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| issue date = 02/27/2006
| issue date = 02/27/2006
| title = Draft RAI on Pump and Valve Relief Requests
| title = Draft RAI on Pump and Valve Relief Requests
| author name = Tam P S
| author name = Tam P
| author affiliation = NRC/NRR/ADRO/DORL
| author affiliation = NRC/NRR/ADRO/DORL
| addressee name = Crane R, Junge M, Scarpello M K, Vasey B
| addressee name = Crane R, Junge M, Scarpello M, Vasey B
| addressee affiliation = Indiana Michigan Power Co, NRC/NRR
| addressee affiliation = Indiana Michigan Power Co, NRC/NRR
| docket = 05000315, 05000316
| docket = 05000315, 05000316
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:From: Peter TamTo:Crane, Randy; Michael Junge; Scarpello, Michael; Vasey, BobDate: 2/27/06 2:21PM
{{#Wiki_filter:From:           Peter Tam To:             Crane, Randy; Michael Junge; Scarpello, Michael; Vasey, Bob Date:           2/27/06 2:21PM


==Subject:==
==Subject:==
Cook - Draft RAI on Pump and Valve Relief Requests (TAC MC9455 andMC9456)Bob:
Cook - Draft RAI on Pump and Valve Relief Requests (TAC MC9455 and MC9456)
We are reviewing your12/28/2005 request for relief for pumps and valves for the 4th interval. Our reviewer Michael Junge has the following draft RAI that we would like to discuss with you in a conference call: 1.Relief request REL-001RAI REL-001-01 ISTC-3560 requires valves with fail-safe-actuators to be tested by observing theoperation of the actuator upon loss of valve actuating power in accordance with the exercisingfrequency of ISTC-3510. Please provide information as to why fail-safe testing of these valves during a refueling outage as required by the ASME Code is impractical. 2.Relief request REL-002RAI REL-002-01 The basis for relief identifies an NRC document titled "Summary of October 9, 1997,Meeting on RWST Mini-Flow Recirculation Line Valve Testing." This document describes an agreement in which it would be appropriate that the valves be added to the licensee's insevice test program as Category B valves. As Category B valves, the Code does not require individual valve leakage testing. For Category B valves, the only requirement is for closure exercising
Bob:
 
