L-2015-098, Fifth Ten-Year Interval Inservice Testing (IST) Program, Relief Request No. PR-01

Fifth Ten-Year Interval Inservice Testing (IST) Program, Relief Request No. PR-01

ML15148A536
Person / Time
Site:	Turkey Point
Issue date:	05/12/2015
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2015-098
Download: ML15148A536 (5)

Text

0 MAY 12 2015 FPL.

L-2015-098 10 CFR 50.55a U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 RE: Florida Power and Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Fifth Ten-Year Interval Inservice Testing (IST) Program Relief Request No. PR-01 Pursuant to 10 CFR 50.55a(z)(2), Florida Power & Light (FPL) hereby requests approval of the attached Relief Request No. PR-01 for the Fifth Ten-Year Interval Inservice Testing Program for Turkey Point Units 3 and 4.

FPL requests relief from the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Section ISTB-5121(c) requirements for the quarterly testing of the boric acid transfer pumps. As an alternative to the code required testing, FPL proposes to test the boric acid transfer pumps by measuring differential pressure and vibration and comparing these values to the reference values on a quarterly basis. During the comprehensive pump test when flow can be measured, full spectrum vibration analysis will be performed above the required vibration analysis required by the Code.

This relief is requested on the basis that compliance with the specified Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The details of the 10 CFR 50.55a request are provided in the attached Relief Request PR-01.

If you have any questions or require additional information, please contact Mr. Mitch Guth, Licensing Manager, at (305) 246-6698.

Sincerely, Michael Kiley Site Vice President Turkey Point Nuclear Plant Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Power & Light Company 9760 SW. 344 Street Homestead, FL 33035

L-2015-098 Page 1 of 4 Turkey Point Units 3 and 4 Inservice Testing Program Relief Request No. PR-01 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety

1. ASME Code Component(s) Affected 3P203A 3A Boric Acid Transfer Pump 3P203B 3B Boric Acid Transfer Pump 4P203A 4A Boric Acid Transfer Pump 4P203B 4B Boric Acid Transfer Pump

2. Applicable Code Edition and Addenda

The Fifth Ten-Year Interval commences on February 22, 2015, and on April 15, 2015 for Turkey Point Units 3 and Unit 4, respectively.

The Code of Record for the Turkey Point Units 3 and 4, Fifth Ten-Year Interval Inservice Testing (IST) Program is the 2004 Edition with the 2005 and 2006 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code).

3. Applicable Code Requirement

ISTB-5121(c) - Where it is not practical to vary system resistance, flow rate and pressure shall be determined and compared to their respective reference values.

4. Reason for Request

The ASME OM Code requires that flow rate be measured during a Group A test and that a Group A inservice test be run on each Group A pump quarterly.

The normal test loop for the boric acid transfer pumps consists of fixed resistance flow paths to limit flow; however, flow measuring instruments are not installed in the flow path. The Turkey Point Units 3 and 4 Boric Acid Transfer Pump Test Diagram is presented in Figure 1. An alternate test circuit is available in which flow rate may be measured, however this flow path requires injection of highly concentrated boric acid solution into the reactor coolant system.

L-2015-098 Page 2 of 4 During power operation, conducting this loop test would result in severe power fluctuations, which would lead to a potential transient and subsequent trip of the reactor.

Using the alternate flow path at cold shutdown intervals would also result in excessive boration of the reactor coolant system resulting in potential difficulties and delays in restarting the plant.

Florida Power & Light Company (FPL) is requesting relief from the ISTB-5121(c) requirements since compliance with the code requirements would require system modifications and installation of flow measuring instruments in the fixed resistance flow path or injection of highly borated water into the reactor coolant system, which would lead to a potential plant transient, and would therefore, cause a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

5. Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(z)(2), in lieu of the Code required test, FPL proposes to test the boric acid transfer pumps every quarter through a fixed resistance flow path without flow instruments and to measure only differential pressure and vibration. Accordingly, differential pressure will be measured and compared to its reference value. Since the system resistance is fixed and can be assumed to be constant, pump degradation can be detected by comparing successive measurements of pump differential pressure.

Additionally, vibration measurements will also be recorded and compared to their reference values.

During the comprehensive pump test when flow can be measured, full spectrum vibration analysis will be performed above the required vibration analysis required by the ASME OM Code. When performing the comprehensive pump test, all required parameters will be measured and compared to their reference values.

Position 9 of Generic Letter (GL 89-04) states that in cases where flow can only be established through a non-instrumented flow path during quarterly pump testing and a flow path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions, the increased interval is an acceptable alternative to the Code requirements provided that pump differential pressure, flow rate, and bearing vibration measurements are taken during this testing and that quarterly testing also measuring at least pump differential pressure and vibration is continued.

These pumps are included in the station preventive maintenance program which requires a pump inspection and oil analysis to be performed periodically. Based on the preventive maintenance inspection results, full spectrum analysis, and continued quarterly and comprehensive testing, an accurate assessment of pump health and operational readiness is determined.

L-2015-098 Page 3 of 4 As discussed herein, the proposed alternative testing provides reasonable assurance that the Turkey Point Units 3 and 4 Boric Acid Transfer Pumps are operationally ready.

6. Duration of Proposed Alternative This proposed alternative will be utilized for the Fifth Ten-Year Interval for the Turkey Point Units 3 and 4 IST Program.

7. Precedents This request was previously approved for the Turkey Point Units 3 and 4 Fourth Ten-Year Interval IST Program (ML042820470).

L-2015-098 Page 4 of 4 Figure 1 Boric Acid Transfer Pump Test Diagram Boric Acid Tank

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Fl IF 113 Boric Acid Blender Boric Acid Transfer Pump 0 S .-. SCharging Pump Suction

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