LR-N12-0043, IST Relief Request to Implement OMN-18 for the Fourth Ten-Year Inservice Testing Interval

IST Relief Request to Implement OMN-18 for the Fourth Ten-Year Inservice Testing Interval

ML12039A070
Person / Time
Site:	Salem
Issue date:	02/07/2012
From:	Duke P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N12-0043
Download: ML12039A070 (5)

Text

PSEG P.O. Box 236, Hancocks Bridge, NJ 08038-0236 OPSEG Nuclear LLC 10 CFR 50.55a LR-N12-0043 February 7,2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

1ST Relief Request to Implement OMN-18 for the Fourth Ten-Year Inservice Testing Interval for Salem Units 1 and 2 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (a)(3), PSEG Nuclear, LLC (PSEG) hereby requests NRC approval for a proposed alternative to requirements associated with the In-Service Testing Program for Salem Units 1 and 2. The attachment 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 fourth ten-year interval. PSEG requests approval of this request by February 7,2013.

There are no regulatory commitments contained in this submittal. If you have any questions or require additional information, please contact Lee Marabella at (856) 339-1208.

Respectfully, Q1JLfl-i Paul R. Duke' v - \

Manager, Licensing Attachments: 10 CFR 50.55a Request Number P-03

ATTN: Document Control Desk February 7,2012 LR-N12-0043 Page 2 cc: Regional Administrator - NRC Region 1 NRC Senior Resident Inspector - Salem NRC Project Manager NJBNE Salem Commitment Coordinator Corporate Commitment Coordinator

Attachment LR-N12-0043 10 CFR 50.55a Request Number P-03 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i):

Alternative Provides Acceptable level of Quality and Safety

1. ASME Code ComQonent{s} Affected Pump Description Class Category Unit 81 CVC-1 CVE4 11 Boric Acid Transfer Pump 3 Group A 1 81 CVC-1 CVE5 12 Boric Acid Transfer Pump 3 Group A 1 82CVC-2CVE4 21 Boric Acid Transfer Pump 3 Group A 2 82CVC-2CVE5 22 Boric Acid Transfer Pump 3 Group A 2 S1CC -1CCE2 11 Component Cooling Pump 3 Group A 1 S1CC -1CCE4 12 Component Cooling Pump 3 Group A 1 S1CC -1CCE3 13 Component Cooling Pump 3 Group A 1 82CC -2CCE2 21 Component Cooling Pump 3 Group A 2 S2CC -2CCE4 22 Component Cooling Pump 3 Group A 2 S2CC -2CCE3 23 Component Cooling Pump 3 Group A 2 81CH -1CHE5 11 Chilled Water Pump 3 Group A 1 S1CH -1CHE6 12 Chilled Water Pump 3 Group A 1 82CH -2CHE6 21 Chilled Water Pump 3 Group A 2 82CH -2CHE7 22 Chilled Water Pump 3 Group A 2 S18F -1SFE5 11 8pent Fuel Cooling Pump 3 Group A 1 S1SF -18FE6 128pent Fuel Cooling Pump 3 Group A 1 S28F-28FE5 21 Spent Fuel Cooling Pump 3 Group A 2 S28F-2SFE6 22 8pent Fuel Cooling Pump 3 Group A 2

2. AQQlicable Code Edition and Addenda A8ME OM Code-2001, with Addenda through OMb-2003

3. AQQlicable Code Requirements Table 18TB-3400-1, "Inservice Test Frequency" Table 18TB-3500-1, "Required Instrument Accuracy" Table ISTB-51 00-1, "Centrifugal Pump Test Acceptance Criteria" ISTB-5123, "Comprehensive Test Procedure" - for centrifugal pumps (except vertical line shaft) 1

Attachment LR-N12-0043

4. Reason for Request

Pursuant to 10 CFR SO.SSa, "Codes and Standards," paragraph (a)(3), relief is requested from the requirements of ASME OM Code ISTB-S123, Table ISTB-3400-1 and Table ISTB-S100-1. The basis for the relief request is that the proposed alternative would provide an acceptable level of quality and safety.

The ASME OM Code Committee has 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 Comprehensive Pump Test (CPT) if the Group A test is conducted at +/- 20% of the design flow rate and uses pressure instruments that meet the CPT accuracy requirements (+/-1/2%). This Code Case was not reviewed for approval in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code", June 2003.

The basis for this change is that a quarterly Group A pump test, performed at the CPT flow rate provides more consistent data for trending than a Group A test in conjunction with a biennial CPT.

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, allow PSEG 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 PSEG proposes that in lieu of the CPT requirements of Table ISTB-3400-1, Group A tests will be performed quarterly within +/- 20 percent of the pump design flow rate, with pressure measuring instrumentation meeting the (+/-1/2%) instrument accuracy requirements of Table ISTB-3S00-1 specified for the biennial Comprehensive Test. In addition, PSEG has elected to restrict the upper limit for differential pressure to 6%, which is more conservative than the 10% upper limit established in Table ISTB-S100-1 for Group A tests as this limit provides needed margin while maintaining an acceptable level of quality and safety, and is consistent with the limit authorized by NRC in similar relief requests. This proposed change to the acceptance range is more restrictive than specified in the current Code Case (OMN-18).

Vibration testing will continue to be performed under the proposed modified Group A test and the acceptance criteria for vibration will be the same as required for Group A tests as shown in Table ISTB-S100-1.

2

Attachment LR-N12-0043 Using the provisions of this relief request as an alternative to those specified in ISTB-5123 will provide adequate indication of pump performance, permit consistent detection of component degradation, and continue to provide an acceptable level of quality and safety.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), PSEG requests relief from the specific ISTB reqUirements identified in this request.

6. Duration of Proposed Alternative The proposed alternative will be used for the remainder of the Fourth Ten-Year Inservice Testing Interval for Salem Units 1 and 2.

7. Precedents Similar requests have been authorized at other facilities including;

• PERRY NUCLEAR POWER PLANT, UNIT NO.1 -RELIEF REQUEST PR-3 FOR THIRD 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM (TAC NO.

ME0820) (ML092640690)

• ST. LUCIE UNIT NOS. 1 AND 2 -RELIEF FROM THE REQUIREMENTS OF THE ASME CODE, RELIEF REQUEST NO.9 (TAC NOS. ME5190 AND ME5191)

(ML11143A077)

• SOUTH TEXAS PROJECT, UNITS 1 AND 2 -RELIEF REQUEST NOS. VRR-01, PRR-01, PRR-02, AND PRR-03 FOR THE THIRD 10-YEAR INSERVICE TESTING PROGRAM INTERVAL (TAC NOS. ME3515, ME3516, ME3517, ME3518, ME3519, ME3520, ME3521, AND ME3522) (ML102150077)

8. References ASME OM Code, 2001 Edition with Addenda through OMb-2003, Subsection ISTB Code case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly within +/- 20%

of Design Flow" 3