ML14125A471

Relief from the Requirements of the ASME Code

ML14125A471
Person / Time
Site:	Surry
Issue date:	05/09/2014
From:	Robert Pascarelli Plant Licensing Branch II
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Barillas M
References
TAC MF1811, TAC MF1812, TAC MF1815, TAC MF1816, TAC MF1818, TAC MF1819, TAC MF1821, TAC MF1822, TAC MF1825
Download: ML14125A471 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Blvd.

Glenn Allen, VA 23060 May 9, 2014

SUBJECT:

SURRY POWER STATION, UNITS NOS 1 AND 2-RELIEF FROM THE REQUIREMENTS OF THE ASME CODE (TAC NOS. MF1811, MF1812, MF1815, MF1816, MF1818, MF1J319, MF1821, MF1822, and MF1825)

Dear Mr. Heacock:

By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), as supplemented by letter dated November 5, 2013 (ADAMS Accession No. ML13316A006), Virginia Electric and Power Company (Dominion), the licensee, submitted Relief Requests P-1, P-3, P-4, P-5 and P-6 for Surry Power Station (Surry),

Unit 1 and P-1,'P-3, P-4, and P-5 for Surry, Unit 2, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternatives are associated with inservice testing (1ST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition, 2005 and 2006 Addenda, for the fifth 1 0-year interval 1ST program at Surry, Units 1 and 2.

Specifically, pursuant to Title 10 of the Code of Federal Regulations ( 1 0 CFR) Part 50, Section 50.55a(a)(3)(i), the licensee requested to use the proposed alternatives P-1, P-3, P-4, P-5, and P-6 on the basis that the alternatives provide an acceptable level of quality and safety.

The licensee proposed alternatives to 1ST requirements for specific pumps in the Chemical Volume and Control System, the Component Cooling Water System, the Containment Spray System, the Auxiliary Feedwater System, the Residual Heat Removal System, the Service Water System, Recirculation Spray System, Safety Injection System, and the Ventilation System. The NRC staff reviewed the Relief Requests stated above for Surry Units 1 and 2 and concludes, as set forth in the enclosed safety evaluation, that Dominion adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i) and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes Relief Requests P-1, P-3, P-4, P-5, and P-6 for Surry, Unit 1, and P-.1, P-3, P-4, and P-5 for Surry, Unit 2, for the fifth 1 0-year 1ST intervals which are scheduled to begin on May 10, 2014, and end on May 9, 2024.

All other ASME OM Code requirements for which alternatives or relief was not specifically requested and approved in the subject request remain applicable.

I

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If you have any questions, please contact the Project Manager, Martha Barillas at 301-415-2760 or via e-mail at Martha.Barillas@nrc.gov.

Docket Nos: 50-280 and 50-281

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NOS. P-1, P-3, P-4. P-5 AND P-6 FOR UNIT 1 AND P-1 I P-3, P-4, AND P-5 FOR UNIT 2 REGARDING ASME OM CODE REQUIREMENTS FOR THE FIFTH 10-YEAR INSERVICE TEST PROGRAM INTERVAL VIRGINIA ELECTRIC AND POWER COMPANY

1.0 INTRODUCTION

SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-280 AND 50-281 By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104 ), as supplemented by letter dated November 5, 2013 (ADAMS Accession No. ML13316A006), Virginia Electric and Power Company (Dominion), the licensee, submitted Relief Requests P-1, P-3, P-4, P-5 and P-6 for Surry Power Station (Surry),

Unit 1 and P-1, P-3, P-4, and P-5 for Surry, Unit 2, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternatives are associated with inservice testing (1ST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition, 2005 and 2006 Addenda, for the fifth 1 0-year interval 1ST program at Surry, Units 1 and 2.

Specifically, pursuant to Title 1 0 of the Code of Federal Regulations ( 10 CFR) Part 50, Section 50.55a(a)(3)(i), the licensee requested to use the proposed alternatives P-1, P-4, P-5, and P-6 on the basis that the alternatives provide an acceptable level of quality and safety.

