ML092640690

Relief Request, PR-3 for Third 10-Year Pump and Valve Inservice Testing Program, TAC ME0820

ML092640690
Person / Time
Site:	Perry
Issue date:	10/08/2009
From:	Shawn Campbell Plant Licensing Branch III
To:	Bezilla M FirstEnergy Nuclear Operating Co
Mahoney, M NRR/DORL/LPLIII- 2 415-3867
References
TAC ME0820
Download: ML092640690 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 October 8, 2009 Mr. Mark B. Bezilla Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A290 P.O. Box 97, 10 Center Road Perry,OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO.1 - RELIEF REQUEST PR-3 FOR THIRD 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM (TAC NO. ME0820)

Dear Mr. Bezilla:

By letter to the Nuclear Regulatory Commission (NRC) dated February 18, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML0906506680),

FirstEnergy Nuclear Operating Company (FENOC), the licensee, submitted Relief Request PR-3 for the third 1O-year interval inservice testing (1ST) program at Perry Nuclear Power Plant.

The licensee requested approval to use Code Case OMN-18 of the American Society of Mechnical Engineers (AS ME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), with modifications, for certain pumps in the 1ST program at Perry. By letter dated June 9,2009 (ADAMS Accession No. ML091670464), FENOC submitted additional information pertaining to the relief request.

The NRC staff has completed its review of this relief request. The details of the NRC staff's review are included in the enclosed safety evaluation. The NRC staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the licensee-proposed alternative to use Code Case OMN-18 of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code), with modifications, for certain pumps in the 1ST program at Perry.

Use of ASME Code Case OMN-18 is authorized until such time as ASME Code Case OMN-18 is published in a future version of Regulatory Guide (RG).1.192 and incorporate by reference in 10 CFR 50.55a(b). At that time, if the licensee intends to continue implementing this ASME Code Case, it must follow all provisions of ASME Code Case OMN-18 with conditions as specified in RG 1.192 and limitations as specified in 10 CFR 50.55a(b)(4), (b)(5), and (b)(6), if any.

M. Bezilla -2 If you have any questions, please contact the Perry Project Manager, Mr. Stephen Sands, at 301-415-3154.

Sincerely,

~GtW Stephen J. Campbell, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST FOR PUMP AND VALVE INSERVICE TESTING PROGRAM FIRSTENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT, UNIT NO.1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated February 18, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML0906506680), FirstEnergy Nuclear Operating Company (FENOC),

the licensee, submitted Relief Request PR-3 for approval to use a modified Code Case OMN-18 of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (1ST) program at Perry Nuclear Power Plant (Perry). By letter dated June 9, 2009, the licensee submitted additional information pertaining to the relief request (ADAMS Accession No. ML091670464). The licensee requested approval for Perry's third 10-year 1ST interval, which begins on May 18, 2010.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, requires that 1ST of certain ASME Code Class 1,2, and 3 pumps and valves be performed at 120-month (10-year) 1ST program intervals in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Nuclear Regulatory Commission (NRC) pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(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 120-month 1ST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv), 1ST 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. 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." ASME OM code cases that are approved for use by the NRC are listed in Regulatory Guide (RG) 1.192, "Operation and Maintenance C0de Case Acceptability, ASME OM Code" dated June 2003.

The NRC's findings with respect to granting or denying the 1ST program relief request are given below:

ENCLOSURE

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3.0 TECHNICAL EVALUATION

3.1 Affected Components Pump Description Class Current Classification 1C41-C001 A&B Standby Liquid Control 2 Group B 1E12-C002A & Residual Heat Removal 2 Group A B (RHR) A and B 1E12-C002C RHRC 2 Group B 1E21-C001 Low Pressure Core 2 Group B Spray 1E22-C001 High Pressure Core 2 Group B Spray (HPCS) 1E51-C001 Reactor Core Isolation 2 Group B Cooling G41-C003A & B Fuel Pool Cooling and 3 Group A Cleanup 1P42-C001A & Emergency Closed 3 Group A B Cooling Water

'I P45-C001A & Emergency Service 3 Group A B Water 1P45-C002 HPCS Emergency 3 Group B Service Water P47-C001A & B Control Complex Chilled 3 Group A Water

'I R45-C001A, B, Fuel Oil Transfer #1 3 Group B

&C 1R45-C002A, B, Fuel Oil Transfer #2 3 Group B

&C 3.2 Applicable Code The applicable ASME OM Code edition and addenda for Perry is the 2001 Edition with Addenda through OMb-2003.

