L-08-350, 10 CFR 50.55a Request Number PR-3, Inservice Testing Program
| ML090650668 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/18/2009 |
| From: | Bezilla M FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-08-350 | |
| Download: ML090650668 (5) | |
Text
FENOC Perry Nuclear Power Station 10 Center Road FirstEnergy Nuclear Operating Company
- Perry, Ohio 44081 Mark B. Bezilla 440-280-5382 Vice President Fax: 440-280-8029 February 18, 2009 L-08-353 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 10 CFR 50.55a Request Number PR-3, In-Service Testin.q Pro.qram In accordance with 10 CFR 50.55a(a)(3),
FirstEnergy Nuclear Operating Company (FENOC) is requesting Nuclear Regulatory Commission (NRC) approval for proposed alternative to requirements associated with the In-Service Testing Program (ISTP) for the Perry Nuclear Power Plant.
The enclosure identifies the affected components, applicable code requirements, reasons for the request, proposed alternative, basis for
- use, and duration.
The proposed alternative would be implemented during the third ten-year ISTP
- interval, which begins May 18, 2009.
FENOC is requesting NRC approval of the alternative by February 18, 2010.
There are no regulatory commitments contained in this submittal.
If there are any questions or additional information is required, please contact Mr. Thomas A. Lentz, Manager-Fleet Licensing, at (330) 761-6071.
Sincerely, Mark B. Bezilla
Enclosure:
10 CFR 50.55a Request Number PR-3 cc:
NRC Region III Administrator NRC Resident Inspector NRC Project Manager
February 18, 2009 L-08-353 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 10 CFR 50.55a Request Number PR-3, In-Service Testing Program In accordance with 10 CFR 50.55a(a)(3), FirstEnergy Nuclear Operating Company (FENOC) is requesting Nuclear Regulatory Commission (NRC) approval for a proposed alternative to requirements associated with the In-Service Testing Program (ISTP) for the Perry Nuclear Power Plant. The enclosure identifies the affected components, applicable code requirements, reasons for the request, proposed alternative, basis for use, and duration.
The proposed alternative would be implemented during the third ten-year ISTP interval, which begins May 18, 2009. FENOC is requesting NRC approval of the alternative by February 18, 2010.
There are no regulatory commitments contained in this submittal. If there are any questions or additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071.
Sincerely, Mark B. Bezilla
Enclosure:
10 CFR 50.55a Request Number PR-3 cc:
NRC Region III Administrator NRC Resident Inspector NRC Project Manager
Perry Nuclear Power Plant Unit 1 10 CFR 50.55a Request Number PR-3, Rev 0 Page 1 of 3 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Component(s) Affected Pumps Code Class 1C41-C001A & B, Standby Liquid Control 2
1E12-C002A, B, & C, Residual Heat Removal 2
1E21-C001, Low Pressure Core Spray 2
1E22-C001, High Pressure Core Spray (HPCS) 2 1E51-C001, Reactor Core Isolation Cooling 2
G41-C003A & B, Fuel Pool Cooling and Cleanup 3
1P42-C001A & B, Emergency Closed Cooling Water 3
1P45-C001A & B, Emergency Service Water 3
1P45-C002, HPCS Emergency Service Water 3
P47-C001A & B, Control Complex Chilled Water 3
1R45-C001A, B, & C, Fuel Oil Transfer #1 3
1R45-C002A, B, & C, Fuel Oil Transfer #2 3
2. Applicable Code Edition and Addenda
ASME OM Code-2001, with Addenda through OMb-2003
3. Applicable Code Requirements
ISTB-2000 defines operating criteria for designating Group A and Group B pumps.
ISTB-3000, General Testing Requirements and Table ISTB-3000-1, Inservice Test Parameters, define and compare parameters (e.g., pressure, flow rate, vibration) measured during Group A, Group B, and Comprehensive Tests.
