ML12314A288

Relief Request-2 for the Fifth 10-Year Interval Inservice Testing Program Plan

ML12314A288
Person / Time
Site:	Robinson
Issue date:	12/11/2012
From:	Jessie Quichocho Plant Licensing Branch II
To:	William Gideon Carolina Power & Light Co
Billoch, Araceli
References
TAC ME8259
Download: ML12314A288 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 11, 2012 Mr. William R. Gideon, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Hartsville, South Carolina 29550 SUB~IECT: H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - 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 No. ML12086A067), as supplemented by letters dated May 10, 2012 (No. ML12138A041), June 4,2012 (No. ML12165A261) and September 20,2012 (No. ML12278A124), Carolina Power & Light Company (the licensee),

doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).

The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of the safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety.

The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1, the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21,2012, and ends on February 18, 2022.

As discussed with the licensee on July 9,2012, the NRC staff is concerned with the amount of information provided in the submittal that required revision after review by and questions from the NRC staff, and your request for multiple concurrent reviews with a short review timeframe.

The uncharacteristic inattention to detail observed in the submittal resulted in the need to focus limited resources to address mostly administrative issues. Additional attention to ensure a high quality submittal would allow for a more efficient use of review resources, and better ability of the NRC staff to accommodate requests for a shortened review timeframe.

w. Gideon - 2 The details of the NRC staff review are included in the enclosed SE. Section 50.55a(f) of 10 CFR, "Inservice Testing Requirements," requires in part, that the 1ST of certain ASME OM Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements.

Therefore, the licensee's proposed alternative for 1ST-RR-2 is authorized for the fifth 10-year 1ST interval at HBRSEP, which started on July 21, 2012, and ends on February 18, 2022.

Sincerely, e F. Quic ocho, Acting Chief lant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

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• • • • "" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN RELIEF REQUEST-2 CAROLINA POWER & LIGHT COMPANY H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. 50-261

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12086A067), as supplemented by letters dated May 10, 2012 (No. ML12138A041), June 4,2012 (No.

ML12165A261) and September 20,2012 (No. ML12278A124), Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).

The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of this safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety.

The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1, the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21, 2012, and ends on February 18, 2022.

2.0 REGULATORY EVALUATION

Section 50.55a(f) of 10 CFR, "Inservice Testing ReqUirements," requires in part, that the 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a.

In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety. Paragraph 50.55a(a)(3) of 10 CFR states, in part, that alternatives to the requirements of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of

-2 quality and safety or if (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The licensee requested authorization in IST-RR-2 of an alternative to the requirements of the ASME OM Code pursuant to 10 CFR 50.55a(a)(3)(i). The NRC staff has previously authorized IST-RR-2 for the third 1ST 1O-year interval on July 15, 1994 (ADAMS Legacy Library No. 9407250145) and for the fourth 1ST 10-year interval on June 27,2002 (ADAMS Accession No. ML031780245) for HBRSEP.

3.0 TECHNICAL EVALUATION

The NRC staff has evaluated the information provided by the licensee in support of IST-RR-2 for relief from, and alternative to, the ASME OM Code requirements and the bases for disposition are documented below.

3.1 IST-RR-2 3.1.1 ASME Code Requirements The applicable ASME OM Code edition and addenda for HBRSEP is the 2004 Edition through the 2006 Addenda.

Table ISTB-351 0-1, "Required Instrument Accuracy,>> requires that flow rate instrumentation used for Group A, Group B, comprehensive, and preservice tests have an accuracy of plus or minus 2 percent.

3.1.2 Component for which Relief is Requested The licensee requested to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the following pumps:

Table 3-1: Components for which Relief is Requested Pump Description Category Type CCW-PMP-A CCW (Component Cooling Water) Pump A Group A Horizontal Centrifugal CCW-PMP-B CCW Pump B Group A Horizontal Centrifugal CCW-PMP-C CCWPumpC Group A Horizontal Centrifugal SI-PMP-A Safety Injection (SI) Pump A Group B Horizontal Centrifugal SI-PMP-B SI Pump B Group B Horizontal Centrifugal SI-PMP-C SI PumpC Group B Horizontal Centrifugal SW-PMP-A SW (Service Water) Pump A Group A Vertical Line Shaft SW-PMP-B SW Pump B Group A Vertical Line Shaft 3.1.3 Licensee's Basis for Relief Request The original plant design of HBRSEP Unit 2 occurred prior to the issuance of 1ST requirements, and the plant design did not include flow rate measurement instrumentation that met subsequent ASME OM Code requirements. Since that time, flow instrumentation that meets

- 3 ASME OM Code requirements has been installed. However, the pumps listed in Table 3-1 have flow instrumentation that may be difficult to replace with certified instruments within the allotted Technical Specification (TS) limiting condition for operation (LCO).

In order to calibrate the flow instruments, a reference standard must be utilized and a calibration certificate obtained. HBRSEP is not equipped to perform this type of calibration and the instruments are sent to a certified vendor. The vendor is no longer capable of calibrating these instruments without the use of a test facility, which must be reserved in advance prior to use.

The time it takes to complete the calibration process varies from 2 to 6 weeks. The TS LCO time period would not be sufficient to facilitate diagnostics, instrument transport, repairs, calibration, reinstallation, and certification upon discovery that a calibrated instrument is found to be deficient. Also, for the SW and CCW pumps, this turnaround time could force the licensee to use noncalibrated flow instruments in consecutive quarterly tests.