ISTB-2000, "Supplemental Definitions," defines operating criteria for designating Group A and Group B pumps.

ISTB-3000, "General Testing Requirements," and Table ISTB-3000-1, "Inservice Test Parameters," define and compare parameters (e.g., pressure flow rate, vibration) measured during Group A, Group B, and Comprehensive pump tests.

ISTB-3400, "Frequency of Inservice Tests," states that an inservice test shall be run on each pump as specified in Table ISTB-3400-1. This table requires a Group A or Group B test to be performed quarterly and a Comprehensive test to be performed biennially.

Table ISTB-3500-1, "Required Instrument Accuracy," defines the required instrument accuracy for Group A, Group B, Comprehensive, and Preservice tests.

-3 Table 18TB-51 00-1, "Centrifugal Pump Test Acceptance Criteria," defines the required acceptance criteria for Group A, Group B, and Comprehensive tests for centrifugal pumps.

Table 18TB-5200-1, "Vertical Line 8haft and Centrifugal Pumps Test Acceptance Criteria,"

defines the required acceptance criteria for Group A, Group B, and Comprehensive tests for vertical line shaft pumps.

Table 18TB-5300-2, "Reciprocating Positive Displacement Pump Test Acceptance Criteria,"

defines the required acceptance criteria for Group A, Group B, and Comprehensive tests for reciprocating positive displacement pumps.

3.3 Licensee's Basis for Requesting Relief The licensee states:

The A8ME OM Code Committee has established Code Case OMN-18, "Alternate Testing Requirements for Pumps Tested Quarterly Within +/- 20% of Design Flow." This code case has not yet been approved for use in RG 1.192, "Operation and Maintenance Code Case Acceptability, A8ME OM Code," June 2003. Although Code Case OMN-18 has not been approved for use, FENOC is proposing this alternative for Group A (and Group B re-c1assified as Group A) pumps.

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 Group A (and Group B pumps that are re-classified as Group A pumps), allows FENOC 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.

3.4 Licensee's Proposed Alternative Testing The licensee states:

FENOC proposes that in lieu of the requirements of 18TB-3400, Group A tests will be performed quarterly within +/- 20 percent of the pump design flow rate, with instrumentation meeting the instrument accuracy requirements of Table 18TB-3500-1 for the biennial Comprehensive test, and the Comprehensive test would not be required.

8pecifically,

a. Pumps tested quarterly using this alternative must be tested within +/- 20 percent of pump design flow, as is required for the biennial comprehensive test in 18TB-3300(e) and (f).

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b. The proposed alternative requires the accuracy of instruments used during quarterly Group A tests to meet the more accurate pressure and differential pressure requirements listed for the Comprehensive test in Table IST8-3500-1 (an accuracy improvement from +/- 2 percent to +/- 0.5 percent). Consistent use of these more accurate instruments during each quarterly test provides for improved Group A pump performance trend data evaluation.

c. Pumps that would normally be categorized as Group 8 pumps, but are re categorized as Group A, may be tested according to the provisions of this alternative.

As a result of this re-categorization from Group 8 to Group A, per Table IST8-3000-1, additional data must be obtained quarterly rather than once every 2 years on the test parameters of:

• Discharge pressure (for the Standby Liquid Control positive displacement pumps), and

• Vibration (for all the affected pumps).

d. Use of this alternative provides for consistent acceptance criteria for pump flow and differential pressure tests. FENOC will consistently utilize the Group A test acceptance criteria in Tables IST8-51 00-1, IST8-5200-1, and IST8-5300-2 for pump tests rather than having to utilize the comprehensive test criterion for one biennial test.

The licensee stated in a letter dated June 9, 2009:

8ased on recent guidance from the ASME OM Code Committee regarding application of Code Case OMN-18, the update of the 1ST Program for the third ten-year interval will reflect a more limiting upper bound Acceptable Range value of 1.06 versus 1.10 for flow and differential pressure. Values above 1.06 would be considered to be in the Required Action Range. This tightened Acceptable Range, in conjunction with using more accurate pressure instruments during testing (an accuracy improvement from +/- 2 percent to +/- 0.5 percent), provides more consistent trend results when comparing sUbsequent tests or test results in aggregate. Due to the improved accuracy, consistent testing methodology, and the addition of quarterly vibration monitoring, deviations in actual pump performance indicative of impending degradation are more easily recognized during quarterly performance trending activities. Additionally, declaring pumps inoperable for reasons other than actual equipment degradation can be avoided.

As detailed in IST8-5100-1, the ASME Code does not require utilization of an Alert Range for quarterly pump tests. As stated above, the proposed quarterly testing methodology is expected to more accurately identify deviations and trends in actual pump performance without relying on the use of a specified Alert Range.

-5 3.5 NRC Staff Evaluation The licensee is proposing to re-c1assify the Group 8 pumps listed in Section 3.1 above as Group A pumps, and perform 1ST for all the pumps listed in Section 3.1 in accordance with modified Group A test procedure.

The ASME OM Code requires that for Group 8 pumps, a Group 8 test is performed every quarter, and a comprehensive test is performed biennially. The Group 8 test is performed within +/- 20 percent of the pump design flow rate (if practicable), the pressure instrument accuracy is +/- 2 percent, and the upper limit for the Acceptable Range for flow rate or differential pressure is 110 percent of the reference values. The comprehensive test is performed within

+/- 20 percent of the pump design flow rate, the pressure instrument accuracy is +/- 0.5 percent, and the upper limit of the Acceptable Range for flow rate and differential pressure is 103 percent of the reference values. Vibration monitoring is only performed during the comprehensive test.

The licensee proposes that for Group A pumps, a modified quarterly test be performed every quarter, and the biennial comprehensive test is not required. The modified Group A quarterly test would be performed within +/- 20 percent of the pump design flow rate, using the more accurate pressure instrumentation that is required for a comprehensive test (+/- 0.5 percent versus +/- 2 percent). This modified quarterly test would replace the comprehensive test. The Acceptable Range for the modified Group A quarterly test is tighter than the range for the Group A quarterly test.

The licensee is proposing to perform a modified Group A pump test every quarter and not perform a comprehensive pump test. The licensee will use a more limiting upper bound of 106 percent for the Acceptable Range for flow and differential pressure in lieu of 110 percent that is required by the OM Code for Group A tests. This proposed upper bound of 106 percent is greater than the upper bound of 103 percent for the biennial comprehensive pump test. The pumps that will be reclassified from Group 8 to Group A will now have vibration monitoring performed quarterly. The OM Code does not require vibration monitoring for Group 8 pump tests. All of the pump tests will be performed with pressure gauges with 0.5 percent accuracy.

For the pumps that are currently classified as Group A, the elimination of the comprehensive pump test (with its more limiting Acceptable Range upper bound of 103 percent) is compensated for by using more accurate pressure gauges on every quarterly test. This will provide for better trending of pump performance. Instead of performing seven tests with pressure gauges with 2 percent accuracy, and then performing the eighth test with pressure gauges with 0.5 percent accuracy, all eight tests will be performed with the same 0.5 percent accurate gauges. For the Group 8 pumps that will be re-c1assified as Group A pumps, the elimination of the comprehensive pump test is compensated for by using a tighter Acceptance Range on the quarterly tests, by using more accurate pressure gauges on every quarterly test, and by performing vibration monitoring on every quarterly test. This will provide for better trending of pump performance. Instead of performing seven tests with pressure gauges with 2 percent accuracy, with no vibration monitoring, and then performing the eighth test with pressure gauges with 0.5 percent accuracy, all eight tests will be performed with pressure gauges with the same 0.5 percent accuracy, all eight tests will include vibration monitoring, and seven of the eight tests will have a tighter Acceptable Range. The proposed alternative would provide reasonable assurance of the operational readiness of the pumps listed in Section 3.1.

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4.0 CONCLUSION

Based on the above evaluation, the NRC staff concludes that the licensee's proposed alternative to the Code Group A and Group B testing requirements for the pumps listed in section 3.1 above are authorized pursuant to 10 CFR 50.55a(a)(3)(i), on the basis that the alternative provides an acceptable level of quality and safety. The licensee's proposed alternative provides reasonable assurance of the operational readiness of the pumps. The alternative is authorized for the third 10-year 1ST program interval.

Use of ASME Code Case OIVlN-18 is authorized until such time as ASME Code Case OMN-18 is published in a future version of RG.1.192 and incorporate by reference in 10 CFR 50.55a(b).

At that time, if the licensee intends to continue implementing this ASME Code Case, it must follow all provisions of ASME Code Case OMN-18 with conditions as specified in RG 1.192 and limitations as specified in 10 CFR 50.55a(b)(4), (b)(5), and (b)(6), if any.

Principal Contributor: RWolfgang, NRR Date: October 8, 2009

M. Bezilla -2 If you have any questions, please contact the Perry Project Manager, Mr. Stephen Sands, at 301-415-3154.

Sincerely, IRA!

Stephen J. Campbell, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

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