ML20211N713
| ML20211N713 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/27/1986 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton, Lear G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20211N715 | List: |
| References | |
| CON-NRC-86-56 VNPNPD-86-279, VPNPD-86-279, NUDOCS 8607030199 | |
| Download: ML20211N713 (12) | |
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MSC00 Sin Electnc eom cown 231 W. MICHIGAN, P.o. BOX 2046, MILWAUKEE.W153201 (414)277-2345 June 27, 1986 VPNPD-86-279 NRC-86-56 e
Mr. H. R. Denton Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, DC 20555 Attention:
Mr. George Lear, Director PWR Project Directorate No. 1 Gentlemen:
DOCKET NOS.50-266 & 50-301 INSERVICE TESTING PROGRAMS FOR PUMPS AND VALVES POINT BEACH NUCLEAR PLANT, UNITS 1 & 2 On January 16, 1984, Wisconsin Electric submitted the second ten-year interim pump and valve inservice testing (IST) program for PBNP Units 1 & 2 to the NRC for review.
Revi-rions to the IST program were subsequently submitted to the NRC for review in our letters dated March 28, 1985, August 26, 1985, and November 12, 1985.
An additional relief request concerning pump vibration measurements was submitted for NRC review and approval together with the March, 28, 1985 revision to the IST program.
In a letter dated June 11, 1985, Wisconsin Electric was granted permission to delay implementation of the PBNP IST program until August 1, 1985.
At that time we were directed to have implemented the proposed IST program submitted on March 28, 1985, with the exception of Pump Relief Request No.
9 concerning pump vibration measurements.
As stated in your letter, we were also required to comply with the more restric-tive requirements of the Technical Specifications and the IST program.
By letter dated August 26, 1985, we informed you that the IST program in our March 28, 1985 letter had been implemented with the exception of Pump Relief Request No. 9.
We also informed you that we were investigating methods to stroke test the main feedwater check valves and would be conducting a review of pump test instrumentation for compliance with the
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requirements of Article IWP 4100 of ASME Section XI.
Wisconsin Electric committed to providing the NRC with our plans regarding main feedwater check valve testing and pump test gQq instrumentation by June 30, 1986.
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Mr. George Lear June 27, 1986 Page 2 We have determined that testing the main feedwater check valves strictly in accordance with ASME XI is not practical.
It is not possible, within the existing plant design, to verify individual check valse closure upon cessation or reversal of flow.
There are two main feedwater check valves in series to each steam generator with no instrumentation taps between the valves.
There are no position indicators on individual valves.
It is, therefore, not possible, through direct or indirect measurements, to verify individual valve closure.
We propose as an alternative test to verify, once each refueling outage, that at least one of the two series check valves is closed.
This will be accomplished by measuring the differential pressure across, or leakage past, the i
series combination of check valves.
We also propose to open and inspect the accessible internals of each main feedwater check valve once every ten years.
Valve Relief Request No. 21 is included in this submittal providing details on the basis for this relief and the proposed alternate testing requirements for the main feedwater check valves.
In our review of pump test instrumentation, we have determined that the accuracy and range requirements for pressure, differen-tial pressure, and flow instruments, as specified in Article-IWP 4100 of ASME XI, in most cases can be met with existing station instrumentation.
Attachment A provides a summary listing of the ranges and accuracies of instrumentation used for pump testing at Point Beach.
As can be seen, the majority of the instrumentation is well within 16% accuracy at their reference values as suggested by the instrument accuracy and range guidelines of Articles IWP 4110 and 4120 respectively.
We believe that the intent of the requirements in Article IWP 4110 and 4120 of ASME XI is to ensure that recorded test parameters are accurate within certain bounds.
It is our position that installed station instrumentation that will provide measurements accurate to 19%, at the reference value, is adequate for pump testing.
Any instrumentation that will not allow measurement of a pump test parameter to an accuracy l
of i9% or better will be replaced or supplemented by other, more i
accurate instrumentation.
This accuracy at the reference value corresponds to an instrument accuracy of 13% of full scale and a range less than or equal to 3. times the reference value.
For those pressure, differential pressure, and flow instruments where the reference value can be read to 19% of the reference value, we plan no corrective action.
The maximum error in the discharge pressure and the differential pressure measurements for the residual heat removal pumps are in excess of i9% at their respective reference values.
The residual heat removal pumps discharge pressure instruments will be replaced or supplemented with more accurate instrumentation so as to meet the requirements i
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Mr. George Lear June 27, 1986 Page 3 of Articles IWP 4110 and 4120 of ASME XI. This will be accomplished by_ January 9, 1987 for Unit 2 and June 30, 1987 for Unit 1.
Pump Relief Request No. 10, enclosed, provides the basis and alternative requirements WE is proposing for pressure, differential prescure, and flow instrumentation.
The portable vibration test instruments currently in use at PBNP do not meet the accuracy requirements of Article IWP 4110 of ASME XI.
The instruments currently used are multiscale instruments which are calibrated to 110% of the reading from 0-5 mils.
These instruments will be replaced with wide band vibration velocity instruments of suitable range and accuracy when Pump Relief Request No. 9 has been approved by the NRC.