The licensee is attempting to replace the ultrasonic flow meters with permanent indicators that require less user interface. However, two flow instrument installations are not functioning properly and will require additional modifications. One permanent flow meter used to support the CCW pump 1ST is working properly, however, the licensee feels it would be prudent to monitor this flow meter installation to ensure that long term performance continues to be accurate and repeatable. If the new flow meter produces erratic results, an ultrasonic flow meter could be used in accordance with HBRSEP procedures to obtain accurate flow measurements in order to assess pump operational readiness.

3.1.4 Licensee's Proposed Alternative Examination In the unlikely event that a flow rate measurement device for the pumps listed in Table 3-1 failed to operate properly and a calibrated flow rate instrument, composed of a meter and a set of transducers that have been previously paired during off-site calibration, is not available for replacement, an uncalibrated ultrasonic flow measurement device, composed of a meter and a set of transducers that have not been previously paired during off-site calibration, can be installed in accordance with specific instructions to ensure proper operation and provide accurate measurement of flow rate. Generally, spare instruments are maintained and certified, but may not be available, or rendered inoperable. When calibrated flow instruments are not available, backup uncalibrated flow measurement 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. Based on past experience, unsatisfactory pump performance can be determined through the use of noncalibrated ultrasonic flow rate instruments when the instruments are properly installed and verified in accordance with site specific procedures. An acceptable level of quality and safety is maintained and the use of this alternative would be prudent in the unlikely event of this emergent condition.

The licensee has used noncalibrated flow measurement instruments on occasion during the HBRSEP fourth 10-year 1ST program interval. For SW pump A, they were used two times between July 2009 and January 2010; for SW pump B, they were used five times bewteen July 2009 and January 2010; for SI pump C, they were used once.

Table 3-2 shows the approximate Acceptable Range margin currently available and the flow reference value for each pump.

-4 Table 3-2 Approximate Acceptable Pump Range Margin, gallons Reference Flow, gpm per minute (gpm)

CCW-PMP-A 2400 5300 CCW-PMP-B 2400 5250 jCW-PMP-C 1200 5440 I-PMP-A 45 335 SI-PMP-B 55 340 SI-PMP-C 60 320 SW-PMP-A 450 7260 SW-PMP-B 650 6880 This alternative is not intended to be used repeatedly as a testing convenience. The licensee will make efforts to obtain an acceptable calibrated flow instrument for use during the next pump test. Documentation of the flow measurements taken will be available for an onsite NRC review.

3.1.5 NRC Staff's Evaluation The licensee has proposed an alternative in lieu of the requirements found in the 2004 Edition through 2006 Addenda of the ASME OM Code, Table ISTB-3510-1. Specifically, the licensee proposed to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the pumps listed in Table 3-1.

Table ISTB-3510-1 of the OM Code requires that flow rate instruments have an accuracy of plus or minus 2 percent for Group A, Group B, and comprehensive tests.

The licensee currently uses externally mounted ultrasonic flow meters to measure flow rate during 1ST for the pumps listed in Table 3-1. If one of these flow meters is out of calibration, the licensee must send it to a vendor for calibration, and the process can take 2 to 6 weeks to complete, which is longer than the TS LCO. The NRC staff previously authorized this alternative for the HBRSEP Unit 2 third 1ST 10-year interval on July 15, 1994, and fourth 1ST 10-year interval on June 26, 2003.

The licensee stated that in the fourth 10-year 1ST interval, noncalibrated flow instrumentation has been used two times between July 2009 and January 2010 for SW pump A. five times between July 2009 and January 2010 for SW pump B, and once for SI pump C. During this time, it became evident to the licensee that the permanent meter for SW pumps A and B was erratic. To eliminate this issue, the licensee purchased and calibrated two new ultrasonic flow meters, and the vendor was brought in to help install and test the new devices. Also, SW pump B was being tested at an increased frequency (every 45 days) during this interim period.

In Table 3-2, the licensee provided the Acceptable Range flow rate margin for each pump, based on the most recent pump test results. This data shows that the flow rate margin is sufficient so that the use of a noncalibrated instrument would not mask pump degradation that would require a pump to enter the Alert Range or Required Action Range.

- 5 The licensee is also attempting to replace the calibrated ultrasonic flow meters with permanent indicators that require less user interface. The licensee will not use noncalibrated flow measurement instruments as a testing convenience. If usage of noncalibrated instruments is required, the licensee will make an effort to obtain a calibrated flow measurement instrument for subsequent tests.

The licensee's alternative request was based on applying the rule of 10 CFR 50.55a(a)(3)(i),

"The proposed alternatives would provide an acceptable level of quality and safety." However, the alternative method described in IST-RR2 is more in line with 10 CFR 50.55a(a)(3)(ii),

"Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety." Therefore, the NRC finds that the proposed alternative provides reasonable assurance that the pumps listed in Table 3-1 are operationally ready.

4.0 CONCLUSION

The NRC staff finds that the proposed alternative, described in alternative request IST-RR-2, provides reasonable assurance that the pumps listed in Table 3-1 are operationally ready.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code's requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests remain applicable.

Therefore, the NRC authorizes the alternative, described in IST-RR-2, for the HBRSEP, 10-year 1ST interval, which began on July 21,2012, and is currently scheduled to end on July 20, 2022.

Principle Contributor: Robert Wolfgang Date of issuance: December 11, 2012

ML12314A288

• Via Memo OFFICE 2/PM LPL2-2/LA DE/EPTB/BC* DE/EICB/BC* LPL2-2/BC NAME ABillochCol6n BClayton AMcMurtray ..IThorp ABiliochCol6n DATE 11/08112 11/14112 11/15/12 11/29/12 12/11/12