ML20210E087
| ML20210E087 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/17/1986 |
| From: | Allen C COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20210E090 | List: |
| References | |
| 2048K, NUDOCS 8609220102 | |
| Download: ML20210E087 (13) | |
Text
/m') Commonwealth Edison l
i_. / 72 West Adams Street, Chicago. IUinois l Address Reply to-Post CFfice Box 76T
\\ v! Chicago, lilino:s 60690 0/67 A
September 17, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Unit 1 Pump and Valve Inservice Testing Plan NRC Docket No. 50-373 Reference (a): Letter dated May 27, 1986 from E. G. Adensan to D. L. Farrar.
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Dear Mr. Denton:
Reference (a) transmitted the results of your staff review of the LaSalle Unit 1 Pump and Valve Inservice Testing Plan.
Included in that tranasittal was a Safety Evaluation Summary which included findings regarding relief Commonwealth Edison (Ceco) requested from the testing requi.rements of ASME Section XI.
Also included was a Safety Evaluation Report, Ptzsp and Valve Testing Program, LaSalle Unit 1, Docket No. 50-373.
The Safety Evaluation Report and Summary have been reviewed and the findings evaluated for incorporation into the LaSalle Unit 1 IST Program.
The majority of the findings are being incorporated into the program es written. However, alternative methods of accomplishing the intent of the requirements are proposed for two of the findings and part of a third.
These proposals and discussion of why they were found to be impractical are addressed in the enclosure.
We would appreciate the opportunity to discuss any of these proposals at length with your staff.
Please direct any additional questions you may have regarding this matter to this office.
Very truly yours, C. M. Allen l
Nuclear Licensing Adninistrator
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Dr. A. Bournia - NRR Resident Inspector - LSCS 7
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FINDING 1:
i Relief has been grenM M.w treacu*tri;; only d(spbG5.cW. vibratico arplitude, as required by Aset 3t41$e UI, a'etEte !!!wMCE Md IWP-G OO f
for all ptmaps in the IST Program, however, tyi !!M Naa m fee!, that the IND Mechanalysis Limits proposed by lev 4h s,r te adepatt TC hkw.re PIoper corrective acticas are taken should ptmp de'y&4plu uct'.d a.ic. h3ve proposed alternate acceptance critartw, 4
The Technical Staff of Lat.Alle AIC/M dith CtWS 9.Y5ters Mafifial Arnlysis Department's (SMAD) Vibrat(c? f#;vy pq revie=vd
- die altericrie acceptance criteria proposed by the.WhC. For MSrdf.f M veloc; tty R&aMAnect limits along with other approaches to vibration testiny ont acoptare criteria.
As a result of this review, LaSalle Stat bm w>u12l lite t's proFOSe, as an alternative, that the vibration testing rec;uistist.ts given pi ANSI /ASMS OM-6i Draf t 8 be used in lieu of t. hose gina its ine Safety Evaluation Report (SER). The testing requiremente in tMr (knument were.
examined along with other testing methodology curr o tly J.n u p At other facilities. Based on the monitoring instruneatation n*;d punp inst 421ation at LaSalle, this methodology was selected as sos.t app W yritte for or configuration.
With this in view, Lasalle plans to rerulait Qa&C hy,vst EP-04, with all additional vibration monitoring requirewatt. of NMI/ &M /04; A
Draft 8 incorporated. The acceptance ranges for pose vibrat$cn will te implemented following NRC approval of the relief request.. A dr.af t of Relief Request RP-04 is provided as Attachment 1.
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FINDING 2f In the Safety Evaluation Report (Reference (a)) the etc denied relief as requested in Rp-05, and stated that the Diesel Oil systeminust be modified to meet ASMt Section XI testing requirements. Analysis of the system for modifications to provide instrumentation to meet ASME require-ments, determined that the test parameters can be measured with the existing configuration as indicated below. Therefore, the affected surveillance procedures will be revised to incorporate the necessary changes to meet ASME Section XI requiremente.
The following information is provided to describe how each of the test parameters will be measured or determined:
i Pump Inlet Pressure - This test parameter will be determined by converting the Diesel Fuel Oil Storage Tank (DFOST) level into a static pressure head in psig for the pump.
