ML20216J794

Informs of Review Being Conducted of Second 10-yr Interval Inservice Testing Program & Associated Requests for Relief for Facility,Submitted on 971201.Response to Encl RAI Requested within 60 Days

ML20216J794
Person / Time
Site:	Waterford
Issue date:	04/15/1998
From:	Chandu Patel NRC (Affiliation Not Assigned)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
TAC-MA0264, TAC-MA264, NUDOCS 9804210491
Download: ML20216J794 (5)

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Mr. Charles M. Dugger April 15, '1998 i Vice President Operatums'

- Entern Operations, Inc.

P. O. Box B Killona, LA 70066 l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE -

WATERFORD 3 SECOND 10-YEAR INTERVAL INSERVICE TESTING l PROGRAM AND ASSOCIATED REQUESTS FOR RELIEF (TAC NO. MA0264)

Dear Mr. Dugger:

l We are reviewing the second 10-year intervalinservice testing program and associated requests for relief for Waterford Steam Electric Station, Unit 3 (Waterford 3), submitted by your letter dated December 1,1997. Additional information is required from Entergy Operations, Inc.,

l in order for us to complete our review. Please provide your response to our enclosed request for additional information within sixty days to meet our review schedule.

1 Sincerely, ORIGINAL SIGNED BYi Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION Docket File PUBLIC PD4-1 r/f C. Patel J.Hannon C.Hawes T. Gwynn, RIV E. Adensam (EGA1) ACRS ,

i Document Name: WAT0264.RAI l  ;

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OFC PM/PD4-in LA/PD4-1 r NPDIV-1 - I NAME CPatel CHawdh ,JHanoon ,

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%{***** / April 15,1998 Mr. Charies M. Dugger Vice President Operations Entergy Operations, Inc.

P. O. Box B Killona, t.A 70066

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE WATERFORD-3 SECOND 10-YEAR INTERVAL INSERVICE TESTING PROGRAM AND ASSOCIATED REQUESTS FOR RELIEF (TAC NO. MA0264)

Dear Mr. Dugger:

We are reviewing the second 10-year intervalinservice testing program and associated requests for relief for Waterford Steam Electric Station, Unit 3 (Waterford 3), submitted by your letter dated December 1,1997. Additional information is required from Entergy Operations, Inc.,

in order for us to complete our review. Please provide your response to our enclosed request for additionalinformation within sixty days to meet our review schedule.

Sincerely,

%b Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Request for AdditionalInformation cc w/ encl: See next page l l

l A

g Mr. Charles M. Dugger ,

Entergy Operations, Inc. Waterford 3 cc:

Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington,TX 76011 Vice President, Operations Resident inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc. Killona, LA 70066 P. O. Box 31995 Jackson, MS 39286 . Parish President Council St. Charles Parish Director P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnville, LA 70057 Entergy Operations, Inc.

P. O. Box B - Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.

Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc. One American Place, Suite 1830 P. O. Box B Baton Rouge, LA 70825 1697 Killona, LA 70066 Licensing Manager Entergy Operations, Inc.

P. O. Box B Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 t

I REQUEST FOR ADDITIONAL INFORMATION FOR IST PROGRAM AND RELIEF REQUESTS SUBMITTED ON DECEMBER 1.1997 WATERFORD. 3 '

1. RELIEF REQUEST PRR-01:

Since the analog charging pump discharge flow instrument in question meets the z 2 percent accuracy requirements but exceeds the maximum allowed full-scale range of three times reference value by approximately 13%, address the applicability of NRC guidelines in NUREG-1482, section 5.5.1,

• Range and Accuracy of Analog Instruments,"

and provide justification if PRR-01 deviates from these guidelines. A range of greater than three times the reference value can be acceptable if the instrument is proportionately more accurate than required. As indicated in section 5.5.1 of NUREG-1482, an altemative can be approved if the combination of range and accuracy yields a reading that meets t 6 percent of reference value. If the guidelines in section 5.5.1 are not applicable because the combination of range and accuracy yields a reading that exceeds

• 6 percent of reference value, an attemative should be proposed to i compensate for the additional uncertainty. One possible attemative is to add the additional uncertainty onto measurements above the reference value and subtract the additional uncertainty from measurements below the reference value when comparing to the allowable ranges of flow.