We are reviewing your12/28/2005 request for relief for pumps and valves for the 4th interval.
and system leakage testing. Under those circumstances, the reverse flow testing is acceptable. Please provide information as to the change to the valve categorization back to category A, and how reverse testing is an acceptable alternative.3.Relief Request PP-2NUREG-1482, Revision 1, Section 5.4 discusses Monitoring Pump Vibration inaccordance with ISTB. The basis section discusses the speed range to be evaluated.
Our reviewer Michael Junge has the following draft RAI that we would like to discuss with you in a conference call:
Instruments with a frequency response that meets these requirements for slow-speed pumpsmay not be widely used. However, the unavailability of instruments alone does not constituteadequate justification for obtaining relief or approval of an alternative; however it may be a significant element in the justification. The NRC has observed that because of technologyadvancement and research in the field of instrumentation and vibration measuring transducers, meeting code requirements can now be procured from various suppliers at reasonable costs.
: 1.     Relief request REL-001 RAI REL-001-01 ISTC-3560 requires valves with fail-safe-actuators to be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-3510. Please provide information as to why fail-safe testing of these valves during a refueling outage as required by the ASME Code is impractical.
Please provide a discussion as to the availability of instruments to measure the lower frequencynecessary to meet the code requirements.4.Relief Request PP-3RAI PP-3-001 The reference used in this Request for Relief, NUREG-1482, Revision 1, Section 5.5.1discusses the range and accuracy of analog instruments. The basis describes the justification for using originally installed gauges with instrument ranges of 4 times the reference value.
: 2.     Relief request REL-002 RAI REL-002-01 The basis for relief identifies an NRC document titled "Summary of October 9, 1997, Meeting on RWST Mini-Flow Recirculation Line Valve Testing." This document describes an agreement in which it would be appropriate that the valves be added to the licensee's insevice test program as Category B valves. As Category B valves, the Code does not require individual valve leakage testing. For Category B valves, the only requirement is for closure exercising and system leakage testing. Under those circumstances, the reverse flow testing is acceptable.
Please provide information as to the change to the valve categorization back to category A, and how reverse testing is an acceptable alternative.
: 3.     Relief Request PP-2 NUREG-1482, Revision 1, Section 5.4 discusses Monitoring Pump Vibration in accordance with ISTB. The basis section discusses the speed range to be evaluated.
Instruments with a frequency response that meets these requirements for slow-speed pumps may not be widely used. However, the unavailability of instruments alone does not constitute adequate justification for obtaining relief or approval of an alternative; however it may be a significant element in the justification. The NRC has observed that because of technology advancement and research in the field of instrumentation and vibration measuring transducers, meeting code requirements can now be procured from various suppliers at reasonable costs.
Please provide a discussion as to the availability of instruments to measure the lower frequency necessary to meet the code requirements.
: 4.     Relief Request PP-3 RAI PP-3-001 The reference used in this Request for Relief, NUREG-1482, Revision 1, Section 5.5.1 discusses the range and accuracy of analog instruments. The basis describes the justification for using originally installed gauges with instrument ranges of 4 times the reference value.
Please provide a basis for using the 0-600 psig gauge to establish the reference value for suction pressure of the Residual Heat Removal Pumps (lowest reference value (23.2 psi).
Please provide a basis for using the 0-600 psig gauge to establish the reference value for suction pressure of the Residual Heat Removal Pumps (lowest reference value (23.2 psi).
Additionally, provide a discussion on the feasability of using temporary gauges for thesepressure test gauges.
Additionally, provide a discussion on the feasability of using temporary gauges for these pressure test gauges.
The sole purpose of this e-mail is to prepare you and others for the proposed conference call. This e-mail does not formally request for additional information, nor does it convey a formal NRC staff position
.Peter S. Tam, Senior Project ManagerPlant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulatione-mail: pst@nrc.gov  Tel.: 301-415-1451 Mail Envelope Properties(4403513F.37C : 12 : 334)


==Subject:==
The sole purpose of this e-mail is to prepare you and others for the proposed conference call.
Cook - Draft RAI on Pump and Valve Relief Requests (TAC MC9455and MC9456)Creation Date:
This e-mail does not formally request for additional information, nor does it convey a formal NRC staff position.
2/27/06 2:21PMFrom: Peter TamCreated By:PST@nrc.govRecipients ActionDate & Time  twf5_po.TWFN_DO Delivered02/27/06 2:21 PMMXJ2 (Michael Junge) Opened02/27/06 2:48 PMaep.com Transferred02/27/06 2:22 PMmkscarpello (Michael Scarpello)rgvasey (Bob Vasey) rmcrane (Randy Crane)Post Office DeliveredRoute twf5_po.TWFN_DO02/27/06 2:21 PM
Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation e-mail: pst@nrc.gov Tel.: 301-415-1451


aep.comFilesSizeDate & Time MESSAGE511702/27/06 02:21PMOptions Auto Delete:
Mail Envelope Properties (4403513F.37C : 12 : 334)
No Expiration Date:None Notify Recipients:Yes Priority:Standard Reply Requested:
No Return Notification:None Concealed


==Subject:==
==Subject:==
Cook - Draft RAI on Pump and Valve Relief Requests (TAC MC9455 and MC9456)
Creation Date:        2/27/06 2:21PM From:                  Peter Tam Created By:            PST@nrc.gov Recipients                                        Action            Date & Time twf5_po.TWFN_DO                                Delivered          02/27/06 2:21 PM MXJ2 (Michael Junge)                        Opened              02/27/06 2:48 PM aep.com                                          Transferred        02/27/06 2:22 PM mkscarpello (Michael Scarpello) rgvasey (Bob Vasey) rmcrane (Randy Crane)
Post Office                                      Delivered          Route twf5_po.TWFN_DO                                02/27/06 2:21 PM aep.com Files                          Size              Date & Time MESSAGE                        5117              02/27/06 02:21PM Options Auto Delete:                  No Expiration Date:              None Notify Recipients:            Yes Priority:                      Standard Reply Requested:              No Return Notification:          None Concealed


