ML071660054

Relief Request from ASME Code IST Requirements for AFW Pump Gauges'

ML071660054
Person / Time
Site:	Harris
Issue date:	07/16/2007
From:	Boyce T NRC/NRR/ADRO/DORL/LPLII-2
To:	Duncan R Carolina Power & Light Co
Boyce T, NRR/ADRO/DORL/301-415-0184
References
TAC MD3894
Download: ML071660054 (6)

Text

July 16, 2007 Robert J. Duncan II, Vice President Shearon Harris Nuclear Power Plant, Unit 1 Carolina Power & Light Company P.O. Box 165 New Hill, NC 27562

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - RELIEF REQUEST AF-PR-1 FOR THE THIRD 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MD3894)

Dear Mr. Duncan:

By letter dated December 18, 2006, the Carolina Power & Light Company (the licensee) submitted Relief Request AF-PR-1 for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP).

By letter dated March 22, 2007, the licensee submitted Revision 1 of the relief request to provide clarification in response to the Nuclear Regulatory Commission (NRC) staffs request.

The licensee requested relief from certain inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the auxiliary feedwater motor-driven pumps gauges. The installed gauges do not meet the OM Code requirements for gauge range.

The NRC authorizes the licensees proposed alternative to use the existing gauges because the indicated accuracy is equivalent to the ASME OM Code. This authorization is in accordance with Title 10 to the Code of Federal Regulations, Section 50.55a(a)(3)(i) since the alternative provides an acceptable level of quality and safety. The NRC staffs evaluation and conclusion are contained in the enclosed safety evaluation.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable. This relief is authorized for the third 10-year interval at HNP which is in effect from May 2, 2007, through May 1, 2017.

Sincerely,

/RA/ B. Mozafari for T. Boyce Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

Safety Evaluation cc w/encl: See next page

ML071660054 NRR-028 OFFICE LPL II-2/PM LPLII-2/PM LPL II-2/LA DCI/CPNB OGC LPL II-2/BC NAME LRegner SBailey RSola JMcHale LSubin TBoyce (via memo) BRM DATE 06/27/07 06/28 /07 06/27/07 04/18/07 07/11/07 07/16/07 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST AF-PR-1 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 CAROLINA POWER AND LIGHT COMPANY DOCKET NO. 50-400

1.0 INTRODUCTION

By letter dated December 18, 2006, the Carolina Power and Light Company (the licensee),

submitted Relief Request (RR) AF-PR-1 for the third 10-year inservice testing (IST) program interval at Shearon Harris Nuclear Power Plant, Unit 1 (HNP). The licensee requested relief from certain IST requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the auxiliary feedwater (AFW) motor-driven pumps gauges. By letter dated March 22, 2007, the licensee submitted Revision 1 of the RR to provide clarification in response to the Nuclear Regulatory Commission (NRC) staffs request.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year)

IST program intervals in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been authorized by the NRC pursuant to paragraphs (a)(3)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each IST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.

In proposing an alternative, the licensee must demonstrate that it provides an acceptable level of quality and safety. Section 50.55a of 10 CFR authorizes the NRC to approve alternatives from ASME Code requirements upon making the necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Revision 1, Guidance for Inservice Testing at Nuclear Power Plants.

The third 10-year IST interval began on May 2, 2007, and concludes on May 1, 2017. The Code of record for the IST program is the 2001 Edition through 2003 Addenda of the ASME OM Code.

3.0 TECHNICAL EVALUATION

Code Requirements The licensee requested relief from ISTB-3510 of the ASME OM Code. ISTB-3510(a) requires that flow instrument accuracy shall be within +/-2 percent of full-scale as defined in Table ISTB-3500-1. ISTB-3510(b)(1) requires that the full-scale range of each analog instrument shall not be greater than three times the reference value.

Relief was requested for the following pumps:

AF1A-SA (Motor-Driven AFW Pump 1A)

AF1B-SB (Motor-Driven AFW Pump 1B)

Licensees Basis for Requesting Relief The permanently installed flow instruments which are utilized to conduct the quarterly pump tests of the two motor-driven AFW pumps (AF1A-SA and AF1B-SB) have a calibrated full-scale range which exceeds a factor of three times their reference values. The full scale range of the instruments is 0-200 gallons per minute (gpm) while the reference value of each pump is 51 gpm. The instruments (FI-2172) are installed in a common pump recirculation line which is shared by both the two motor-driven AFW pumps and the single turbine-driven AFW pump.

The indicators are sized to accommodate the combined restricted flows of all three pumps simultaneously. Although the full scale range of the instruments does not comply with ASME OM Code requirements, the accuracy of +/-1 percent of full scale exceeds what is required.

The instruments do not meet the ASME OM Code requirement for range; however, they are capable of providing an indicated accuracy at the reference value that is superior to the minimum indicated accuracy that is required by the ASME OM Code. As documented by NUREG-1482, Revision 1, Section 5.5.1, the minimum required indicated accuracy is

+/-6 percent based on the least accurate instrument that would theoretically be allowed by the Code. The derived indicated accuracy of the instruments based upon the current reference values, is:

Reference value = 51 gpm Full scale range = 200 gpm Instrument tolerance = +/-2 gpm (+/-1 percent x 200 gpm)

Therefore, the indicated accuracy is:

+/-2 gpm / 51 gpm x 100 percent = +/-3.9 percent The indicated accuracy is theoretically better than what is allowed by the ASME OM Code.

Licensees Proposed Alternative Testing The existing permanently installed pump instruments are acceptable because the indicated accuracy is less than or equal to +/-6 percent as calculated at the reference value.

Evaluation The AFW system provides water to the steam generators in the event of loss of normal feedwater. The safety-related AFW system includes two, 50-percent capacity motor-driven pumps and one, 100-percent capacity steam turbine-driven pump.

The 2001 Edition of the OM Code, ISTB-3510(a) requires that the accuracy of flow rate instruments be within +/-2 percent of full-scale for analog instruments. Additionally, ISTB-3510(b)(1) requires the full-scale range of each analog instrument be no greater than three times the reference value. In NUREG-1482, Revision 1, Section 5.5.1, the NRC staff evaluated the situation where the range of an analog instrument is greater than three times the reference value, but the accuracy is more conservative than that required by the OM Code.

The NUREG states that the NRC staff may grant relief when the combination of the range and accuracy yields a reading that is at least equivalent to the reading achieved from instruments that meet the Code requirements (i.e., up to +/-6 percent).

In this RR, the accuracy meets the OM Code requirements, however, the range exceeds the requirements. Considered together, the reading accuracy achieved from the installed instruments is +/-3.9 percent, which meets the intent of the OM Code and yields an acceptable level of quality and safety.

4.0 CONCLUSION

Pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the licensees proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.

This alternative is authorized for the third 10-year interval which begins May 2, 2007, and ends May 1, 2017.

Contributor: Yuken Wong

Mr. R. J. Duncan II Shearon Harris Nuclear Power Plant Carolina Power & Light Company Unit 1 cc:

David T. Conley Mr. Robert P. Gruber Associate General Counsel II - Executive Director Legal Department Public Staff NCUC Progress Energy Service Company, LLC 4326 Mail Service Center Post Office Box 1551 Raleigh, North Carolina 27699-4326 Raleigh, North Carolina 27602-1551 Chairman of the North Carolina Resident Inspector/ Harris NPS Utilities Commission c/o U. S. Nuclear Regulatory Commission Post Office Box 29510 5421 Shearon Harris Road Raleigh, North Carolina 27626-0510 New Hill, North Carolina 27562-9998 Mr. Tony Gurley, Chair Ms. Margaret A. Force Board of County Commissioners Assistant Attorney General of Wake County State of North Carolina P. O. Box 550 Post Office Box 629 Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 Mr. Tommy Emerson, Chair Public Service Commission Board of County Commissioners State of South Carolina of Chatham County Post Office Drawer 11649 P. O. Box 87 Columbia, South Carolina 29211 Pittsboro, North Carolina 27312 Ms. Beverly Hall, Section Chief Mr. Thomas J. Natale, Manager Division of Radiation Protection Support Services N.C. Department of Environment Shearon Harris Nuclear Power Plant and Natural Resources Carolina Power & Light Company 3825 Barrett Drive P. O. Box 165, Mail Zone 1 Raleigh, North Carolina 27609-7721 New Hill, North Carolina 27562-0165 Mr. J. Paul Fulford Mr. David H. Corlett, Supervisor Manager, Performance Evaluation and Licensing/Regulatory Programs Regulatory Affairs PEB 5 Shearon Harris Nuclear Power Plant Carolina Power & Light Company Carolina Power & Light Company Post Office Box 1551 P. O. Box 165, Mail Zone 1 Raleigh, North Carolina 27602-1551 New Hill, NC 27562-0165 Mr. Eric McCartney Mr. John H. ONeill, Jr.

Plant General Manager Pillsbury Winthrop Shaw Pittman, LLP Shearon Harris Nuclear Power Plant 2300 N Street NW.

Carolina Power & Light Company Washington, DC 20037-1128 P. O. Box 165, Mail Zone 3 New Hill, North Carolina 27562-0165 Mr. Chris L. Burton Director of Site Operations Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165