. during a discussion of Technical Specification changes related to llPSI flow balance.
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SAEETI_I3.!ECIION_AND.CONIAINMENI_SERAI_SYSIEN 1.
Could full-stroke exercising valves 1(2)-SI-113. 123, 133. and 143 during cold shutdown result in a low temperature overpressurization of the reactor coolant system?
1 5
What are the consequences of failure of either valve 1(2)-HOV-659 or 660 in the closed position during quarterly testing? Would this render'an entire safety system unavailable to perform its safety function?
6 How are valves 1(2)-SI-4146 and 4147 verified to full-stroke open during cold shutdowns?
8.
Review the safety-related function of valves 1(2)-HOV-654 and 656 (P&ID No.
OH-74. Sh. 1. Coords. F-5 and D-5) to determine if they should be included in the IST program and tested to the Cod) requirements. Provide justification if not included and tested per Code requirements.
9.
What is the proposed test frequency for disassembly and inspection of valves 1(2)-SI-215, 225, 235. and 2457 (see valve relief request no. SI-3) 10 What is the proposed test frequency for disassembly and inspection of valves 1(2)-SI-217, 227, 237. and 247? There is an apparent typedraphical error in the basis for relief (see valve relief request no. SI-5).
11.
Provide a more detailed technical justification for not leak rate testing valves 1(2)-SI-217. 227, 237 and 247 in accordance with the Code requirements.
12 Provide a more detailed technical justification for not full-stroke exercising. valves 1(2)-CV-306 quarterly in accordance with Code requirements.
13 Provide the stroke time limit fer valves 1(2)-CV-306 17 i
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SAEIIY_IHJICI1ON_AND.CONIAINHENI_SERAY.SYSIIH I. L.
full-stroke Provide a more detailed technical justification for not exercising valves 1(2)-MOV-651 and 652 quarterly in accordance with the Code 14.
?
Do these valves perform a pressure boundary isolation requirements.Provide the stroke time limits for these valves.
function?
full-stroke Provide a more detailed technical justification for not exercising valves 1(2)-SI-313 and 323 quarterly in accordance with Code 15 Are these valves verified to full-stroke during cold shutdown requirements.
testing?
is the proposed test frequency for disassembly and inspection of valves 16 What 1(2)-?1-316, 326, 330, and 3407 (see valve relief request no. SI-1).
Provide the stroke time limits for valves 1(2)-CV-657 and 1(2)-MOV-658 18 Provide a more detailed technical justification for not full-stroke exercising valves 1(2)-SI-4148 and 4149 quarterly in accordance with the 20 is the proposed test frequency for disassembly and Code requirements. What inspection o'. these valves?
Eesponse:
1 See the attached Relief Request SI-A 1(2)HOV-659 and 660 will be tested at Cold Shutdowns, and a Justification 5
has been prepared (see Appendix E in question I. A.6).
See the attached Relief Request SI-B 6
These valves are passive and locked open during power operation, and Therefore, these 8
therefore have no safety function to change position.
valves need not be included in the IST Program.
the current NRC 9 and 10 Changes have been made to both SI-3 and SI-5 to reflect position on sample disassembly of check valves (see attached).
These valves are continuously monitored upstream by pressure instrumentation Operator actions, aided by the instrumentation, alarms, and 11 and alarms.
and correct leakage past these valves. No program l
procedures will detect "V" requirements were sent to CCNPP changes need be made. NOTE: No event via the April 20, 1981 NRC order.
See BC&E letter dated March 30. 1988 from Tiernan to Document Co 12 and 13 18
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l-I. 1.. S AE EII_lH.IICIlotLAN D_ CONI AlHH EHI_S ERAY_SYSI EH Provide a more detailed technical justification for not full-stroke exvreising valves 1(2)-H0V-651 and 652 quarterly in accordance with the Code 14.
3-Do these valves perform a pressure boundary isolation requirements.
function? Provide the stroke time limits for these valves.
full-stroke Provide a more detailed technical justification for not 15 exercising valves 1(2)-SI-313 and 323 quarterly in accordance with Code Are these valves verified to full-stroke during cold shutdown requirements.
testing?
frequency for disassembly and inspection of valves 16 What is the proposed test 1(2)-SI-316, 326. 330. and 3407 (see valve relief request no. SI-1).