ISTB-3400, Frequency of Inservice Tests, states that an inservice test shall be run on each pump as specified in Table ISTB-3400-1. This table requires a Group A or Group B Test to be performed quarterly and a Comprehensive Test to be performed biennially.
Table ISTB-3500-1 defines the required instrument accuracy for Group A, Group B, and Comprehensive Tests.
Table ISTB-5100-1 defines the required acceptance criteria for Group A, Group B, and Comprehensive Tests (Centrifugal Pumps).
Page 2 of 3 Table ISTB-5200-1 defines the required acceptance criteria for Group A, Group B, and Comprehensive Tests (Vertical Line Shaft Pumps).
Table ISTB-5300-2 defines the required acceptance criteria for Group A, Group B, and Comprehensive Tests (Reciprocating Positive Displacement Pumps).
- 4. Reason for Request The ASME OM Code Committee has established Code Case OMN-18, Alternate Testing Requirements for Pumps Tested Quarterly within +/- 20% of Design Flow. This code case has not yet been approved for use in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, June 2003.
Although Code Case OMN-18 has not been approved for use, FENOC is proposing this alternative for Group A (and Group B re-classified as Group A) pumps.
The increased requirements imposed by the proposed alternative on the parameters to be monitored during every quarterly pump test and the more accurate instruments that must consistently be used during quarterly testing of pumps classified as Group A (and Group B pumps that are re-classified as Group A pumps), allows FENOC to perform better trending of pump performance data due to the more consistent requirements for each of the quarterly tests.
Due to the increased requirements on the parameters imposed by the proposed alternative during all quarterly tests there is no added value in performing the biennial Comprehensive Test.
5. Proposed Alternative and Basis for Use
FENOC proposes that in lieu of the requirements of ISTB-3400, Group A tests will be performed quarterly within +/- 20 percent of the pump design flow rate, with instrumentation meeting the instrument accuracy requirements of Table ISTB-3500-1 for the biennial Comprehensive Test, and the Comprehensive Test would not be required.
Specifically,
- a. Pumps tested quarterly using this alternative must be tested within +/-20 percent of pump design flow, as is required for the biennial Comprehensive Test in ISTB-3300(e) and (f).
- b. The proposed alternative requires the accuracy of instruments used during quarterly Group A tests to meet the more accurate pressure and differential pressure requirements listed for the Comprehensive Test in Table ISTB-3500-1 (an accuracy improvement from +/- 2 percent to +/- 1/2 percent). Consistent use of these more accurate instruments during each quarterly test provides for improved Group A pump performance trend data evaluation.
- c. Pumps that would normally be categorized as Group B pumps, but are re-categorized as Group A, may be tested according to the provisions of this alternative. As a result of this re-categorization from Group B to Group A, per Table
Page 3 of 3 ISTB-3000-1, additional data must be obtained quarterly rather than once every two years on the test parameters of Discharge pressure (for the Standby Liquid Control positive displacement pumps), and Vibration (for all the affected pumps).
- d. Use of this alternative provides for consistent acceptance criteria for pump flow and differential pressure tests. FENOC will consistently utilize the Group A Test acceptance criteria in Tables ISTB-5100-1, ISTB-5200-1, and ISTB-5300-2 for pump tests rather than having to utilize the Comprehensive Test criterion for one biennial test.
The provisions of this request, as an alternative to the requirements of ISTB-3400, provide a reasonable alternative to the code requirements. The proposed alternative provides an acceptable level of quality and safety for monitoring the pumps and ensures they are capable of performing their safety function.
6. Duration of Proposed Alternative
The proposed alternative identified in this request shall be utilized during the Third Ten-Year IST Interval beginning May 18, 2009, or until the NRC publishes a new revision of RG 1.192 that approves Code Case OMN-18, whichever comes first.
- 7. Reference Code Case OMN-18, Alternate Testing Requirements for Pumps Tested Quarterly within +/- 20% of Design Flow