CSPP Rev. 0 Page 1 Condition Report Engineering Evaluation Form 1 Engineering Evaluation (Typical) Page 1 of 5 CR# Condition/Action Summary: STP has been granted an exemption from Inservice Testing Requirements of the ASME OM Code for Low and NRS components. Evaluate the testing requirements for GQA Risk Rank “Low” pumps in IST group CSPP (pump tags are listed in evaluation that follows). Engineering Evaluation: BACKGROUND: The goal of the exemption allowance is to focus resources on safety significant components and eliminate unnecessary burden while providing sufficient confidence that Low Risk/Non Risk significant SSCs will satisfy their design functional requirements. Since these pumps are Low risk and may be exempted from IST requirements, this CREE will document the basis for reasonable confidence that these pumps will operate satisfactorily. This evaluation will include a review of the failure history for the pumps, maintenance history, operational evolutions involving these pumps and a review of inspection and testing results, as applicable. ANALYSIS: IST pump group CSPP 1(2)PA101A, 1(2)PA101B, 1(2)PA101C Containment Spray Pump SAFETY FUNCTIONS: 1. Supply borated water from the RWST to the containment spray ring header during the short-term injection phase upon receipt of a “Hi-3” containment pressure signal. 2. Recirculate borated water from the containment sumps to the containment spray ring header during the long-term recirculation phase. Additional Actions Required? Approvals: Brad Scott Preparer (Print/Sign) No Date Ye If Yes, list CR s Action #s Approval (Print/Sign) Date CSPP Rev. 0 Page 2 Condition Report Engineering Evaluation Form 1 Engineering Evaluation (Typical) Page 2 of 5 CR# ANALYSIS:(cont) GROUP INFORMATION This pump group contains 3 pumps in each unit for a total of 6 pumps. These pumps are motor driven vertical centrifugal canned suction pumps with a design point of 1900 gpm at 560 feet of water. MAINTENANCE AND TEST HISTORY Maintenance, testing and operational history from 1990 to present has identified several work activities associated with these pumps. These work activities were attributed to routine pump maintenance related to the worn pump/motor bearings, mechanical seal leakage, loose fasteners, and flange leakage. In all cases the pumps were repaired using routine maintenance to restore the pumps to service following satisfactory post maintenance testing. Review of the maintenance history since 1990 has not identified any Inservice Testing failures during the operation of these pumps for testing. None of the maintenance activities for this pump group represent a failure of the pumps to perform their design function. The maintenance activities identified for this pump group were typical of pump behaviors and maintenance patterns. No catastrophic pump failures were identified. These pumps are included in the station Preventive Maintenance Program and required to have an inspection and diagnostic test performed every 78 weeks. In addition the pump 0rings and mechanical seals are required be replaced once every 676 weeks. Maintenance activities identified for these pumps are consistent with the EPRI templates for Pumps. INSERVICE TESTING REQUIREMENTS These pumps are tested for mechanical and hydraulic performance each quarter in accordance with the Containment Spray Pump Inservice Test, 0PSP03-CS-0001/2/3. These tests verify the ability of the pumps to perform their design functional requirements. Upon removal from the IST Program, there is reasonable confidence that these pumps will continue to satisfy their design functional requirements when demanded based on the following: CSPP Rev. 0 Page 3 Condition Report Engineering Evaluation Form 1 Engineering Evaluation (Typical) Page 3 of 5 CR# a) The Containment Spray Pumps are normally in the standby mode. The pumps start automatically upon receipt of a Hi-3 containment pressure signal to deliver spray flow to the containment spray ring header during the injection and recirculation phases of an accident requiring containment spray. Failure of any one of the pumps to start would not affect the safety function of the system since three 50% capacity pumps are provided and only two are required to provide the necessary design spray flow. In addition, the pumps are powered from redundant independent power supplies. b) These pumps will continue to be tested once every 54 months in conjunction with Response Time Testing per procedure 0PSP03-SP-13A/B/C. This testing satisfies Technical Specification 4.3.2.2.6.A. In addition, pump testing can also be performed in conjunction with System Leakage Testing per procedure 0PSP11-CS-0006/7/8. This testing satisfies