Provide the stroke time limits for valves 1(2)-CV-657 and 1(2)-MOV-658 18 full-stroke Provide a more detailed technical justification for not exercising valves 1(2)-SI-4148 and 4149 quarterIy in accordance with the
- 20. -
Code requirements. What is the proposed test frequency for disassembly and inspection of these valves?
Eesponse:
1.
See the attached Relief Request SI-A 1(2)MOV-659 and 660 vill be tested at Cold shutdowns, and a Justification 5
has been prepared (see Appendix E in question I.A.6).
6 See the attached Relief Request SI-B These valves are passive and locked open during power operation, and Therefore, these 8
therefore have no safety function to change position.
^
valves need not be included in the IST Program.
the current NRC 9 and 10 Changes have been made to both SI-3 and SI-5 to reflect position on sample disassembly of check valves (see attached).
Th9se valves are continuously :onitored upstream by pressure instrumentation Operator actions, aided by the instrumentation, air.ms, and 11 and alarms.
and correct leakage past these valves. No program procedures, will detect "V" requirements were sent to CCNPP changes need be made. NOTE: No event via the April 20, 1981 NRC order.
See BC&E letter dated March 30, 1988 from Tiernan to Document Control.
12 and 13 18
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SAZITY IN.1ECI1Qtl AND CQtiIAINtiEMI_SEEAI_SISIElf Easponses Cont'd 14.
These valves are interlocked to remain shut on reactor pressure, and do provide PIV functioni changes will be mcde in the Test Program to reflect these updates. See Appendix E for cold shetdown justification. The stroke.
j times are based on actual valve times and will be incorporated in the test e
program (the stroke times are shown below).
Unit _1 Unit _2 X-MOV-651 108 109 X-MOV-652 102 108 1
NOTE: These stroke times are subject to change per ASME Section XI.
15 See attached Relief Request SI-6.
16.
See attached Relief Request SI-1.
18 The stroke times are shown below and will be incorporated in the IST Program.
b Unit _1 Unit _2 X-c.>657 60 (open) 79 (open) 121 (shut) 86 (shut)
X-CV-658 97 92 NOTE: These stroke times are subject to change per ASME Section XI.
p 20.
See attached Relief Request SI-2.
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L -._
S I. L.
$ AE E11.IN J EC110N _AN D.CDNI AINM ENI_S E RAI_ S IS T EM RELIEF REQUEST NiMBER SI-A
)
Safety Injection and Containment Spray System:
PkID:
OH-74. SH 1 Yalves:
1(2)-SI-113. 123, 133, and 143 Category:
C-1 Class:
2 Functions Injection check valves for HPSI Full stroke exercising per IWV-3520 Impractical Test Requirement:
Full stroke exercising these valves during power operation is Basis for Relief:
not possible. Mode 5 testing would greatly increase the probability of a Low Temperature Overpressurization Condition. Part-stroking these valves would require depressurization of the reactor coolant system, as well as causing unnecessary thermal cycling of SI lines. leading to equipment failure.
These valves will be full-stroke exercised in Mode 6 Alternative Testing:
during full-flow testing of SI.
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I SAEZII_IHlICI10N_AND_CONIAINHENI_SEKAI SISIEH I. L.
RELIEF REQUEST NUMBER SI.B
)
Esfety Injection ind Containment Spray Systes:
P&ID:
OH-74 SH 1 Valves:
1(2)-SI-4146 and 4147 Category:
C-1 Clasnt 2
Supply water from the RWT to Safety Injection Pumps Function:
Full stroke per IWV-3520 Impractical Test Requirement:
Full stroke exercising these valves requires simultaneous Basis for Relief:
actuation of all safety systems. Since separate discharge pathways do not exist for all systems, this is not possible.
These large diameter check valves will be part-stroked frequently (whenever an associated pump is run) but a full stroke is impossible.
One check valve of each pair will be disassembled and Alternative Testing:
inspected each refueling outage to verify operability if any problems are noted the remaining valve will be tested.
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,4 Unit 1/2
^
RELIEF REQUEST NUMBER SI-1 System:
Safety Injection and Containment Spray
)
P61D:
OH-74. SH3 t
Valves:
SI-316.. SI-326. SI-330. SI-340 Category:
AC-1 Class:
2 Function:
Containment Spray Header inlet checks, inside and outside containment isolation valves.