Enclosed you will find 5 copies of the current revision of the PBNP pump and valve program for your review.
This program replaces, in its entirety, any previous revision provided to you.
As Ydiscussed above, Valve Relief Request No. 21 and Pump Relief Request No. 10 are included in the program for your review and approval.
A summary of all changes to the program since our last submittal in our November 12, 1985 letter has been provided as Attachment B.
We submitted Pump Relief Request No. 9 concerning pump vibration measurements to you for review and approval in our March 28, 1985, letter.
We are still awaiting your response on this relief request.
It is our opinion that use of vibration velocity measurements is superior to the use of vibration displacement measurements for determination of machinery condition.
Use of velocity measurements is a widely accepted industry practice for evaluating the condition of rotating machinery and predicting component failures for machinery operating at speeds greater than 600 rpm.
Use of displacement measurements is normally recommended for machinery which operates at less than 600 rpm.
All of the pumps in the PBNP pump and valve test program operate somewhere between 1200 and 3600-rpm, well above the 600 rpm range.
We request that you give further consideration to granting Pump Relief Request No.
9.
As you know, Wisconsin Electric filed License Amendment Request Nos. 42 and 58 on February 17, 1977 and Novonber 27, 1978 for Point Beach Nuclear Plant, Units 1 and 2 respectively, for Technical Specification changes necessitated by the revised' inservice testing requirements, as required by 10 CFR 50.55a.
To date, only certain portions of these proposed amendments have been reviewed and approved by the NRC.
Next year, an entire decade will have passed for the Unit 1 submittal without any resolution of these items.
It is our understanding from conversations with our NRC i
Project Manager that these amendments will be issued before the end of the year.
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Mr. George Lear June 27, 1986 Page 4 The proposed Technical Specification changes are in agreement with these revised programs and approval should be expedited.
As we have previously stated, it is our position that approval of these outstanding Technical Specification change requests should have been completed prior to implementation of the new IST programs.
However, pursuant to your order transmitted by letter dated June 11, 1985, the subject inservice testing programs were imple-mented in conjunction with the existing Technical Specification testing requirements.
We nonetheless request your prompt approval of these long outstanding license amendment requests.
Should you have any questions regarding the attached programs or require additional clarification or details, please contact us.
Very truly yours, gb h
Vice President-Nuclear Power C. W.
Fay Enclosures Copy to NRC Resident Inspector
Page 1 ATTACHMENT A Accuracy As Range Accuracy as Percent of Parameter of Percent of Reference 4 Range Reference Pump Measured Instrument Full Scale Value Ref Value Value Safety Injection Pumps, PISA, B
' Monthly Test Discharge 0-2000 psi 3%
1560 psi 1.3 3.8%
Pressure RWST Level 0-100%
3%
98%
1.0 3.1%
Inlet 0-29 psis 3.1%
28.4 psi 1.0 3.1%
Pressure.
Calculated 1 Differential. Calculated 1532 psi NA 3.8%
Pressure Refueling Discharge 0-2000 psi 3%
1280 psi 1.6 4.7%
Pressure RWST Level 0-100%
3%
66%
1.5 4.5%
Inlet 0-29 psi 5 3.1%
19 psi 1.5 4.6%
Pressure Calculated 2 Differential Calculated 1261 psi NA 4.7%
Pressure Flow 0-1500 gpm 3%
645 gpm 2.3 7.0%2 I
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Page 2 ATTACHMENT A Accuracy As Range Accuracy as Percent of Parameter of Percent of Reference 4 Range Reference Pump Measured Instrument Full Scale Value Ref Value Value Rssidual Heat
'Rcmoval Pumps, P10A, B Monthly Tect Discharge 0-600 psi 3%
182 psi 3.3 9.9% 2 s Pressure Inlet 0-60 psi 2%
30 psi 2.0 4.0%
Pressure 152 psi NA 11.9% 2 3 2 Differential Calculated Pressure Rafueling Test Discharge 0-600 psi 3%
152 psi 3.9 11.8% 2 s Pressure Inlet 0-60 psi 2%
21.6 psi 2.8 5.6%
Pressure 130 psi NA 13.9% 2 s 1 Differential Calculated Pressure Flow 0-4000 gpm 3%
1560 gpm 2.6 7.7% 2
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Page 3 ATTACHMENT A Accuracy As Range Accuracy as Percent of Parameter of Percent of Reference 4 Range Reference Pump Measured Instrument Full Scale Value Ref Value Value Containment Spray Pumps, P14A, B Monthly Test Discharge 0-600 psi 2%
269 psi 2.23 4.5%
' Pressure RWST Level 0-100%
3%
98%
1.0 3.1%
Inlet.
0-29 psis 3.1%
28.4 psi 1.0 3.1%
Pressure
. Calculated 1 Differential -Calculated 240 psi NA 5.0%
Pressure i
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Page 4 ATTACHMENT A Accuracy As Range Accuracy as Percent of 4
Parameter of Percent of Reference -
Range Reference Pump Measured Instrument Full Scale Value Ref Value Value Stcam-Driven Auxiliary Feed Pump, P29 Monthly Test Discharge 0-1600 psi 3%
1380 psi 1.1 3.5%
Pressure Inlet 0-30 psi 2%
14 psi 2.1 4.3%
Pressure 1366 psi NA 3.5%
1 Differential Calculated Pressure Refueling Test Discharge 0-1500 psi 2%
1290 psi 1.2 2.3%
Pressure Inlet 0-30 psi 2%
10 psi 3.0 6.0%
Pressure 1280 psi NA 2.3%
2 Differential Calculated Pressure Flow 0-400 gpm 3%
390 gpm 1.0 3.1%
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Page 5 ATTACHMENT A Accuracy As Range Accuracy as Percent of Parameter of Percent of Reference 4 Range Reference Pump Measured Instrument Full Scale Value Ref Value Value Motor-Driven Auxiliary Feed Pump, P38A, B Monthly Test Discharge 0-1600 psi 3%
1310 psi 1.2 3.7%
Pressure Inlet 0-30 psi 2%
16 psi 1.9 3.8%
Pressure 1 Differential Calculated 1294 psi NA 3.7%
Pressure R3 fueling. Test Discharge 0-1500 psi 2%
1170 psi 1.3 2.6%
Pressure Inlet 0-30 psi 2%
11.2 psi 2.7 5.4%
Pressure 2 Differential Calculated 1159 psi NA 2.6%
Pressure Flow 0-200 gpm 3%
198 gpm 1.0 3.0%
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Page 6 ATTACHMENT A Accuracy As Range Accuracy as Percent of Parameter of Percent of Reference 4 Range Reference Pump Measured Ins?.rument Full Scale Value Ref Value Value Sorvice Water P32A,B,C,D,E,F Monthly Test Discharge 0-1SO psi 13%
6S psi 2.3 6.9% 2 Pressure NOTE 1:
DIFFERENTIAL PRESSURE = DISCHARGE PRESSURE - SUCTION PRESSURE.
NOTE 2:
INSTRUMENTS THAT HAVE A TOTAL INSTRUMENT ERROR IN EXCESS OF 16% AT THE REFERENCE VALVE.
NOTE 3:
INSTRUMENTATION THAT DOES NOT MEET THE MINIMUM REQUIREMENTS OF PRR-10. (PROPOSED PBNP REQUIREMENTS)
THESE WILL BE REPLACED.
NOTE 4:. THE REFERENCE VALVES USED ARE REPRESENTATIVE OF TYPICAL REFERENCE VALUES FOR EACH GROUP OF PUMPS.
NOTE S:
SUCTION PRESSURE IS OBTAINED BY MEASURING RWST LEVEL AND CONVERTING 'IHE RWST STATIC HEAD AT THE PUMP SUCTION TO SUCTION PRESSURE.
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Page 1 ATTACHMENT B Section Change All Sections Changed valve position namencla-ture in IST plan to correspond with standard verbage.
Changed
" closed" to " shut" and "C" to "S"
throughout the plan.
2.7.2.15 Correct typographical error.
Valve Tables Changed the frequency of testing-4 U1, Page 17 of valve 1713 from RR to OP to U2, Page 17 reflect actual testing being -
conducted.
VRR-14 Delete relief request since valve 1713 will be tested on a quarterly basis while in service.
Valve Tables Change the category and type for U1, Page 18 valves 2017 and 2018.
Change the j
U2, Page 18 category from "C" to "B" and the type from "CK" to "SCK."
These valves are not self-actuating and cannot be considered check valves.
Valve Tables
. Change the category and test type U1, Page 19 for valves 2019 and 2020. Changed U2, Page 19 the category from "C" to "B" and test type from CVT to BT.
These valves are not check valves, but power-operated valves.
l Valve Tables Valve ICLand 2C from service air U1, Page 28 for Unit 1 & 2 respectively were U2, Page 24 listed on the wrong unit's tables (i.e., Unit 1 valve on Unit 2 table and vice versa).
Tables were. corrected.
Note 9 was deleted since it did not apply to valves lc and 2C.
Valve Tables Add valves 6 and 7 to the tables U1, Page 36 for the PACVS.
These valves will U2, Page 30 be leak tested in accordance with j
Appendix J..
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Page 2 ATTACHMENT B e
Valve Tables Valve 808 and 809 were renumbered U2, Page 26 to 286 and 287 respectively to reflect the correct valve ID nos.
Valve Tables Change the maximum stroke time of Ul, Page 22 2838 and 2839 to 10 sec.
The previous entry (4.5 sec) was a typographical error.
Deleted relief request VRR-0 from relief request column.
These valves are not fast acting valves.
Valve Tables Change the frequency of testing U1, Page 33 of valves 466A&B (Unit 1) and.
U2, Page 29 476A&B (Unit 2) from "CS" to "RR."
Add VRR-21 to Relief Request columns for 466A&B (Unit 1) and 476A&B (Unit 2)
VRR-21 Added relief request for main feedwater check valve testing Pump Tables Added Pump Relief Request No. 10 to the relief request blocks for all pumps PRR-10 Added relief request for pump test instrumentation accuracy and range requirements.
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