Pursuant to 10 CFR 50.55a(f)(6)(i), the licensee requested to use proposed testing in Relief Request P-3 on the basis that the code requirement is impractical.

2.0 REGULATORY EVALUATION

The 10 CFR 50.55a(f), "lnservice Testing Requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda.

The 10 CFR 50.55a(a)(3), states, in part, that alternatives to the requirements in paragraph (f) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with Enclosure the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.The 10 CFR 50.55a(f)(5)(iii), states, in part, that licensees may determine that conformance with certain code requirements is impractical and that the licensee shall notify the Commission and submit information in support of the determination.

The 10 CFR 50.55a(f)(6)(i), states that the Commission will evaluate determinations under paragraph (f)(5) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to grant the relief and authorize the alternatives requested by the licensee.

The Surry, Units 1 and 2, fifth 1 0-year 1ST intervals are both scheduled to begin on May 1 0, 2014, and end on May 9, 2024.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the licensee's regulatory and technical analyses in support of the relief requests from the inservice test requirements of the ASME OM Code that are described in and 2 of the application (ADAMS Accession No. ML13128A104 ).

3.1 Surry. Unit 1. Alternative Request P-1 In its submittal, the licensee proposed an alternative to the ASME OM Code vibration testing requirements for the pumps listed in Table 1 below. The licensee's request involves an alternative to the requirements of ASME OM Code paragraphs ISTB-3300, ISTB-5120, ISTB 5121, ISTB-5123, ISTB-5220, \\STB-5221, \\STB-5223, and Table \\STB-5121-1 and Table ISTB-5221-1.

ISTB-3300, "Reference Values," defines the requirements for obtaining reference values for the inservice testing of pumps.

ISTB-3300, "Reference Values," (a) states that "initial reference values shall be determined from the results of testing meeting the requirements of ISTB-31 00, "Preser:vice Testing," or from the results of the first inservice test."

ISTB-3300, "Reference Values," (d) states that "reference values shall be established at point(s) of operation (reference point) readily duplicated during subsequent testing."

ISTB-3300, "Reference Values," (f) states that "all subsequent test results shall be compared to these initial reference values or to new reference values established in accordance with ISTB-3310, ISTB-3320, or ISTB-6200(c)."

ISTB-5120, "lnservice Testing" (Centrifugal Pumps, Except Vertical Line Shaft Centrifugal Pumps), ISTB-5121, "Group A Test Procedure," (e), and ISTB-5123, "Comprehensive Test Procedure", (e), state that "All deviations from the reference vaJues shall be compared with the ranges of Table ISTB-5121-1 and corrective action taken as specified in ISTB-6200. The vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5121-1."

ISTB-5220, "lnservice Testing" (Vertical Line Shaft Centrifugal Pumps), ISTB-5221, "Group A Test Procedure," (e) and ISTB-5223, "Comprehensive Test Procedure," (e), state that "All deviations from the reference values shall be compared with the ranges of Table ISTB-5221-1 and corrective action taken as specified in ISTB-6200.. The vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5221-1."

a e umps ec e

)y erna 1ve eques - ' m T bl 1 P Aff t db Alt f

R t p 1 u "t 1 Pump System Code OM Description Group Class Grou(:>_

1-CC-P-1A Component 3

A Component Cooling Water Pumps 1-CC-P-1 8 Cooling 1-CC-P-2A Component 3

A Component Cooling Water Pump Cooling to Charging Pum~

1-CH-P-18 Chemical and 2

A High Head Safety Injection I 1-CH-P-1C Volume Control I Charging Pump Safety Injection 1-CH-P-2A Chemical and 2

