ML082770229

Request for Additional Information, Pump and Valve Inservice Testing Program for Next 10-Year IST Interval

ML082770229
Person / Time
Site:	Nine Mile Point
Issue date:	10/14/2008
From:	Richard Guzman Plant Licensing Branch 1
To:	Polson K Nine Mile Point
Guzman R, NRR/DORL, 415-1030
References
TAC MD9202, TAC MD9203
Download: ML082770229 (4)

Text

October 14, 2008 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NOS. 1 AND 2 (NMP 1 AND 2), PUMP AND VALVE INSERVICE TESTING (IST) PROGRAM FOR 10-YEAR IST INTERVAL (TAC NOS.

MD9202 AND MD9203)

Dear Mr. Polson:

By letter dated June 30, 2008, Nine Mile Point Nuclear Station, LLC requested approval of several relief requests prior to the start of the next NMP 1 and 2 10-year IST intervals, which will both begin on January 1, 2009.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in that letter and has determined that additional information is needed to complete its review.

Enclosed is the NRC staffs request for additional information (RAI). The RAI was discussed with your staff on October 2, 2008, and it was agreed that your response would be provided within 30 days from the date of this letter.

Sincerely,

/RA/

Richard V. Guzman, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosure:

As stated cc w/encl: Distribution via Listserv

October 14, 2008 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NOS. 1 AND 2 (NMP 1 AND 2), PUMP AND VALVE INSERVICE TESTING (IST) PROGRAM FOR 10-YEAR IST INTERVAL (TAC NOS.

MD9202 AND MD9203)

Dear Mr. Polson:

By letter dated June 30, 2008, Nine Mile Point Nuclear Station, LLC requested approval of several relief requests prior to the start of the next NMP 1 and 2 10-year IST intervals, which will both begin on January 1, 2009.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in that letter and has determined that additional information is needed to complete its review.

Enclosed is the NRC staffs request for additional information (RAI). The RAI was discussed with your staff on October 2, 2008, and it was agreed that your response would be provided within 30 days from the date of this letter.

Sincerely,

/RA/

Richard V. Guzman, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrPMRGuzman RidsNrrDciCptb RidsNrrAcrsAcnw&mMailCenter LPLI-1 R/F RidsNrrLASLittle RidsOGCRp RidsRgn1MailCenter WPoertner Accession Number: ML082770229

• RAI provided by email. No substantial changes made.

OFFICE LPLI-1/PM LPLI-1/LA CPTB/BC LPLI-1/BC NAME RGuzman SLittle JMchale* MKowal DATE 10/14/08 10/14/08 9/23/08 10/14/08 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION NINE MILE POINT NUCLEAR STATION, UNIT NOS. 1 AND 2 (NMP 1 AND 2)

PUMP AND VALVE INSERVICE TESTING (IST) PROGRAM FOR 10-YEAR IST INTERVAL DOCKET NOS. 50-220 AND 50-410 The Nuclear Regulatory Commission (NRC) staff has reviewed the Nine Mile Point Nuclear Station submittal dated June 30, 2008. The NRC staff has determined that additional information requested below will be needed to complete its review.

Relief Request CRD-VR-01 (Unit 1) 1.a. The relief request discusses various flow paths associated with the air supply to the scram discharge volume vent and drain valves. Please provide a simplified schematic of the referenced flow paths.

1.b. The relief request states that the test solenoid flow path is not a fixed resistance system and can result in inaccurate stroke-time measurements. Please provide valve stroke-time data indicating the variation in quarterly stroke time measurements observed as a result of using the test solenoid flow path and discuss the corrective action consequences that resulted from the inaccurate stroke-time measurements.

Relief Request CTNH-202-VR-02 (Unit 1)

2. The relief request states that the valves stroke in less than 2 seconds and that a limiting value of 2 seconds is assigned to the group. Subsequent to this statement, the relief request states that if the slowest valve exceeds the acceptance criteria (50% of the group reference value or 2 second limiting value) the group is declared inoperable. The American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) states that valves that stroke in less than 2 seconds may be exempted from ISTC 5152(b) and that in such cases the maximum limiting stroke time shall be 2 seconds. Please clarify the acceptance criteria to be utilized during valve stroke-time testing (2 seconds versus 50% of the group reference value).

Relief Request RBCLC-PR-01 (Unit 1) 3.a. Please discuss the feasibility of installing permanent or temporary flow instrumentation in the pump discharge lines to allow compliance with the ASME OM Code requirements.

3.b. The use of analytical methods to determine individual pump flow rates has been authorized by the NRC in cases where single pump operation is not attainable during normal operation and individual pump flow instrumentation is not installed. Please discuss the feasibility of utilizing analytical methods to determine individual pump flow rates.

Enclosure

3.c. Please discuss the feasibility of establishing hydraulic performance acceptance criteria based on dual pump operation.

Relief Request MSS-VR-01 (Unit 2) 4.a. The ASME OM Code has developed a code case addressing test frequencies of ASME Class 1 pressure relief/safety valves. The code case provides a 72-month test interval with a 6-month grace period to accommodate extended shutdown periods provided certain requirements are implemented. One of the requirements is that each valve is disassembled and inspected after as-found set pressure testing to verify that parts are free of defects resulting from time related degradation or service induced wear. Based on this inspection, the owner shall determine the need for additional inspections or testing to address any generic concerns. Please discuss the feasibility of implementing the criteria established by the ASME OM Code for extending the safety relief valve (SRV) test interval beyond 5 years.

4.b. The relief request states that 5 as-found setpoint tests exceeded the Code tolerance of plus or minus 3%. Please provide the as-found setpoint data for the five failed tests, identify the cause of the failure if known, and identify any corrective actions taken to improve valve performance following the failed tests.

4.c. Please provide a summary of the SRV testing conducted for the last 5 refueling outages (valve, date tested, as-found setpoint, interval between previous test).