ML073040276

Request for Additional Information Forth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Tac Nos. MD5998 Through MD6011)

ML073040276
Person / Time
Site:	Calvert Cliffs
Issue date:	11/20/2007
From:	Pickett D NRC/NRR/ADRO/DORL/LPLI-1
To:	Spina J Calvert Cliffs
Pickett D, NRR/DORL, 415-1364
References
TAC MD5998, TAC MD5999, TAC MD6000, TAC MD6001, TAC MD6002, TAC MD6003, TAC MD6004, TAC MD6005, TAC MD6006, TAC MD6007, TAC MD6008, TAC MD6009, TAC MD6010, TAC MD6011
Download: ML073040276 (6)

Text

November 20, 2007 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: FOURTH TEN-YEAR INSERVICE TEST PROGRAM FOR SAFETY-RELATED PUMPS AND VALVES

- CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - (TAC NOS. MD5998 THROUGH MD6011)

Dear Mr. Spina:

By letter dated July 2, 2007, Calvert Cliffs Nuclear Power Plant, Inc., submitted the Fourth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves. Included in this submittal were requests for relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code. The Nuclear Regulatory Commission staff has identified additional information that will be required in order to complete our review. Our request for additional information is included in the enclosure. Based on discussions with your staff, it is our understanding that you plan to respond to these questions within 60 days of receipt of this letter.

Please contact me at 301-415-1364 if you have any questions.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated cc w/encl: See next page

ML073040276 OFFICE PM/LPL1-1 LA/LPL1-1 BC/CPTB BC/LPL1-1 NAME DPickett SLittle JMcHale as MKowal signed on 11/19/07 DATE 11/19/07 10/ 22 /07 11/20/07 REQUEST FOR ADDITIONAL INFORMATION (RAI)

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 FOURTH 10-YEAR INTERVAL INSERVICE TESTING (IST) PROGRAM DOCKET NOS. 50-317 AND 50-318

Reference:

Letter from Constellation Energy, to Nuclear Regulatory Commission (NRC),

"Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Docket Nos. 50-317 and 50-318, Fourth 10-year Inservice Testing (IST) Program, dated July 2, 2007.

1. Relief Request GA-RR-01 RAI GA-RR-01-01 Please confirm that the modifications and limitations in 10 CFR 50.55a(b)(3)(i), (ii), (v),

and (vi) will be applied to the Fourth 10-Year Interval.

2. Relief Request GV-RR-01 RAI GV-RR-01-01 Please verify that water at ambient temperature is the test medium that will be used to setpoint test the relief valves in the scope of this relief request. Describe the test medium and how the test medium is maintained at ambient temperature if a test medium other that water is used to setpoint test the valves in the scope of this relief request.

3. Relief Request CVC-RR-01 RAI CVC-RR-01-01 The NRC has learned that, due to technology advancement and research work performed in the field of instrumentation, vibration-measuring transducers meeting the Code provisions can be easily procured from various suppliers at a reasonably low cost.

The NRC also presented a paper on Pumps Vibration Measuring Instruments (Transducers) Issue during the Ninth NRC/ASME Symposium on Valve and Pump Testing in July 2006. [NUREG/CP-0151, Vol. 6, July 2006, Proceeding of the Ninth NRC/ASME Symposium on Valve and Pump Testing (ML072700042).] Please provide and discuss reasons for not meeting the Code requirement.

RAI CVC-RR-01-02 In the section entitled Basis, the licensee did not mention any hardship and/or reason for not using or installing the Code-required vibration-measuring transducers with specified ranges from one-third minimum pump shaft rotational speed to at least 1000 Hz.

The licensee did not provide sufficient information on the basis for the hardship or unusual difficulty associated with complying with the Code. Please provide this information

4. Relief Request SI-RR-01 General Comment This relief request consists of two parts: (1) Relief from paragraph ISTB-1400(b); and (2)

Relief from the vibration requirements of paragraph ISTB-5121(e), and Table STB-5121-1.

In the section entitled Alternative Testing, the licensee states that low-pressure safety injection (LPSI) pumps will be tested as stand-by pumps (Group B) during Modes 1-4 and continuously operating pumps (Group A) during Modes 5-6. In Modes 5-6, the comprehensive pump test may be substituted for a quarterly Group A test that comes due during a mid-cycle cold shutdown period.