8 Boric Acid Transfer Pump 1-CH-P-28 Volume Control 1-FW-P-38 Auxiliary 3

A Auxiliary Feedwater Motor Driven Feedwater Pump 1-RH-P-1A Residual Heat 2

A Residual Heat Removal Pump 1-RH-P-18 Removal 1-SW-P-10A Service Water 3

A Service Water Pump to Charging 1-SW-P-108 Pump 1-VS-P-18 Ventilation 3

A Main Control Room Air 1-VS-P-1C Conditioning System Condenser Water Pump 1-VS-P-1D Ventilation 3

A Main Control Room Air 1-VS-P-1 E Conditioning System Condenser Water Pump 1-VS-P-2A Ventilation 3

A Main Control Room Air 1-VS-P-28 Conditioning System Chilled 1-VS-P-2C Water Pump 1-VS-P-2D Ventilation 3

A Main Control Room Air 1-VS-P-2E Conditioning System Chilled Water Pump

Reason for Request

The pumps listed in Table 1 have at least one vibration reference value (Vr) that is currently less than 0.05 inches per second (ips). Small values for Vr produce small acceptable ranges for pump operation. The acceptable ranges are defined in Tables ISTB-5121-1 and ISTB-5221-1 as less than or equal to 2.5Vr. Based on a small acceptable range, a smooth running pump could be subject to unnecessary corrective action ifthe measured vibration parameter exceeds this acceptable range.

For very small reference values, hydraulic noise and instrument error can be a significant portion of the reading and affect the repeatability of subsequent measurements. Also, experience gathered from the North Anna preventive maintenance program has shown that changes in vibration levels in the range of 0.05 ips do not normally indicate significant degradation in pump performance.

To avoid unnecessary corrective action, a minimum value for Vr of 0.05 ips has been established for velocity measurements. This minimum value will be applied to individual

. vibration locations for the pumps listed in Table 1 where the measured reference value is less than 0.05 ips.

When new reference values are established per ISTB-3310, ISTB-3320 or ISTB-6200(c), the measured parameters will be evaluated for each location to determine if the provisions of this relief request still apply.

In addition to the requirements of ISTB, the pumps in the ASME OM Code 1ST Program are included in the Surry Predictive Maintenanc~ Program. The Surry Predictive Maintenance.

Program currently employs predictive monitoring techniques such as:

• vibration monitoring and analysis beyond that required by ISTB, and oil sampling and analysis where applicable (e.g., for pumps with sufficiently large oil reservoirs).

If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may include:

increased monitoring to establish rate of change, review of component specific information to identify cause, and removal of the pump from service to perform maintenance.

It should be noted that all of the pumps in the 1ST Program will remain in the Predictive Maintenance Program even if certain pumps have very low vibration readings and are considered to be smooth running pumps. This alternative to the requirements of ISTB-3300, ISTB-5120 and ISTB-5220, and Table ISTB-5121-1 and Table ISTB-5221-1 provides an acceptable level of quality and safety.

Proposed Alternative The licensee proposed an alternative to the reference value requirements of ISTB-3300 for the

~

pumps listed in Table 1, whereas pumps with a measured reference value below 0.05 ips for a particular vibration measurement location will have subsequent test results for that location compared to an acceptable range based on 0.05 ips. The licensee's proposed alternative states it will maintain all pumps in the 1ST Program in the Surry Predictive Maintenance Program as well, regardless of their smooth running status.

NRC Staff Evaluation

The NRC staff notes that pumps with vibration levels of 0.1 ips or less are generally considered "smooth running pumps," and that the licensee's proposed minimum vibration level is well below this point. In addition, as per ASME OM Code Table ISTB-5121-1, the alert range for pumps that operate with a pump speed greater than 600 rpm is 0.325 to 0. 7 ips. Therefore, action is required for vibration greater than 0. 7 ips. The pumps listed in Table 1 operate with pump speeds greater than 600 rpm. It is also noted that for reference values smaller than 0.05 ips, hydraulic noise and instrument error can be a significant porti_on of the reading and therefore affect the repeatability of subsequent measurements. If a very small reference value were utilized, non-repeatable measurements may result in unnecessary testing or maintenance.