Pump Differential Pressure - This test paranter will be determined by recording the ptump discharge pressure and subtracting off the running inlet pressure. Ru..ning inlet pressure is calculated by subtracting the auction strainer differential pressure, when the pump is operating, froni the static pump inlet pressure. Calculations have determined that the friction head loss resulting from the approximate 8 foot section of suction piping is negligible.
Pump Flow Rate - This test parameter will be calculated using the Diesel Fuel Oil Day Tank level indicator as the flow rate quantity meter as permitted in IWP-4600, and converting the measured rate of change to flow rate in GPM.
In summary, relief from the requirements of ASME Section XI will not be requested and RP-05 will be deleted. An Inservice Test will be rtas on each Diesel puel Oil Transfer Pump to obtain new base line data for establishing new reference values, and applicable procedures will be revised to incorporate the additional test parameter measurements and acceptance ranges.
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FINDInto 3:
Based upon the NRC's position on rapid acting valves the only valves at LaSalle which fall into this category are solenoid valves. Therefore, Relief Request RV-02 will be revised to include only solenoid valves. A draft revised Relief Request RV-02 is included as Attachment 2.
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FINDING 4:
Per the Safety Evaluation Report, the IST Progran for Unit I will be revised to include the f;110 wing full-flow test valves: HPCS - IE22-F010,1E22-F011, IE22-F023; LPCS - 1E21-F012; RHR -
IE12-F021; RCIC - 1E51-F022 and 1ES1-F059 as Ilsted below.
V21ve l Site lP&lDlCoordl Class / l Valve lAct.l Valve l Test l Test lMaxStrokel Relief lActcrl Remarks No.
l lNo.l l Category l Type l Type lPos.l lSchd.l Time l Request l Passive l HPCS IE22-f010 10 95 D4 2/8 G8 M0 C
FS ST Q 165 A
Test Olscharge to PIT RR CST Upstrean Stop IE22-F011 10 95 D2 2/8 GB Mo C
FS,ST Q 165 A
Test Disccharge to PIT RR CST Downstream Stop 1E22-F023 12 95 C4 2/A GB M0 C
FS.ST Q 198 RV-19 A
full Flow Test to PIT,LT RR SP (See Notes 4,8)
LPCS 1E21-F012 14 94 c5 2/A G8 M0 C
FS,ST Q 231 RV-19 A
Full Flow Test to PIT,LT RR SP (See Note 4)
RHR IE12-F021 18 96-3 ES 2/A G8 NO C
FS,ST Q 297 RV-19 A C RAR Pump Full PIT,ti RR Flow Test Stop to SP (See Notes 4, 6,8)
RCIC IL51-F022 4 101-2 D6 2/8 G8 M0 C
FS,ST Q 66 A
Full Flow Test Up-PIT RR stream Stop IE51-F059 4 101-2 OS 2/8 G8 M0 C
FS ST Q 66 A
Full Flow Test PIT RR Downstrean Stop 2048K
I FINDING 5:
1.
Control Rod Drive Charging Water Header Check Valves CRD-115 The Control Rod Drive (CRD) systes provides high pressure charging water to the under piston area of the control rod drive mechanism to scram the reactor when required. If the charging water header pressure is lost, the individual scram accumulators provide a source of energy to perform the scram function. Check valves CRD-115 are located between the accumulators and the charging water header. These check valves maintain the accumulators pressurized following a loss of charging water pressure.
If a check valve leaks after charging water pressure is lost, the accumulator pressure could decrease below the pressure required to insert the control rod if the reactor pressure is insufficient to provide a source of high pressure water to accomplish the scram function (Startup ar.d Refueling modes).
There is a concern when the reactor vessel is at less than operating pressure (less than 950 psig), that the control rod drive accumulators do not maintain adequate pressure for a period of time compatible with operator action if no control Rod Drive Pump is operating (SSER #2, Section 4.6.2).
With reactor pressure greater then 950 psig, charging water pressure is not of concern because reactor prescure is sufficient to ensure adequate scran capability.
To ensure that sufficient high pressure water is available for a scram in the Startup and Refueling modes, a reactor trip (SCRAM) on low CRD discharge water header pressure has been designed and installed in Unit 1.