Impractical Test Requirements:
IWV-3520 requirement to exercise the valves once every 3 months.
Basis for Relief Check valves SI-316. SI-326. SI-330. and SI-340 cannot he stroked during operation without spraying large quantities of contaminated water into the containment.- This contaminated refueling pool water is also borated to approximately 2300 FPm.
Spraying the containment would result in a radioactive contamination cleanup problem and seriously damage components such as lagging reactor coolant pumps and control rod element assenbly coils.
Ore of these 8-inch check valves will be disassembled Alternative Testing:
and inspected during each refueling outages if any problems are found, all remaining valves will be inspected.
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e 1
linit 1/2 RELIEF REQUEST NUMBER SI-2
)
System:
Safety Injection and Containment Spray PEID:
OH-467. SH 3 Valves:
SI-4148. 51-4149 Category:
C-1 Class:
2 Function:
Containment Sump Outlet Check Valves Impractical Test Requirement: IWC-3520 requirement to exercise the valves once every 3 months.
Basis for Relief:
Cback valves cannot be full-str6ke exercised without flooding the containment floor with contaminated refueling pool water that is borated to approximately 2300 ppm. This would result in serious damage to lagging and electrical systems' control components in addition to the radioactive contamination cleanup problem of the containment sump and associated equipment.
These check valves are in the two 24" DIA rectre lines leading from the containment sump to the Safety Injection system pump suctions. To exercise these valves full-stroke would require a flooding of the containment building. Even if this were feasible exercising the valves every 3 months would require power entries to set-up the test and extensive reconfiguring of the HPSI. LPSI and CS pumps and piping to handle this large volume of contaminated water.
Alternative Testing:
One of these valves will be disassembled and ir.spected during each refueling outages if any problems are noted, all remaining valves wi21 be inspected.
b F
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e Unit 1/2 RELIEF REQUEST NUMBER SI-3 System:
Safety Injection PkID:
OH-74, SH 2 Valves:
1-SI-215, 1-SI-225, 1-SI-235, 1-SI-245 Category:
AC-1 Class:
1 Function:
-Safety Injection Tank discharge check valves, pressure system isolation valves.
Impractical Test Requirement: IWV-3520 requirement to full-stroke exercise valves.
Basis for kellef:
It is not possible to measure the flowrate through these valves nor to simulate rapid depressurization of the RCS.
Additionally, achieving the design flowrate through these valves would require removal of the reactor vessel head and the flowrate required could cause damage to the core-internals.
Alternative Testing:
One valve w!.11 be disassembled and inspected each refueling intervals if any problems are noted, all remaining valves will be inspected.
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't-o Unit 1/2 RELIEF REQUEST NUMBER SI-5 System:
Safety Injection PkID:
OH-74, Sil 2 h
Valves:
1-SI-217, 1-SI-227, 1-SI-237, 1-SI-247
?
Category:
A-1 Function:
Safety Injection to RCS loop check valves, pressure system isolation valves.
Impractical Tect Requirement:
IWV-3520 requirement to full-stroke exercise the valves.
Basis for Relief:
It is not possible to measure the flowrate through these valves nor to simulate rapid depressurization of the RCS during power operation. Additionally, achieving the analyzed design flowrate requires rcmoving the reactor vessel head and-the flowrate required could cause damage to the core internals.
Alternative Tasting:
One valve will be disassembled and inspected each refueling interval if any problems are noted, all remaining valves will be inspected. In addition, the valves are part-stroked whenever shutdown cooling is in operation during cold shutdoens.
(
9 25
_y I-o RELIEF REQUEST NUMBER SI-6
~ System:
Containment Spray for Both Units PEID:
M-74 & M-462 Valves:
1(2)-SI-313/323 Category:
C-1 Class:
2 Function:
Containment Spray Pump Check Valve Impractical Test Requirement:
IWV-3520 requires a check valve to be tested to its design flow position once a quarter.
Basis for Relief:
These valves cannot be full-flow stroke tested due to limitations on the bypass discharge flow paths.