Therefore, the NRC staff finds the licensee's proposal to use 0.05 ips as a minimum threshold in the evaluation of vibration velocity is conservative and acceptable.

The licensee has also included the pumps in Table 1 in Surry's Predictive Maintenance Program which includes additional vibration monitoring and oil sampling and analysis. The NRC staff I

notes that the performance of these additional monitoring techniques, along with application of the alternative alert and action ranges proposed by the licensee, provides reasonable assurance that the licensee will be able to detect degradation of the pumps listed in Table 1.

Based on the alternative limits proposed by the licensee for vibration monitoring of the pumps listed in Table 1, and the inclusion of these pumps in Surry's Predictive Maintenance Program, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuantto 10 CFR 50.55a(a)(3)(i) for vibration testing of the pumps listed in Section 3.1 of this safety evaluation.

The proposed alternative will be used for the Surry, Unit 1, fifth 1 o.:.year 1ST Interval which is currently scheduled to start on May 10, 2014, and end on May 9, 2024.

3.2 Surry, Unit 1, Alternative Request P-3 In its submittal, the licensee requested relief from Table ISTB-3500-1 and ISTB-3510(b)(1).

Table ISTB-3500-1, "Required Instrument Accuracy," requires that Group A test pressure instrument accuracy shall be within +/- 2 percent.

ISTB-351 0, "General," (b)( 1) requires that the full-scale range of each analog instrument shall be not greater than three times the reference value.

The components affected by this relief request are Boric Acid Transfer Pumps 1-CH-P-2A and 1-CH-P-28. The pumps are classified as Group A pumps in the 1ST Program and function to supply boric acid to the suction of the charging pumps for emergency boration.

Reason for Request

Calibrating the inlet pressure instruments for the boric acid transfer pumps to an accuracy within

+/- 2 percent has proven difficult and may be impractical in the future with the current instruments. Calibrating the inlet pressure instruments to an accuracy within +/- 3 percent would be practical.

The inlet pressure gauges have a full scale range of 0 to 15 pounds per square inch gauge (psig). These instruments were sized by evaluating the static pressures present at the suction side of the pumps and applying the three times rule of ISTB-351 O(b )( 1 ). The static pressures range from 6 to 7 psig.

When the pumps are started, the pressure at the suction side of the pumps drops to

. approximately 2 psig; therefore, the inlet pressure gauges do not meet the three times rule for.

dynamic inlet pressure.

Using a lower range pressure gauge (i.e. 0 to 5 psig) would meet the three times rule for dynamic inlet pressure; however, the lower range gauge would be repeatedly exposed to an over range condition (static pressures in excess of 5 psig) which would damage the instruments.

Using a lower range temporary gauge on a quarterly basis presents a hardship because the process fluid contains boric acid and is contaminated. If contaminated, the temporary instruments would probably become waste material. However, with the current 0 to 15 psig inlet pressure gauges calibrated to +/- 3 percent, a differential pressure can be determined that exceeds the accuracy requirements for differential pressure.

Each boric acid transfer pump discharge pressure gauge (0 to 150 psig range) has an instrument loop accuracy of 1.59 percent. Computing the maximum error for differential pressure using the current instrument configuration and an inlet pressure gauge accuracy of

+/- 3 percent, yields an error of 2.85 psid.

Computing the ASME OM Code allowed error for differential pressure for an inlet pressure gauge with a 2 percent accuracy and a 0 to 5 psig range and a discharge pressure instrument with a 2 percent accuracy and a 0 to 150 psig range yields an error of 3.1 psid. With the current instrument configuration, the loop accuracy of each discharge pressure instrument could be as high as 1. 75 percent, which equates to a 3.075 psid error, and still be within the ASME OM Code allowed error of 3.1 psid for differential pressure. Therefore, for purposes of trending pump degradation using differential pressure and flow, the current instrument is adequate as long as the discharge pressure instrument loop accuracies remain at or below 1. 75 percent.