This provides for a Control Rod Drive Charging Water Header Low Pressure SCRAM with a trip setpoint of greater than or equal to 1267 psig (allowable value 1185 psig) with a time delay of less the 1 or equal to 10 seconds. This scram will be automatically bypassed when the reactor mode switch is in other than the startup or Refuel positions (Operational Conditions 2 and 5).
The Technical Specification surveillance requirement 4.1.3.5 b.2 to " measure and record the time I
that each individual accumulator check valve maintains the associated accumulator pressure above the alarm setpoint with no control rod drive pump operating" ir no longer required because the worst case leakage rate of the accumulator check valves still provider sufficient pressure to insert the control rods with the charging water header low pressure scram in effect.
Based on NRR review and acceptance of this Technical Specification change, we believe that these valves are not required to be tested and l
do not need to be added to the IST program as category "C" valves. The technical Specification change is described in a letter dated February 4, 1986 from EG Adensam to DL Farrar transmitting Amendment 33 to NPF-11 (Attachment 3).
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2.
Control Rod Drive Charging Water Header Check Valves CRD-138 The control rod drive cooling weter header checic valves CRD-138 are already functional tested as F rt n' the 10 CFR 50 Appendix J Type A test in that during the test the :. J nystem is in its post-accident condition (screamed condition witn the pumps off). With the CitD system ir. this condition any ler.kage via this pathway w>uld be' included in the Type A test results. This testing method meets the requirements of Section 3.1.4 of the SER to test the valves; however, it is impractical to meet the IST requirement es we cannot quantify the leakage via this path or assign the leakage to a particular valve. Therefore, we meet the intent of the SER, but tind it. impractical to record the data required to meet ASME Section Yr.
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This relief request has been deleted frra the IST Program.
"As-Pound" relief valve setpoints are verified, and action is taken in accordance with ASME Section XI. Article IW-3513, and IW--3514.
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A FINDING 7:
REFERENCES:
A)
UFSAR Table 6.2-21 B)
NURBG 0519 LaSalle County Station SER The 10 CFR 50 Appendix J program has been previously reviewed and approved in reference (B). The listing of containment isolation valves and their classification is documented in reference (A). This program is describad in the Technical Specifications section 3.6.1.2 and Table 3.6.3-1.
In this SER the Staff identified several valves which were 61ther not included in the IST program or if they were included were not categorized as A or A/C as appropriate.
The following action or justification is provided with regards to correctly categorizing these valves in the IST Program.
Valve Number (s)
Action IE22-F023 These valves will be added to the 1E21-F012 program as category A.
1E12-F021 IIN100 These valves are category B valves IIN101 por reference (A) and not included in i
Tech Spec Table 3.6.3-1, and will be i
added to the program as such. Refer to note 38 of Reference (A)(Attachment 4).
ICM004 These valves will be added to the ICM012 program as excess flow check valves, category A/C. Refer to Reference (A) footnote 32 (Attachment 4).
1CM022A These valves are not category A valves, 1CM024A and are presently in the program as 1CM025A category B.
Refer to reference (A)
ICM021B note 40 and Tech Spec Table 3.6.3-1 1CM0238 footnote (H). In reference (A) valve ICM026B 1CM021B "Through Line Leakage" classi-fication is a typo and will be corrected in the next update of the UFSAR.
1E12-F099A These valves will be added to the 1E12-F099B program as category A.
However, they are not leak tested in accordance with Appendix J.
Refer to Technical Speci-fication Table 3.6.3-1 footnote (g).
The IST Program for Unit I will be revised as follows:
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FINDING: 7 (Continued)
Valve l Size lP&lDlCoordl Class / l Valve lAct.l Valve l Test l Test l Max Stroke l Relief lAct or l Remarks No.
