ML12202A069

Request for Additional Information Related to Relief Request RR-2 for the Fifth 10-Year Interval Inservice Testing Program Plan

ML12202A069
Person / Time
Site:	Robinson
Issue date:	08/21/2012
From:	Billoch-Colon A Plant Licensing Branch II
To:	William Gideon Carolina Power & Light Co
Billoch, Araceli
References
TAC ME8259
Download: ML12202A069 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 21, 2012 Mr. William R. Gideon, Vice President Carolina Power & Light Company H.B. Robinson Steam Electric Plant, Unit 2 3581 West Entrance Road Hartsville, South Carolina 29550 SUB..IECT: H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUEST-2 FOR THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN (TAC NO. ME8259)

Dear Mr. Gideon:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16, 2012 (Agencywide Documents Access and Management System Accession (ADAMS) No. ML12086A067),

Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted Relief Requests (RR)-1, RR-2, and RR-3 for the Inservice Testing (1ST) Program Plan for the Fifth 10-Year Interval for the H. B. Robinson Steam Electric Plant, Unit No.2.

By letter dated May 10,2012 (ADAMS Accession No. ML12138A041), the licensee submitted its response to the NRC's staff request for additional information (RAI), which was sent on May 4,2012. Subsequently, by letter dated June 4,2012 (ADAMS Accession No. ML12165A261), the licensee submitted its response to RAI-2, which was sent on May 24,2012.

The NRC staff is reviewing your responses to RAI-2 and has determined that additional information is required to complete its review of 1ST RR-2. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on July 20, 2012, it was agreed that you would provide a response within 30 days of the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources.

Please contact me at (301) 415-3302 if you have any questions.

Sincerely, CUd* T. ~U:.

Araceli Billoch Colon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

RAI cc w/encl: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION REGARDING H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 INSERVICE TESTING PROGRAM PLAN FOR THE FIFTH 10-YEAR INTERVAL DOCKET NO. 50-261 By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110310012),

Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc.,

submitted Relief Requests (RR)-1, RR-2, and RR-3 for the Inservice Testing Program (1ST) Plan for the Fifth 10-Year Interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).

By letter dated May 10, 2012 (ADAMS Accession No. ML12138A041), the licensee submitted its response to the NRC's staff request for additional information (RAI), which was sent on May 4,2012. Subsequently, by letter dated June 4,2012 (ADAMS Accession No. ML12165A261), the licensee submitted its response to RAI-2, which was sent on May 24,2012.

The NRC staff is reviewing your responses to RAI-2 and has determined that additional information is required to complete its review of 1ST RR-2.

1ST-RR-2: "Required Instrumentation Accuracy" In the basis for requesting relief, the licensee stated:

Generally, spare instruments are maintained and certified, but may not be available, or rendered inoperable. When calibrated instruments are not available, back-up instruments can be installed and verified in accordance with a detailed procedure in order to provide a high level of assurance relative to the proper operation of the flow rate device.

1) Explain why the back-up flow measurement instruments are not calibrated.

2) Clarify if the back-up instruments are property of the plant and where the instruments are stored when not in use.

3) Explain if the procedure that addresses the installation and verification of the back-up instruments addresses calibration procedures.

4) Clarify if there is a plant procedure that addresses instrument calibration and if the back-up instruments are included in that procedure.

5) State how many of these noncalibrated flow measurement instruments the plant has installed.

Enclosure

-2 In letter dated May 10, 2012 (ML12138A041), the licensee submitted the following response to

RAI-3

The ultrasonic flow meters are dependent of pipe size, wall thickness and spacing parameters. HBRSEP has used non-calibrated meters in the past and found the degree of error to be within the normally expected test variations.

Vendor literature indicates that an intrinsic accuracy of 3% of flow rate can be expected when set up proper/yo The degree of error is based on percent of reading; which provides a higher accuracy than percent of scale where the actual allowable error is 6% of reading. However, the vendor rating is not replicated on a certificate of compliance. HBRSEP documents the proper installation and set up of these meters prior to use. This relief was utilized during the fourth program interval and a table showing the results of use during the previous interval, is included below. The table may not be inclusive of each instance that this provision was utilized due to the large volume of tests; however, is intended to reflect the known instances and is indicative of expected instrument performance.

Pump Non-Calibrated Flow Calibrated Flow Deviation (PMP) Rate Rate

[Service Water] 7327 [gallons per minute] 7316 gpm on 1/14/10 0.15% of actual SW-PMP-A gpm on 10/22/09 SW -PMP-B 7062 gpm on 11/17/09 6910 gpm on 1/14110 2.2% of actual 7024 gpm on 2/19/10 0.54% of actual

[Safety Injection] 1186.59 psid @ set flow of 1176.79 psid @ set 0.87% of actual SI-PMP-C 322 gpm on 117/09 flow of 323 gpm on 8/18/10 1186.8 psid @ set flow of 325.1 gpm on 3/23/10 SW-PMP-A & SW-PMP-B utilize a common flow rate device. The SI-PMP-C test involved the biennial comprehensive pump test. A subsequent test was completed approximately 5 months later, instead of 2 years.

The data contained in the table provided is very limited and the dates of measurement are too far apart. In the case of SW-PMP-A, the time between the calibrated and the noncalibrated flow rate tests is of about 3 months.

1) Clarify if there is a larger data sample that compares the measurements of calibrated and noncalibrated instruments within a shorter time frame.

ML12138A041), the licensee submitted its response to the NRC's staff request for additional information (RAI), which was sent on May 4,2012. Subsequently, by letter dated June 4,2012 (ADAMS Accession No. ML12165A261). the licensee submitted its response to RAI-2, which was sent on May 24,2012.

The NRC staff is reviewing your responses to RAI-2 and has determined that additional information is required to complete its review of 1ST RR-2. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on July 20, 2012, it was agreed that you would provide a response within 30 days of the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources.

Please contact me at (301) 415-3302 if you have any questions.

Sincerely, IRAJ Araceli Billoch Col6n, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

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