Proposed Alternative The licensee proposed to use inlet pressure gauges with a full-scale range of 0 to 15 psig and calibrated to an accuracy within +/- 3 percent in order to measure dynamic inlet pressures.

Also, the licensee's alternative proposed to maintain loop accuracies for the discharge pressure gauges at or below an accuracy of 1. 75 percent to ensure that the differential pressure error is below the differential pressure error allowed by the ASME OM Code.

NRC Staff Evaluation

The boric acid transfer pumps 1-CH-P-2A and'1-CH-P-28 supply boric acid to the suction of the charging pumps for emergency boration. The inlet pressures to these boric acid transfer pumps vary significantly between their standby and operating modes. The static inlet pressure available to the pumps during operation is 6 to 7 psig. However, when the pumps are started, the inlet pressure drops to about 2 psig. When the inlet pressure drops to 2 psig, ISTB-3510(b)(1) requires that the inlet gauges must have a range of 0 to 6 psig. However, the NRC staff notes that the use of a 0 to 6 psig range gauge would be unsuitable at static inlet pressures due to the possibility of damaging the gauge by over-ranging. To meet the ASME OM Code requirements, the licensee would be required to install temporary instruments at the inlet of the boric acid transfer pumps prior to each quarterly test.

The ASME OM Code, Table ISTB-3500-1 requires that Group A test pressure instrument accuracy be within+/- 2 percent, and ISTB-3510(b)(1) requires thatthe full-scale range of each analog instrument not be greater than three times the reference value. The licensee has proposed an alternative to the above ASME OM Code requirements because they have determined that the instruments do not meet the ASME OM Code accuracy and range requirements for boric acid transfer pumps 1-CH-P-2A and 1-CH-P-28. As such; the licensee has proposed an alternative to the Table ISTB-3500-1 and ISTB-3510(b)(1) requirements that would test the pumps with 0 to 15 psig, full-scale range inlet pressure gauge, accurate to within

+/- 3 percent for the measurement of dynamic inlet pressures. Additionally, the licensee stated that the loop accuracies for the discharge pressure gauges will be maintained at or below an accuracy of 1. 75 percent to ensure that the differential pressure error is below the differential pressure error allowed by the ASME OM Code..

Section 5.5.1 of NUREG-1482, Revision 2, "Guidelines for lnservice Testing at Nuclear Power Plants (ADAMS Accession No. ML13295A020)," states that although instrument modifications are considered practical in the context of 10 CFR 50.55a(f)( 4 ), the use of available instruments that meet the intent of the ASME OM Code requirements for the actual reading would yield an acceptable level of quality and safety for testing.

The NRC staff has reviewed the ASME OM Code Table ISTB-3500-1 and ISTB-3510(b)(1) requirements. The intent of these requirements is to ensure that the range and accuracy readings obtained from flow and pressure instrumentation are within a range small enough to make degradation monitoring meaningful. The licensee's proposed alternative meets the intent of the ASME OM Code requirements, since the combination of errors in the proposed alternative results in errors less than the combined errors of instrumentation that strictly meets the ASME OM Code requirements. The licensee stated as a proposed alternative it will calibrate the accuracy of the 0 to 15 psig range inlet pressure gauges to within +/- 3 percent and will maintain loop accuracies for the discharge pressure gauges at or below an accuracy of

1. 75 percent to ensure that the intent of the ASME OM Code is maintained for testing of boric acid transfer pumps 1-CH-P-2A and 1-CH-P-28.

Based on the proposed alternative to limit discharge pressure to 1. 75 percent and calibrate the suction gauge to within 3 percent, the NRC staff finds that the licensee's proposed alternative provides an acceptable level cif quality and safety pursuant to 10 CFR 50.55(a)(3)(i) for the inservice testing of boric acid transfer pumps 1-CH-P-2A and 1-CH-P-28.