l lNo.l l Category l Type l Type lPos.l lSchd.l Time l Request l Passive l CM ICM004
.75 92-2 83 2/ A/C EFC 0
E.LT RR RV-34 A
LP Excess Flow (See Note 9)
ICM012
.75 92-2 C6 2/ A/C EFC 0
E LT RR RV-34 A
LP Excess Flow (See Note 9)
IN N100 1 66-7 C7 2/8 G8 50 0
RV-02 A ~ South Side N2 to DW PIT,FST RR RV-12 Isolation IIN101 1 66-7 C6 2/8 G8 S0 0
RV-02 A
North Side N2 to DW PIT,FST RR RV-12 Isolation HPCS 1E22-F023 12 95 C4 2/A G8 M0 C
FS ST Q 198 RV-19 A
Full Flow Test to PIT,LT RR SP (See Notes 4,8)
LPCS 1E21-F012 14 94 C5 2/A G8 M0 C
FS.ST Q 231 RV-19 A
Full Flow Test to PIT,LT RR SP (See Note 4)
RHR 2-F021 18 %-3 ES 2/A G8 MD C
FS ST Q 297 RV-19 A
C RHR Pisap Full PIT,LT RR Flow Test Stop to SP (See Notes 4, 6,8)
IE12-F099A 2 %-1 C7 1/A G8 M0 C
RHR S/D Cooling PIT,LT RR Loop Testable CK Bypass Stop (See Notes 1,5)(M-8) 1E12-F0998 2 %-2 C7 1/A G8 M0 C
RHR S/D Cooling PIT,LT RR Loop Testable CK Bypass Stop (See Notes 1,5)(M-9) 2048K
ATTACMENT 1 Relief Request:
RP-04 (Draft 1)
Affected Component (s):
Component EPN Class / Category Function Al? Puers N/A N/A ASME Section XI Test Requirement:
IWP-3100 Inservice Test Procedure; IWP-4500 Vibration - For measuring vibration amplitude.
Basis for Relief:
Relief is requested from the requirements of measuring vibration amplitude. A far more informative reading is obtained using vibration velocity equipment because it accounts for both displacement and rate of frequency. Therefore, it is more advantageous to measure vibration velocity than vibration amplitude displacement for determining the mechanical condition of a pump.
Alternative Testing:
The alternative testing described herein for pump vibration monitoring was developed using ANSI /ASME OM-6 (Draft 8) as a guideline, with the intent of incorporating into the program any additional vibration testing requirements of OM-6 to those found in ASME Section XI.
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Pump vibration measurements are obtained and recorded in velocity (inches per second), and are broadband (unfiltered) Peak readings. All monitored locations are clearly marked to identify the specific point at which the transducer is to be placed while taking vibration measurements using portable equipment. The readout system and transducers used to take vibration measurements are capable of frequency response in the range of one-third minimum pump speed to at least one-thousand hertz, and they meet the minimum accuracy requirement ever that range of +/-5%.
t All centrifugal pumps in the program will have vibration measurements taken in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each accessible pump bearing housing.
Measurement will also be taken in the axial direction on all bearing housings when accessible. Reciprocating pumps will have vibration measurements taken approximately perpendicular to,the crankshaft and the line of plunger travel, including the axial direction when accessible on each pump bearing housing.
The acceptable, alert, and required action ranges of ANSI /ASME OM-6 (Draft 8), Table 6100-1 will be used in lieu of Table 3100-1 of Section XI as shown below. Corrective actions will be taken in accordance with article IW-3230.
Ranges of Vibration Pump Alert Range Required Action Range Type Low High centrifugal 2.5V(ref) 6V(ref) 6V(ref)
But not> 0.325 in/sec But not> 0.~10 in/sec.
Reciprocating 2.5V(ref) 6V(ref) 6V(ref)
Notes 1: V (ref) is the reference velocity in inches per second.
2: Any vibration measurement value below the low alert range is acceptable.
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ATTACMENT 2 Relief Request:
RV-02 Affected Component (s):
Component EPN Class / Category Punction All solenoid valves required 2/A & B Various
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to be stroke time tested, and normally stroking in less than 2 seconds.
ASME SECT XI Test Requirement:
Set alert range limits in accordance with subarticle IWV-3417(a).
Basis for Relief:
Setting the alert range in accordance with IWV-3417(a) for solenoid valves which stroke in less than 2 seconds, will many times lead to increased frequency testing and/or possible maintenance activities when these actions are not reasonably warranted. This is due to the relatively larger error introduced when timing the stroke of these rapid-acting valves., Therefore, relief is requested from the 50% increased frequency testing requirement'of IWV-3417(a) for solenoid valves which normally stroke in less than 2 seconds.
Alternative Testing:
Set the alert range for solenoid valves at 2 seconds. When the stroke time exceeds 2 seconds they will be put on monthly testing until corrective action can be taken in accordance with IWV-3417. The stroke times of these valves will not be included in the Trend Analysis Program.
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