2. RELIEF REQUEST PRR-02:

The Code requires the frequency response range of vibration measurement instrurt ents to extend as low as one-third minimum pump shaft rotational speed. For the positive displacement charging pumps in question, one-third of the minimum pump rotational speed is approximately 65 rpm, which corresponds to 1.1 hertz. However, the frequency response range of instrumentation used for these pumps extends only as low as 5 hertz, using static testing, and as low as 10 hertz, using dynamic testing. In order to support the statement in PRR-02 that the instrumentation will provide adequate information to evaluate pump condition, please provide documentation, including manufacturer's recommendation, that demonstrates that these pumps are not susceptible to rolling element bearings degradation mechanisms that result in increased vibration levels seen at frequencies below the pump rotational speed frequency, such as impacts from rolling element bearing cage defects.

Also, a few standards laboratories may provide a calibration of vibration monitoring instruments that extends to as low as 3 hertz. Address the practicability of calibrating these instruments down to about 3 hertz at one of these standards laboratories.

OM-6 allows either displacement or velocity in measuring vibration. NUREG/CP-0111,

" Proceedings of the Symposium on Inservice Testing of Pumps and Valves," contains a paper presented by J. Howard Maxwell, " Measurements of Vibrational Parameters for Pump Testing," which states that displacement is the better parameter in determining i

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vibration severity of machines which operate below 600 rpm. Please address the applicability of measuring displacement for the charging pumps in this relief request.

3. RELIEF REQUESTS VRR-01, VRR-02, VRR-03, AND VRR-05:

it is not evident based on the information presented in VRR-01, VRR-02, VRR-03, and VRR-05 that stroke timing is impractical or would result in hardship without a compensating increase in the level of quality and safety. If the stroke timing requirements cannot be met, please provide a basis in sufficient detail to justify a proposed attemative, following the applicable guidelines in NUREG-1482, section 4.2.3, " Measurement of Valve Stroke Time," section 4.2.8, " Solenoid-Operated Valve," and appendix A, pp A-24 to A-34.

The basis should also address the following anomalies:

3.1 The statement in the relief requests that "there is no critical limit on the stroke time " appears to be inconsistent with the NRC guidelines in GL 89-04, position 5,

" Limiting Values of Full-Stroke Times for Power-Operated Valves," and NUREG-1482, appendix A, " Position, Questions, Responses, and Current Considerations Regarding GL 89-04," pp A-24 to A-34.

3.2 Some valves in question have a safety function to close; therefore, the basis should be expanded, as necessary, to include discussions on stroke timing in the closed direction.

3.3 VC-10, a clarification of valve testing, referenced on page 111 of the IST program, appears to be missing from the program.

3.4 The basis does not address non-intrusive techniques or assigning a reasonable, objective acceptance criterion to ars observable parameter, such as a flow rate or AP, to measure stroke times and assess degradation.

4. RELIEF REQUESTS VRR-04 AND VRR-06:

With regard to VRR-04 and VRR-06 on the individual closure verification of category A check valves, please address the applicable guidelines in NUREG-1482, section 4.1.1,

" Closure Verification for Series Check Valves without intermediate Test Connections," l and provide justification if the requests deviate from these guidelines.

5. The following relief valves appear to be Code Class 2 and to have a safety function to protect safety systems: SI-2034 A/B, A, and B (drawing G-167, sheet 1 of 4, coordinates F-5, J-5, and t> 5); and CVC-115 (drawing G-168, sheet 1 of 3, coordinate E-7). Provide justification for not including these valves in me IST program, in accordance with Section 1.1 of OM-10.