Please note that the OM Code paragraph ISTB-1400(b) states that "a pump that meets both Group A and Group B pump definitions shall be categorized as a Group A pump."

Therefore, the NRC staff is not in a position to authorize the same pump (LPSI pump) to be classified as Group A and Group B during different modes of operation. Based on the licensees description, the LPSI pumps should be considered as a Group A pump.

RAI SI-RR-01-01 In the section entitled Alternative Testing, under LPSI Pump Bearing Acceptance Criteria During Low-Flow Testing, the licensee states that vibration acceptance criteria shall be used for any low-flow LPSI pump post-maintenance (Group A) testing done during cold shutdown periods. Whereas, second paragraph on page 2 of 9 states that the LPSI pumps are also tested at a substantial flow rate (3500 gpm) during every refueling outage, as well as during planned and unplanned cold shutdown periods when plant conditions and circumstances permit.

Based on the general comment above, the licensee needs to revise the relief request to categorize these LPSI pumps as Group A pumps, and to perform vibration measurements (1) during Group A test (at low-flow or full flow); and (2) during the comprehensive test (at full flow or large flow).

RAI SI-RR-01-02 In the section entitled Basis, under Minimum Pump Run-Time (page 2 of 9), the licensee states that as Group B pumps, the 2-minute minimum pump run-time for quarterly tests is also eliminated. The licensee is requested to update this information, when LPSI pumps are categorized as Group A pumps as specified in the general comments above.

RAI SI-RR-01-03 In the section entitled Alternative Testing, under Item 2, LPSI Pump Bearing Acceptance Criteria During Low-Flow Testing (page 7 of 9), the licensee states that vibration acceptance criteria shall be used for any low-flow LPSI pump post-maintenance (Group A) testing done during cold shutdown periods. Please explain how post-maintenance testing at low-flow provides confidence for operational readiness of LPSI pump at full flow.

RAI SI-RR-01-04 In the section entitled Alternative Testing, under Item 2, LPSI Pump Bearing Acceptance Criteria During Low-Flow Testing (pages 7 and 8 of 9), the licensee provides the maximum acceptable range of vibration V 0.63; however the typical value/range values contained in Table 1 and Table 2, are lower than 0.49 ips. Please explain and clarify the use of (higher) acceptable vibration value of 0.63 ips as an alternative. Note: By categorizing LPSI pump as Group A pump as suggested in the general comment, the measured vibration values during Group A and comprehensive tests and their acceptance values may be different.

Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:

Mr. Michael J. Wallace, President Regional Administrator, Region I Constellation Energy Nuclear Group, LLC U.S. Nuclear Regulatory Commission 750 East Pratt Street, 18th Floor 475 Allendale Road Baltimore, MD 21202 King of Prussia, PA 19406 Mr. John M. Heffley, Senior Vice President Ms. Kristen A. Burger, Esquire and Chief Nuclear Officer Maryland People's Counsel Constellation Energy Nuclear Generation 6 St. Paul Centre Group Suite 2102 111 Market Place Baltimore, MD 21202-1631 Baltimore, MD 21202 Ms. Patricia T. Birnie, Esquire President Co-Director Calvert County Board of Maryland Safe Energy Coalition Commissioners P.O. Box 33111 175 Main Street Baltimore, MD 21218 Prince Frederick, MD 20678 Mr. Roy Hickok Mr. Carey Fleming, Esquire NRC Technical Training Center Sr. Counsel - Nuclear Generation 5700 Brainerd Road Constellation Energy Nuclear Group, LLC Chattanooga, TN 37411-4017 750 East Pratt Street, 17th floor Baltimore, MD 21202 Mr. Louis S. Larragoite Manager - Nuclear Licensing Mr. Jay S. Gaines Constellation Energy Nuclear Generation Director, Licensing Group Calvert Cliffs Nuclear Power Plant 111 Market Place, 2nd Floor 1650 Calvert Cliffs Parkway Baltimore, MD 21202 Lusby, MD 20657-4702 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. R. I. McLean, Manager Nuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)

Tawes State Office Building Annapolis, MD 21401