It is not possible to test its normal flow path because this would result in spraying the containment with a contaminated boric acid solution. This would result in equipment damage and expensive radiological clean-up.
Alternative Requirements:
On a Cold Shutdown basis the valves will be part-stroke tested. One valve will be disassembled and inspected each refueling outages if any problems are noted, the remaining valve will be inspected.
Note:
BC&E is investigating two alternatives to disassembly. It may be possible on a Cold Shutdown basis to use two bypass flow paths to obtain full design flow. During the next refueling outage we plan to test these flow paths to determine if a successful full flow test can be conducted on a Cold Shutdown frequency. The second alternative is to measure the differential pressare across the valve at full - open stroke. We are currently looking into the instrumentation requirements and availability if this alternative is substituted for the discssembly.
26 v.
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I.N.
GAS _ ANALYZING _SISIElf
+
i 1.
Are the following valves ever opened during power operation? Provide a more detailed technical justification for not exercising these valves. quarterly during power operations.
1(2)-SV-6507A-C-1(2)..SV-6531 1(2)-SV-6540A-G
Response
These valves have been designated passive during power operation and the system provides no safety function except as Containment Isolation. '(All valves will be categorized " A-passive" which requires only a 10CFR50 Appendix J 1eak.
test at refueling, which is presently being performed.)
The system provides no required action to mitigate the consequences of an accident nor'is it needed to place the plant in cold shutdown following an accident. The NSSS Sampling System is our credited post-accident sampling system.
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4 I.O.
AUXILIARLEIEDWAIER_SISIEM 1
Do valves 1(2)-MS-103 and 106 perform a safety-related function in the closed position as well as the open position?
2.
How are valves 1(2)-MS-108 and 110 verified to full-stroke during quarterly testing?
Response
1.
These valves do provide a safety function in the closed direction. They will be tested to the closed position on a Cold Shutdown basis. (See Appendix E in Response to question _I.A.6).
2.
These valves will be part-stroked quarterly during operation and full-stroked at Cold Shutdown. (See Appendix E in Response to question I.A.6.)
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.Q II.
ElRIE_IESIING_EROGRAM 1.
The NRC staff's position is that the emergency diesel generators perform a
. safety-related function and therefore, the emergency diesel generator fuel oil transfer' pumps should be included in the IST program and tested in accordance with the Code requirements.
2.
Pump relief request number 2 is not required since there is no lubricant level or pressure to observe.
3 Provide a more detailed technical justification for not measuring inlet pressure for the salt water pumps 11, 12, 13, 21, 22 end 23 during quarterly pump testing in accordance with the Code requirements. How is differential pressure measured for these pumps?
4.
How is flow rate measured during quarterly testing of the salt water pumps 11, 12, 13, 21, 22 and 237 5
Are vibration measurements being taken at all required locations on salt water pumps 11, 12, 13, 21, 22, and 237
Response
1 BC&E has evaluated the DC Fuel Oil Transfer Pumps and has determined that they should be excluded from the IST Program for the following reasons:
Reg. Guide 1 26 does not assi.gn the DC Fuel Oil Transfer System a a.
quality classification commensurate with other safety-related components containing water, steam or radioactive material.
b.
Fuel Oil Transfer System piping. currently categorized by BC&E to be non= class per ASME Section XI.
We ensure Fuel Oil Transfer Pump and pump starting logic reliability by c.
the implementation of our DC Surveillance Testing Program as recommended in Reg. Guide 1 108. Transfer pump operability is proven via a minimum of one test per month. Performance reliability is proven by an annual test.
The annual test is four-to-eight-hour full load DC run.
2.
Relief Request No. 2 will be rep.isced by a note in the pump table of the IST Ptogram.
3 The Relief Request referencing inlet prernure will be replaced by a note in the pump Lables of the IST program.
lulet pressure is measured as feet of water abcve pump suction.
29
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EME_IESIlliG_EROGEAti
'i
'Rasponse Cont *d 4.
Saltwater pump'~ flow rate is measured ' quarterly by use of an annubar inserted in flow points downstream of the service water heat exchangers. The test loop established for the test is through the service water heat exchanger with all other parallel flow peths isolated.
5 Vibration measurements are taken on the pump inner (i.e., only) bearing at two locations 900 apart with the reading of highest deflection recorded.
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