No Security:Standard To Be Delivered:Immediate Status Tracking:Delivered & Opened}}
==Subject:==
No Security:                     Standard To Be Delivered:               Immediate Status Tracking:               Delivered & Opened}}

Latest revision as of 22:51, 23 November 2019

Draft RAI on Pump and Valve Relief Requests
ML060590089
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 02/27/2006
From: Tam P
Plant Licensing Branch III-2
To: Crane R, Junge M, Scarpello M, Vasey B
Indiana Michigan Power Co, Office of Nuclear Reactor Regulation
References
TAC MC9455, TAC MC9456
Download: ML060590089 (3)


Text

From: Peter Tam To: Crane, Randy; Michael Junge; Scarpello, Michael; Vasey, Bob Date: 2/27/06 2:21PM

Subject:

Cook - Draft RAI on Pump and Valve Relief Requests (TAC MC9455 and MC9456)

Bob:

We are reviewing your12/28/2005 request for relief for pumps and valves for the 4th interval.

Our reviewer Michael Junge has the following draft RAI that we would like to discuss with you in a conference call:

1. Relief request REL-001 RAI REL-001-01 ISTC-3560 requires valves with fail-safe-actuators to be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-3510. Please provide information as to why fail-safe testing of these valves during a refueling outage as required by the ASME Code is impractical.
2. Relief request REL-002 RAI REL-002-01 The basis for relief identifies an NRC document titled "Summary of October 9, 1997, Meeting on RWST Mini-Flow Recirculation Line Valve Testing." This document describes an agreement in which it would be appropriate that the valves be added to the licensee's insevice test program as Category B valves. As Category B valves, the Code does not require individual valve leakage testing. For Category B valves, the only requirement is for closure exercising and system leakage testing. Under those circumstances, the reverse flow testing is acceptable.

Please provide information as to the change to the valve categorization back to category A, and how reverse testing is an acceptable alternative.

3. Relief Request PP-2 NUREG-1482, Revision 1, Section 5.4 discusses Monitoring Pump Vibration in accordance with ISTB. The basis section discusses the speed range to be evaluated.

Instruments with a frequency response that meets these requirements for slow-speed pumps may not be widely used. However, the unavailability of instruments alone does not constitute adequate justification for obtaining relief or approval of an alternative; however it may be a significant element in the justification. The NRC has observed that because of technology advancement and research in the field of instrumentation and vibration measuring transducers, meeting code requirements can now be procured from various suppliers at reasonable costs.

Please provide a discussion as to the availability of instruments to measure the lower frequency necessary to meet the code requirements.

4. Relief Request PP-3 RAI PP-3-001 The reference used in this Request for Relief, NUREG-1482, Revision 1, Section 5.5.1 discusses the range and accuracy of analog instruments. The basis describes the justification for using originally installed gauges with instrument ranges of 4 times the reference value.

Please provide a basis for using the 0-600 psig gauge to establish the reference value for suction pressure of the Residual Heat Removal Pumps (lowest reference value (23.2 psi).

Additionally, provide a discussion on the feasability of using temporary gauges for these pressure test gauges.

The sole purpose of this e-mail is to prepare you and others for the proposed conference call.

This e-mail does not formally request for additional information, nor does it convey a formal NRC staff position.

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation e-mail: pst@nrc.gov Tel.: 301-415-1451

Mail Envelope Properties (4403513F.37C : 12 : 334)

Subject:

Cook - Draft RAI on Pump and Valve Relief Requests (TAC MC9455 and MC9456)

Creation Date: 2/27/06 2:21PM From: Peter Tam Created By: PST@nrc.gov Recipients Action Date & Time twf5_po.TWFN_DO Delivered 02/27/06 2:21 PM MXJ2 (Michael Junge) Opened 02/27/06 2:48 PM aep.com Transferred 02/27/06 2:22 PM mkscarpello (Michael Scarpello) rgvasey (Bob Vasey) rmcrane (Randy Crane)

Post Office Delivered Route twf5_po.TWFN_DO 02/27/06 2:21 PM aep.com Files Size Date & Time MESSAGE 5117 02/27/06 02:21PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened