ML101340691
| ML101340691 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/10/2010 |
| From: | Shawn Campbell Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co |
| DiFrancesco N, NRR/DORL/LPL3-2, 415-1115 | |
| References | |
| TAC ME1546, TAC ME1705, TAC ME1709 | |
| Download: ML101340691 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 10, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 SUB~IECT:
CLINTON POWER STATION, UNIT NO.1 - SAFETY EVALUATION OF RELIEF REQUEST NOS. 2201, 2202, AND 3201, FOR THE THIRD 10-YEAR INSERVICE TESTING INTERVAL (TAC NOS. ME1546, ME1705, ME1709)
Dear Mr. Pacilio:
By letter dated June 16, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091690167), as supplemented by letter dated March 31, 2010 (ADAMS Accession No. ML100900387), Exelon Generation Company, LLC (EGC, the licensee), submitted Relief Requests (RR) Nos. 2201,2202, and 3201 to the Nuclear Regulatory Commission (NRC) for the use of alternatives to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements for the third 10-year inservice testing (1ST) program interval at Clinton Power Station (CPS), Unit NO.1.
Specifically, for RR Nos. 2201 and 3201, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i), the licensee requested to use the proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety. For RR 2202, pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative on the basis that complying with current ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The NRC staff has determined that proposed alternatives RR Nos. 2201 and 3201 provide an acceptable level of quality and safety and that proposed alternative RR No. 2202 provides reasonable assurance that the main steamline safety relief valves are operationally ready.
Accordingly, the NRC staff concludes that the licensee had adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(3)(i) for alternative RR Nos. 2201 and 3201 and 10 CFR 50.55a(3)(ii) for alternative RR No. 2202. Therefore, the NRC authorizes alternative RR Nos. 2201, 2202, and 3201 at CPS for the third 10-year 1ST program interval, which begins on June 15, 2010, and ends on June 14, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.
M. Pacilio
- 2 A copy of the Safety Evaluation is enclosed. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Project Manager, Nicholas J. DiFrancesco, at 301-415-1115.
~6'~
Stephen J. Campbell, Branch Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461
Enclosure:
Safety Evaluation 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 REQUESTS NOS. 2201, 2202, AND 3201 REGARDING COMPONENT TESTING OF ASME CLASS 1, 2, AND 3 MOTOR-OPERATED VALVES, ASME CLASS 1 MAIN STEAMLINE SAFETY RELIEF VALVES, AND ASME CLASS 2 WATERLEG PUMPS EXELON GENERATION COMPANY, LLC CLINTON POWER STATION, UNIT NO.1 DOCKET NO. 50-461
1.0 INTRODUCTION
By letter dated June 16, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091690167), as supplemented by letter dated March 31, 2010 (ADAMS Accession No. ML100900387), Exelon Generation Company, LLC (EGC, the licensee), submitted Relief Requests (RR) Nos. 2201, 2202, and 3201 to the Nuclear Regulatory Commission (NRC) the use of alternatives to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements for the third 10-year inservice testing (1ST) program interval at Clinton Power Station (CPS), Unit NO.1.
Specifically, for RR 2201 and RR 3201, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i), the licensee requested to use the proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety. For RR 2202, pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative on the basis that complying with current ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
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 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
- 2 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 Code Case Acceptability, ASME OM Code" dated June 2003.
The CPS third 10-year 1ST interval begins on June 15,2010, and ends on June 14, 2020. The program was developed in accordance with the 2004 Edition of the ASME OM Code.
3.0 TECHNICAL EVALUATION
The NRC's findings with respect to authorizing the proposed alternatives to the ASME OM Code are given, as follows:
3.1 The Licensee's Alternative RR No. 2201 ISTA-3130(b), "Application of Code Cases," states that code cases be applicable to the edition and addenda specified in the test plan.
ISTC-3100(a), "Preservice Testing," states that any valve that has undergone maintenance that could affect its performance after the preservice test be tested in accordance with ISTC-3310, "Effects of Valve Repair, Replacement, or Maintenance on Reference Values."
ISTC-3310 requires that a new reference value shall be determined or the previous reference value reconfirmed by an 1ST after a valve has been replaced, repaired, or has undergone maintenance that could affect the valve's performance.
ISTC-3510, "Exercising Test Frequency," requires that active Category A and Category B, motor-operated valves (MOVs) shall be exercised nominally every 3 months.
ISTC-3521, "Exercising Requirements - Category A and Category B Valves," requires that Category A and B MOVs be exercised during cold shutdowns if it is not practicable to exercise the valves at power, or that active Category A and B MOVs be exercised during refueling outages if it is not practicable to exercise the valves during cold shutdowns.
ISTC-3700, "Position Verification Testing," states that valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated.
ISTC-5121 (a), "Motor-Operated Valves-Valve Stroke Testing," states that active valves shall have their stroke times measured when exercised in accordance with ISTC-3500, "Valve Testing Requirements."
- 3 The licensee proposes to adopt the requirements of Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing on Certain Electric Motor-Operated Valve Assemblies in Light Water Reactor Power Plants," Revision 1, as revised in the 2006 Addenda to the 2004 Edition of the ASME OM Code in lieu of the performance of stroke time testing and position indication testing as described by Section ISTC of the 2004 Edition of the ASME OM Code. The provision to allow for motor control center (MCC) testing, as contained in Section 6.1, "Acceptance Criteria", of the ASME Code Case OMN-1, is excluded from this request. The licensee is proposing this alternative testing for all ASME Class 1, 2, and 3 MOVs currently included in the CPS MOV Testing Program.
The NRC amended its regulations to incorporate by reference the 2004 Edition of the ASME OM Code on September 10, 2008. In the latest 10 CFR 50.55a(b), it states in part, that RG 1.192, "Operating and Maintenance Code Case Applicability, ASME Code," has been approved for incorporation by reference. In RG 1.192, as stated in Table 2, "Conditionally Acceptable OM Code Cases," the licensee may use the alternative rules of ASME Code Case OMN-1, Revision 0, when applied in conjunction with the provisions for leakage rate testing in ISTC-3600, "Leak Testing Requirements," and must apply all the stated provisions.
This conditional acceptance of OMN-1, Revision 0, per RG 1.192 is applicable in lieu of the provisions for stroke-time testing in Subsection ISTC of ASME OM Code-2004. Since RG 1.192 was last published, Code Case OMN-1 has been updated/modified to address and incorporate all of the original RG 1.192 listed provisions. The licensee proposes to adopt the requirements of Code Case OMN-1, Revision 1, as presented in the ASME OMb Code, "Addenda to ASME OM Code-2004, Code for Operation and Maintenance of Nuclear Power Plants," for 2006, in lieu of the performance of stroke time testing and position indication testing as described by Subsection ISTC of the 2004 Edition of the ASME OM Code.
The CPS MOV testing program was developed as a result of NRC GL 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," and GL 96-05, "Periodic Verification of Design Basis Capability of Safety-Related Motor-Operated Valves," utilizing Topical Report MPR-1807, "Joint BWR, Westinghouse and Combustion Engineering Owners Group Program on Motor Operated Valve Periodic Verification," Revision 2. CPS is currently utilizing MPR-2524-A, "Joint Owners' Group Motor-Operated Valve Periodic Verification Program Summary," (November 2006) as guidance for the MOV program. The adoption of Code Case OMN-1 will consolidate testing between the station's 1ST and MOV programs.
3.1.1
NRC Staff Evaluation
Section 4.2.5, "Alternatives to Stroke-Testing," of NUREG-1482, states in part that as an alternative to MOV stroke-time testing, ASME developed Code Case OMN-1, which provides periodic exercising and diagnostic testing for use in assessing the operational readiness of MOVs, may be used. Section 4.2.5 recommends that licensees implement ASME Code Case OMN-1 as an alternative to the MOV stroke-time testing. The periodic exercising and diagnostic testing requirements in Code Case OMN-1 provide an improved method for assessing the operational readiness of MOVs.
Application of code cases is addressed in 10 CFR 50.55a(b)(6) through references to RG 1.192, which lists acceptable and conditionally acceptable code cases for implementation in 1ST programs. RG 1.192, Table 2, conditionally approves the use of Code Case OMN-1 and states that the code case is applicable to the 2000 Addenda and earlier editions and addenda of the Code. There is no technical reason for prohibiting the use of Code Case OMN-1 with the 2004 Edition of the Code. This is consistent with the NRC staff position in NUREG-1482, and
- 4 RG 1.192. Code Case OMN-1 was revised in the 2006 Addenda to the ASME OM Code. Most of the revisions are enhancements; however, there was one significant revision in Section 6.1 that states that MCC testing is acceptable if correlation with testing at the MOV has been established. MCC diagnostic testing was not specifically addressed in the original version of OMN-1. Historically, diagnostic testing of MOVs has been conducted using at-the-valve tests.
The ASME OM Code does not address a method for the correlation of MCC based measurements to diagnostic test measurements conducted at-the-valve. EGC has excluded the provision for MCC testing from this relief request. Therefore, the MCC test method will not be used as an acceptance criterion to determine the operational readiness of MOVs.
The NRC staff finds that the 2006 Addenda of Code Case OMN-1 provides an acceptable level of quality and safety for testing of MOVs and is an acceptable alternative for use in CPS's 1ST Program, except for Section 6.1 of this Code Case.
3.1.2 Conclusion Based on the above evaluation, the NRC staff concludes that the licensee's proposed alternative to the Code MOV testing, in accordance with Code Case OMN-1, as revised in the 2006 Addenda to the ASME OM Code, with the exception that the MCC test method will not be used, is authorized pursuant to 10 CFR 50.55a (a)(3)(i) on the basis that the alternative provides an acceptable level of quality and safety. This alternative is authorized for the third 10-year 1ST interval, which begins on June 15,2010, and ends on June 14, 2020.
3.2 The Licensee's Alternative RR No. 2202 ASME OM Code Mandatory Appendix I, Paragraph 1-1320(a), "Test Frequencies, Class 1 Pressure Relief Valves," 2004 Edition requires that Class 1 pressure relief valves be tested at least once every 5 years. The licensee proposed an alternative test interval to the 5-year test interval requirement in Mandatory Appendix I, Section 1-1320(a)for CPS main steam safety relief valves (SRVs) 1B21-F041 A, 1B21-F041B, 1B21-F041 C, 1B21-F041 D, 1B21-F041 F, 1B21-F041G, 1B21-F041L, 1B21-F047A, 1B21-F047B, 1B21-F047C, 1B21-F047D, 1B21 F047F, 1B21-F051B, 'IB21-F051C, 'IB21-F051D, and 1B21-F051G.
The SRVs are Dikkers Model G-471 design. The licensee proposed in RR 2202 to test the SRVs on a 72-month plus a six-month grace period interval. The licensee stated that it would refurbish each SRV prior to the start of the extended test interval. Critical components will be inspected for wear and defects, and critical dimensions will be measured. Worn, defective, and out-of-specification parts will be repaired or replaced.
Specifically, pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed the alternative on the basis that complying with the ASME OM Code 5-year SRV test interval would result in hardship or unusual difficulty due to unnecessary personnel radiation exposure without a compensating increase in the level of quality and safety. A minimum of 24 SRVs have to be removed and tested over three refueling outages on a 5-year test interval. Extending the test interval to 72 months with a 6-month grace period would reduce the minimum number of SRVs tested over three refueling outages by eight. The licensee estimates that removal and replacement of an additional eight SRVs over three refueling outages would result in additional radiation exposure of approximately 5.6 person-rem if the proposed alternative is not authorized. The licensee also indicated that as-found SRV set pressure test data demonstrates the current maintenance practices have been effective.
- 5 3.2.1
NRC Staff Evaluation
The ASME published Code Case OMN-17, "Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves," in the 2009 Edition of the OM Code. Code Case OMN-17 allows extension of the test frequency for SRVs from 5 years to 72 months with a 6-month grace period. The code case imposes a special maintenance requirement to disassemble and inspect each SRV to verify that parts are free from defects resulting from the time-related degradation or maintenance-induced wear prior to the start of the extended test interval. The NRC staff recognizes that although Mandatory Appendix I, Paragraph 1-1320(a) of the ASME OM Code does not require that SRVs be routinely refurbished when tested on a 5-year interval, routine refurbishment provides additional assurance that set-pressure drift during subsequent operation is minimized. Consistent with the special maintenance requirement in Code Case OMN-17, the licensee stated that each SRV will be refurbished prior to the start of each 72-month test interval. Critical components will be inspected for wear and defects, and the critical dimensions will be measured during the inspection. Components will be reworked to within the specified tolerance or replaced if found to be worn or outside of specified tolerances.
The NRC staff finds that extending the test interval for main steamline SRVs 'IB21-F041 A,
'IB21-F041 B, 1B21-F041C, 1B21-F041 D, 'IB21-F04'1 F, 1B21-F041G, 1B21-F041 L, 1B21 F047A, 1B21-F047B, 1B21-F047C, 1B21-F047D, 1B21-F047F, 1B21-F051 B, 1B21-F051 C, 1B21-F051 D, and 1B21-F051 G to 72 months with a 6-month grace period is acceptable.
Extending the test interval should not adversely affect the operational readiness of the SRVs because the SRVs will be disassembled and inspected prior to the start of the extended test interval. This additional maintenance is beyond what is required by OM Code Mandatory Appendix I when testing SRVs on a 5-year interval, and justifies extension of the test interval for up to 72 months plus a 6-month grace period while providing an acceptable level of quality and safety. Extending the test interval will also reduce radiation exposure due to the reduction in the number of SRVs that are removed and replaced during the third 1O-year inservice test interval.
EGC notes that this change will reduce station radiation exposure by approximately 5.6 person rem over a period of three refueling outages.
3.2.2 Conclusion As set forth above, the !\\IRC staff determines that the alternative in RR 2202 is acceptable for CPS main steam SRVs 1B21-F041A, 1B21-F041B, 'IB21-F041C, 'IB21-F041D, 1B21-F041F, 1B21-F041G, 1B21-F041L, 1B21-F047A, 1B21-F047B, 1B21-F047C, 1B21-F047D, 1B21-F047F, 1B21-F051B, 1B21-F051C, 1B21-F051D, and 1B21-F051G. Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the OM Code requirements.
Therefore, the NRC staff authorizes the alternative in RR 2202 for main steam SRVs 1B21-F041A, 1B21-F041 B, 1B21-F041 C, 1B21-F041D, 1B21-F041 F, 1B21-F041 G, 1B21-F041L, 1B21-F047A, 1B21-F047B, 1B21-F047C, 1B21-F047D, 1B21-F047F, 1B21-F051B, 'IB21-F051C, 'IB21-F051D, and 1B21-F051G at CPS for third 10-year 1ST program interval which begins on June 15,2010, and ends on June 14, 2020.
3.3 The Licensee's Alternative RR No. 3201 ISTB-3400, "Frequency of Inservice Tests," requires that an inservice test shall be run on each pump as specified in Table ISTB-3400-1. Table ISTB-3400-1 specifies that a Group A pump test shall be performed quarterly.
- 6 ISTB-3300(e)(2), "Reference Values," states that reference values shall be established within
+/- 20 percent of pump design flow for the Group A test, if practicable. If not practicable, the reference point flow rate shall be established at the highest practical flow rate.
ISTB-5121, "Group A Test Procedure," requires that Group A tests shall be conducted with the pump operating at a specified reference point. ISTB-5121(b) requires that the resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value.
The licensee requested relief from the requirements of ISTB-3400, ISTB-3300(e)(2), and ISTB 5121 for quarterly Group A testing for the following pumps:
. ti Pump Descnouon CI C t ass a egory j1E12-C003 Residual Heat Removal 2
Group A System (RHR) Loop B/C I
Waterleg Pump 1E21-C002 Low Pressure Core Spray 2
Group A (LPCS) and RHR A Waterleg Pump 1E51-C003 Reactor Core Isolation 2
Group A Cooling (RCIC) Waterleg Pump The waterleg pumps are continuously-running pumps whose safety function is to keep their supported system's pump discharge header piping in a filled condition. This function prevents water hammer and the delay of flow to the reactor upon the supported system's pump start.
The actual output and hydraulic performance of the waterleg pumps are not critical to their safety function, as long as the waterleg pumps are capable of maintaining their associated system's pump discharge full of water. The amount of flow delivered by each waterleg pump is dependent upon each supported system's leakage rate.
LPCS and RHR A waterleg pump 1E21-C002 services the LPCS system piping and Loop A of the RHR system. RHR Loop B/C waterleg pump 1E12-C003 services RHR loops Band C.
Traditional testing of these waterleg pumps requires declaring portions of the RHR and LPCS systems inoperable. Traditional testing of RCIC waterleg pump 'IE51-C003 requires the RCIC system to be declared inoperable due to the system configuration changes that are necessary to perform the surveillance test.
The suction pressure for these waterleg pumps is essentially constant because the suppression pool and the RCIC storage tank (suction water sources) levels over the past year were maintained within a 5-inch band. This allows the waterleg pumps' readiness to be confirmed by monitoring the supported system's main header pressure. Quarterly monitoring of discharge pressure and bearing vibration in accordance with Position 9, "Pump Testing Using Minimum Flow Return Lines With or Without Flow Measuring Devices," of GL 89-04, "Guidance On Developing Acceptable Inservice Testing Programs," dated April 3, 1989, will be performed to monitor for pump degradation and to assess pump performance. The flow rate for each of these waterleg pumps varies little during normal operation, and testing of these pumps at a predetermined reference point as described in ISTB-5121 (b) is not necessary to detect pump degradation or to establish that these pumps can perform their safety function. The rated flows
- 7 for pumps 1E12-C003, 1E21-C002, and 1E51-C003 are 43 gallons per minute (gpm), 43 gpm, and 50 gpm respectively.
Instead of performing a quarterly Group A test, the CPS waterleg pumps will be monitored for degradation on a quarterly basis by observing pump discharge pressure and bearing vibration during normal operating conditions. This testing will be performed without varying the resistance of the system as discussed in ISTB-5121(b). These parameters will then be evaluated and trended to assess the pumps' performance. The measurement and trending of these parameters under these conditions will provide satisfactory indication of the operational readiness of the pumps and detect degraded performance. These waterleg pumps will be full flow tested every 24 months in conjunction with the comprehensive pump test performed in accordance with the requirements specified in ISTB-5123, "Comprehensive Test Procedure."
In addition to this quarterly testing, each of these waterleg pump's supported system pump discharge headers have sensors that continuously monitor header pressure, and provide an alarm in the main control room when their low pressure setpoint is reached. This will provide indication that the associated waterleg pump is no longer performing its safety function, and allow CPS operators to respond accordingly to station procedures. Moreover, these pumps are currently being monitored under the CPS Vibration Monitoring Program, which is not currently required by any Federal, state, or industry mandate. Because rotating equipment faults that can be detected by vibration monitoring will show up any time the equipment is operating, returning these pump to a fixed set of operating conditions is not necessary to detect such faults. Lastly, each of these waterleg pump's supported system pump discharge header is verified to be filled with water on a monthly basis in accordance with Surveillance Requirements in the CPS Technical Specifications. Any indication that the supported system's pump discharge header piping is not filled with water would provide timely indication that the associated waterleg pump's performance has degraded.
3.3.1
NRC Staff Evaluation
The RHR, LPCS, and RCIC waterleq pumps are continuously operating pumps. Their safety function is to keep their respective discharge header piping in a filled condition to prevent water hammer upon the start of the pump for the supported system(s). The actual output and hydraulic performance of the waterleg pumps are not critical to the safety function, as long as the pumps are capable of maintaining the discharge header piping full of water.
In lieu of an OM Code-required Group A test and flow measurement, the licensee proposes to monitor the pump discharge header pressures and bearing vibrations on a quarterly basis. In addition to this, there are alarms on the headers that would promptly alert plant operators of a low pressure condition indicative of a waterleg pump malfunction or any other condition that allows pressure to degrade (e.g., excessive leakage beyond waterleg pump make-up capabilities). The low pressure alarm will provide an early detection of a low header pressure.
Also, CPS technical specification SR 3.5.1.1 requires verification every 31 days that the respective RHRlLPCS/RCIC headers are filled with water from the main pump discharge valve to the injection valve. The continuous monitoring of discharge header pressure in the control room and monthly (more frequent than quarterly) verification that the headers are filled with water will provide reasonable assurance that the waterleg pumps are operable, or that the system leakage has not exceeded the capacity of the waterleg pumps. In addition, the quarterly vibration measurement of the pump bearings meets the Code requirements and will provide the required test results reflecting the mechanical condition of the pumps. The proposed alternative
- 8 will therefore provide reasonable assurance of the operational readiness of the RHRlLPCS/RCIC waterleg pumps 1E12-C003, 1E21-C002, and 1E51-C003.
3.3.2 Conclusion Based on the above evaluation, the NRC staff concludes that the licensee's proposed alternative to the Code Group A testing requirements, for waterleg pumps 1E12-C003, 1E21-C002, and 1E51-C003, is 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 these waterleg pumps. The alternative is authorized at CPS for the third 10-year 1ST program interval, which begins on June 15, 2010, and ends on June 14, 2020.
4.0 CONCLUSION
As set forth above, the NRC staff has determined that proposed alternatives RR Nos. 2201 and 3201 provide an acceptable level of quality and safety and proposed alternative RR No. 2202 provides reasonable assurance that the main steamline SRVs are operationally ready.
Accordingly, the NRC staff concludes that the licensee had adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(3)(i) for alternative RR Nos. 2201 and 3201 and 10 CFR 50.55a(3)(ii) for alternative RR No. 2202. Therefore, the NRC authorizes alternative RR Nos. 2201, 2202, and 3201 at CPS for the third 10-year 1ST program interval, which begins on June 15, 2010 and ends on June 14, 2020. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.
Principal Contributors: Russell Lake, NRR Steven Tingen, NRR Robert Wolfgang, NRR Date: June 10, 2010
ML101340691 NRR-106 OFFICE LPL3-2/PM LPL3-2/LA CPTB/BC LPL3-2/BC NAME NDiFrancesco THarris MAMcMurtray SCampbell DATE 06/15/10 06/03/10 05/07/10 via email 06/10/10