3F0309-06, Submittal of Relief Request 09-001-IT, Revision 0

Submittal of Relief Request #09-001-IT, Revision 0

ML090920219
Person / Time
Site:	Crystal River
Issue date:	03/30/2009
From:	Cahill S Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0309-06
Download: ML090920219 (4)

Text

0Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10CFR50.55a March 30, 2009 3F0309-06 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Relief Request #09-001-IT, Revision 0

Dear Sir:

Pursuant to 10 CFR 50.55a(a)(3)(i), Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., is hereby submitting Relief Request #09-001-IT, Revision 0, to request relief from the Comprehensive Pump Test (CPT) requirements of ASME Operations and Maintenance (OM) Code ISTB-5000. The basis for the relief request is that the proposed alternative would provide an acceptable level of quality and safety.

Table ISTB-3400-1 specifies a biennial frequency for CPT of Group A and Group B pumps.

ISTB-5100 and ISTB-5200 describe the specific requirements for performance of CPT for centrifugal pumps. Performance of the biennial CPT on the identified pumps is unnecessary since the existing Group A quarterly pump tests are performed at sufficient flow rates to adequately monitor for pump degradation (i.e., + 20 percent of the pump's design flow). The attachment to this letter contains the proposed alternative, Relief Request #09-001-IT, Revision 0.

No regulatory commitments are contained within this submittal.

The proposed alternative will be implemented during the Fourth Ten-Year Inservice Testing Inspection Interval, which begins on May 11, 2009. FPC requests the review and approval of this proposal by March 31, 2010.

If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Supervisor, Licensing and Regulatory Programs at (352) 563-4796.

Sn e relg ,

Stephen J. Cahill Manager, Engineering Crystal River Nuclear Plant SJC/dwh

Attachment:

Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i) xc: NRR Project Manager Regional Administrator, NRC Region II Senior Resident Inspector Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428 ý

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ATTACHMENT PROPROSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)

U. S. Nuclear Regulatory Commission Attachment 3F0309-06 Page 1 of 2 10 CFR 50.55a Relief Request Number 09-001 -IT Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

1.0 ASME Code Components Affected

BSP-1A, BSP-1B: Reactor Building Spray Pumps CHP-1A, CHP-1 B: Chilled Water Supply Pumps DCP-1A, DCP-1 B: Decay Heat Closed Cycle Cooling Water Pumps DHP-1A, DHP-1B: Decay Heat Pumps EFP-3: Diesel Driven Emergency Feedwater Pump RWP-2A, RWP-2B: Emergency Duty Nuclear Services Raw Water Pumps RWP-3A, RWP-3B: Decay Heat Raw Water Pumps SFP-1A, SFP-1B: Spent Fuel Coolant Pumps SWP-1A, SWP-1 B: Nuclear Services Closed Cycle Cooling Pumps 2.0 Applicable Code Edition and Addenda American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM)

Code, 2001 Edition through OMb-2003 Addenda 3.0 Applicable Code Requirement Table ISTB-3400 Inservice Test Frequency ISTB-5100 - Centrifugal Pumps (Except Vertical Line Shaft Centrifugal Pumps)

ISTB-5200 - Vertical Line Shaft Centrifugal Pumps 4.0 Reason for Request Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (a)(3), relief is requested from the requirements of ASME OM Code ISTB-5000. The basis for the relief request is that the proposed alternative would provide an acceptable level of quality and safety.

Table ISTB-3400-1 specifies a biennial frequency for Comprehensive Pump Testing (CPT) for Group A and Group B pumps. ISTB-5100 and ISTB-5200 describe the specific requirements for performance of CPT for centrifugal pumps. Performance of the biennial CPT on the pumps identified above is unnecessary since the existing Group A quarterly pump tests are performed at sufficient flow rates to adequately monitor for pump degradation (i.e., +/- 20 percent of the pump's design flow).

The ASME Code Committees have approved Code Case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly within +/- 20% of Design Flow," which allows owners to perform a Group A test in lieu of the CPT if the Group A test is conducted at the CPT flow rate using pressure instruments that meet the CPT accuracy requirements (e.g., 0.5 percent of full scale for analog gauges). The basis behind this change is that a

U. S. Nuclear Regulatory Commission Attachment 3F0309-06 Page 2 of 2 quarterly Group A pump test, performed at the CPT flow rate, is far more effective in assessing the pump's operational readiness through trending, than a Group A test in conjunction with a biennial CPT. Additionally, when the Group A test is being performed with instrumentation that meets the CPT requirements, there is little added value in performing a CPT with the more stringent acceptance criterion. This Code Case has not been approved for use in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code, June 2003."

5.0 Proposed Alternative and Basis for Use Crystal River Unit 3 (CR-3) proposes to perform modified Group A quarterly tests in lieu of performing the Code required CPT. The modified Group A test will be run at +/- 20 percent of the pump's design flow rate using 0.5 percent accurate gauges to determine pump differential pressure. CR-3 will utilize an acceptance range of 0.90 to 1.06 on the differential pressure, a range that is more restrictive than the current code case (OMN-18).

Using the provisions of this relief request as an alternative to the specific requirements of ISTB-5123 and ISTB-5223 will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety. Therefore, pursuant to 10CFR50.55a(a)(3)(i), CR-3 requests relief from the specific ISTB requirements identified in this request.

6.0 Duration of the Proposed Alternative The proposed alternative will be used for the remainder of the Fourth Ten-Year Inservice Testing Inspection Interval for CR-3.

7.0 Precedents The ASME Code committees have approved Code Case OMN-18, which allows for the substitution of quarterly Group A pump testing for the biennial CPT. This precedent also requires slight changes to the quarterly pump testing such as use of 0.5 percent accuracy pressure gauges. CR-3 will be imposing the additional measure of a tighter maximum acceptance criterion of 106 percent for differential pressure to these quarterly test results.

8.0 References

1. ASME OM Code, 2001 Edition through OMb-2003 addenda, Subsection ISTB

2. Code Case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly within +/- 20% of Design Flow"