Technical Specifications 6.8.3.A. If the pumps do not operate and deliver flow as required during any test, a Condition Report will be generated to investigate/correct the concern. c) A pump test will continue to be performed to verify the pumps operate and deliver flow following any maintenance activity affecting operation of these pumps. d) If the Technical Specification requirements in item (b) above is deleted or extended, administrative controls (PM task/procedure) will be generated to ensure these pumps are operated and deliver flow every 18 months. e) Any failure of the pumps to operate and deliver flow during testing or normal operations will be identified and corrected in accordance with the STP Corrective Action Program. f) Routine Operator rounds and periodic System Engineering walkdowns during normal plant operations will identify visible pump deficiencies. Any deficiency identified during these inspections will be documented corrected in accordance with the STP Corrective Action Program. CONCLUSIONS: There is reasonable confidence that these pumps will continue to have the capability to perform their intended design safety function throughout the life of the plant. Periodic response time testing and system leakage testing ensures the operational readiness of these pumps. Periodic Operator and System Engineering inspections will continue to be performed to detect any visible external degradation of the pumps. In addition, these pumps will continue to be maintained in the STP Preventive Maintenance program. CSPP Rev. 0 Page 4 Condition Report Engineering Evaluation Form 1 Engineering Evaluation (Typical) Page 4 of 5 CR# These pumps will be removed from the scope of the IST program. The Technical Specification surveillance requirements for Response Time and System Leakage testing will continue to be performed for these pumps. ACTIONS: 1. Update the Inservice Testing Program by performing the following activities: For each pump in IST pump group CSPP include a reference to this Engineering Evaluation in the STPIST inservice testing database, update the IST Plan to show these pumps have been exempted from IST testing, and update the IST Basis Document to include a discussion of the basis for exemption and the alternate method of determining functionality described in this Engineering Evaluation. 2. Revise 0PSP03-CS-0001, 0PSP03-CS-0002 and 0PSP03-CS-0003 to remove these pumps from surveillance testing per Technical Specification 4.0.5. 3. Update the Surveillance Testing database to reference this Engineering Evaluation and to show that the Inservice Testing (TS 4.0.5) surveillance tests are no longer required. 4. The following procedures should be revised to provide assurance that the subject pumps will be maintained within the procedures and tested as stated in this evaluation. Train A ESF Actuation and Response Time Test, 0PSP03-SP-0013A Train B ESF Actuation and Response Time Test, 0PSP03-SP-0013B Train C ESF Actuation and Response Time Test, 0PSP03-SP-0013C Containment Spray System Train 1A/2A Contaminated System Leakage Test, 0PSP11-CS-0006 Containment Spray System Train 1B/2B Contaminated System Leakage Test, 0PSP11-CS-0007 Containment Spray System Train 1C/2C Contaminated System Leakage Test, 0PSP11-CS-0008 CSPP Rev. 0 Page 5 Condition Report Engineering Evaluation Form 1 Engineering Evaluation (Typical) Page 5 of 5 CR# REFERENCES: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. STPEGS 2nd Interval Inservice Testing Plan IST Program Basis Document RI-IST Maintenance History review RI-IST Preventive Maintenance Activities review P&ID 5N109F05037, Containment Spray System DBD 5N109MB1024, Containment Spray System Procedure 0PSP03-CS-0001, Containment Spray Pump 1A(2A) Inservice Test Procedure 0PSP03-CS-0002, Containment Spray Pump 1B(2B) Inservice Test Procedure 0PSP03-CS-0003, Containment Spray Pump 1C(2C) Inservice Test Procedure 0PSP03-SP-0013A Train A ESF Actuation and Response Time Test Procedure 0PSP03-SP-0013B Train B ESF Actuation and Response Time Test Procedure 0PSP03-SP-0013C Train C ESF Actuation and Response Time Test Procedure 0PSP11-CS-0006, Containment Spray System Train 1A(2A) Contaminated System Leakage Test Procedure 0PSP11-CS-0007, Containment Spray System Train 1B(2B) Contaminated System Leakage Test Procedure 0PSP11-CS-0008, Containment Spray System Train 1C(2C) Contaminated System Leakage Test UFSAR Section 1.2.2.3.2, Containment Heat Removal Systems UFSAR Section 6.2.2, Containment Heat Removal Systems UFSAR Section 6.5.2, Containment Spray System – Iodine Removal UFSAR Table 16.1-4, Engineered Safety Features Response Times Technical Specifications 4.3.2.2.6.A Technical Specifications 6.8.3.A