ML20153G200

Forwards Revised Format for Relief Requests VO6,PO3 & PO9 to Pump & Valve Inservice Testing Program,Per 880429 Telcon Request

ML20153G200
Person / Time
Site:	Callaway
Issue date:	05/05/1988
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ULNRC-1769, NUDOCS 8805110167
Download: ML20153G200 (6)

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filhzrcine i JEDicirc:aritic: l issa 1901 Gratet Street, St. Louis Donald F. Schnell May 5, 1988 Vce Fresident U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 ULNRC-1769 Gentlemen:

o DOCKET NUMBER 50-483 CALLAWAY PLANT CALLAWAY PUMP AND VALVE INSERVICE TESTING PROGRAM

Reference:

ULNRC-1756, dated April 12, 1988 The referenced letter submitted updates to the Callaway Pump and Valve Inservice Testing (IST) Program. Included as an attachment to this letter are relief requests V06, P03, and PO9 which are being resubmitted in a revised format. These changes were requested by the NRC in an April 29, 1988 telephone conversation. Revision bars in the margin denote the areas of change.

If you have any questions regarding this letter, please contact us.

Very truly yours, j .Jn

• L Donal F. Schnell WEK/kea Attachment 88051'0167 880505 DR ADOCK 0500 g }

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1 Marhng Address: P.O Box 149. St. Louts. MO 63166 \

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1 cc: Gerald Charnoff, Esq. .

Shaw, Pittman, Potts & Trowbridge l 2300 N. Street, N.W. l Washington, D.C. 20037 1

Dr. J. O. Cermak CFA, Inc. ,

4 Professional Drive (Suite 110) l Gaithersburg, MD 20879 W. L. Forney Chief, Reactor Project Branch 1 l

U.S. Nuclear Regulatory Commission Region III l 799 Roosevelt Road Glen Ellyn, Illinois 60137 j l

Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 I l

Tom Alexion (2)

Office of Nuclear Reactor Regulation U.S. Muclear Regulatory Commission Mail Stop 316 7920 11orfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 l

Jefferson City, MO 65102 4

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SThTE OF MISSOURI ) l

) SS l CITY OF ST. LOUIS )

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Robert J..Schukai, of' lawful' age,'being first duly:cworn .!

upon oath says that.he is General Manager-Engineering (Nuclear) for l Union Electric Company; that he has read the foregoing document and _

l knows the content thereof; that he has executed the same for and on '

behalf of~said company with full power and authority to do so; and

-that the facts therein stated are true and correct to the best of his l

, knowledge, information and belief.

By Rober rJ.' Schukai Generh anager-Engineering Nuclear SUBSCRIBED and sworn to before me this 8 day of ,198[ l a

l BARGAfMDFA F '!

60TARY PUBUO, STATE Of MISSOURI MY COMMISSION EXPIRES april 22, 1987 ST. LOUIS COUNTY l

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'l RELIEF REQUEST # V06 VALVE: BB-PCV-0455A, -0456A CATEGORY: A CLASS: 1 TEST REQUIREMENT: ASME Section XI IWV-3417(a) corrective action shall be

, applied to all power operated valves.

BASIS FOR RELIEF: The trending. requirements of IWV-3417(a) specifies that valve test frequencies shall be increased to monthly for valves with stroke times 10 seconds or less when stroke times increase by 50%. Valves normally stroking rapid'.y can increase by 50% and show a relatively small numerical stroke time increase, thereby not_ indicating degradation.

ALTERNATE TESTING: Power operated valves with maximum stroke times of 2 seconds will be exempted from the corrective action and trending requirements of Section XI IWV-3417(a). A limiting stroke time of 2 seconds will be' assigned to these valves. Valves exceeding this limit will be corrected in accordance with IWV 3417(b).

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RELIEF REQUEST # P03 SYSTEM: Chemical and Volume Control System COMPONENT: PBGOSA and PBG05B CLASS: 2 /

FUNCTION: To provide high head safety injection to the reactor.

TEST REQUIREMENT: The resistance of the system shall be varied unE11 either the measured differential pressure or the measured flowrate equals the corresponding reference value.

, BASIS FOR RELIEF: Technical Specification 4.5.2.f.1 states "Each ECCS Subsystem shall be demonstrated OPERABLE by verifying that each centrifugal charging pump develops a discharge pressure greater than or equal'to 2390 psig on recirculation flow when tested persuant to Specification 4.0.5." Testing of these pumps is performed on the fixed resistance mini-flow path ( 2500 psid.

60 gpm). At this flow rate, the pump curve for these pumps is relatively flat ( 25 psid/60 gpm). Flow rate l changes of 50% would result in less than 1% change in pump differentini pressure. Based on this, we do not feel it is warranted to install additional instrumentation to ensure flow is maintained at the same point (12% accuracy) i for each quarterly test. Adequate flow is verified for protection of the puups by monitoring discharge pipe temperature changes. To further verify pump performance and monitor degradation, we will run an additional test, on a refueling freruency, s at or above the design flow point for the pumpu and monitor pump flowrate, differential pressare, and vibration. The flow measurement to be performed during these outages will be done utilizing an alternate flow path which is only available during cutage conditions and has installed flow instrumentation. This flow instrumentation meets the requirements of ASME Section XI Subsection IWP.

ALTERNATE TESTING: Pump differential pressure and vibration will.be measured and trended quarterly. A second set of reference values will be established at or above the pumps' design flow point ( 462 gpm). Pump differential pressure, flowrate, l and vibration wil' be measured on a refueling frequency and trended againet this second set of reference values.

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RELIEF REQUEST # P09 l SYSTEM: Chemical and Volume Control System l

COMPONENT: PBG02A and PBG02B CLASS: 3 9

FUNCTION: To provide emergency boration.

TEST REQUIREMENT: The resistance of the system.shall be varied until either the measured differential pressure or the measured flowrate equais the corresponding reference value.

BASIS FOR RELIEF: Quarterly testing of these pumps if performed on the fixed resistance mini-flow path ( 112 psid, 15 gpm). At this l flowrate, the pump curve for these pumps is relatively flat (8 psid/42 gpm). 'Flowrate changes of 225% would result in less than a 1% change in pump differential pressure. Based on this, we do not feel it is warranted to install additional instrumentation to ensure flow is maintained at the same point (22% accuracy) for each quarterly test. Adequate flow is verified for protection of the pumps by monitoring discharge pipe temperature changes. To further verify pump performance and monitor degradation, we will run an additional test, on a cold shutdown frequency, at or above the design flow point for the pumps and monitor pump differential pressure, flowrate, and vibration. The flow measurement to be performed during these outages will be done utilizing an alternate flow path which is only available during outage conditions and has installed flow instrumentation. This flow instrumentation meets the requirements of ASME Section XI Subsection IWP.

ALTERNATE TESTING: Pump differential pressure and vibration will be measured and trended quarterly. A second set of reference values will be established at or above the pump design flow point

( 75 gpm). Pump differential pressure, flowrate, and l  ;

vibration will be measured on a cold shutdown frequency i and trended against this second set of reference values. l

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