The proposed alternative will be used for the Surry, Unit 1, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

3.3 Surry, Unit 1. Alternative Request P-4 In its submittal, the licensee proposed an alternative to the requirements of IST8-351 O(b)(1 ).

IST8-351 0, "General," (b)( 1) states that the full-scale range of each analog instrument shall be not greater than three times the reference value.

The components affected by this alternative request are charging pump cooling water pumps 1-CC-P-2A and 1-CC-P-28. The pumps are classified as Group A pumps in the 1ST Program and function to supply cooling water to transfer heat from the charging pump mechanical seals.

Reason for Request

Installed inlet pressure gauges used for the Group A tests have a full scale range of 0 to 3.5 psig. Readings from these inlet pressure gauges over the past year indicate that the dynamic pressures fall within the bottom third of full scale. However, the difference in the error between the 0 to 3.5 psig gauges and gauges that would meet the three times full-scale rule are so small that the 0 to 3.5 psig gauges can be considered to be equivalent in terms of accuracy for determining differential pressure.

For example, inlet pressures as low as 0.8 psig have been recorded for pump 1-CC-P-28. A

. gauge that meets the three times full-scale rule would have a full scale of 2.4 psig or less. A 2 percent accuracy for the 2.4 psig gauge translates to an error of 0.05 psig. A 2 percent accuracy for the 3.5 psig gauge translates to an error of 0.07 psig. The difference in error of 0.02 psig is insignificant when determining the differential pressures for these pumps which range between 50 and 60 psig. Therefore, the two gauges can be considered to be equivalent in terms of accuracy for determining differential pressure.

Proposed Alternative The licensee proposed to measure pump suction pressure with gauges that have a full scale of 0 to 3.5 psig for charging pump cooling water pumps 1-CC-P-2A and 1-CC-P-28.

NRC Staff Evaluation

The charging pump cooling water pumps 1-CC-P-2A and 1-CG-P-28 are Group A, Class 3 pumps that are part of the Component Cooling Water (CCW) System. The pumps supply cooling water to transfer heat from the charging pump mechanical seals. These pumps have been recorded to have inlet pressures as low as 0.8 psig and commonly have differential pressures that range from 50 to 60 psig.

The ASME OM Code, ISTB-3510(b)(1) requires that the full-scale range of each analog instrument shall be not greater than three times the reference value. The licensee has requested relief from ASME OM Code requirements because the use of a gauge with a full-scale range of 0 to 3.5 psig would provide an adequate level of quality and safety for the measurement of inlet pressures to the charging pump cooling water pumps 1-CC-P-2A and 1-CC-P-28.

The NRC staff reviewed the ISTB-351 O(b )( 1) requirements and has determined that there would be a negligible accuracy error in determining the differential pressures across these pumps when a 0 to 3.5 psig gauge is used as compared to a gauge that would meet the three times full-scale rule (a 0 to 2.4 psig gauge). Therefore, the use of the inlet pressure gauge with a full-scale range of 0 to 3.5 psig will provide an acceptable level of quality and safety pursuant to 10 CFR 50.55(a)(3)(i), for the operation of the charging pump cooling water pumps.

Based on the negligible errors introduced by use of ah inlet pressure gauge with a full-scale range of 0 to 3.5 psig when compared to differential pressures that range between 50 and 60 psig, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(3)(i) for Group A testing of charging pump cooling water pumps 1-CC-P-2A and 1-CC-P-28.

The proposed alternative will be used for the Surry, Unit 1, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

• 3.4 Surry, Unit 1, Alternative Request P-5 In its submittal, the licensee proposed an alternative to the comprehensive pump testing requirements of ASME OM Code, subparagraph ISTB-3300(e)(1 ).

ISTB-3300, "Reference Values," (e)(1) states, "reference values shall be established within

+/- 20 percent of pump design flow rate for the comprehensive test."

The components affected by this alternative request are containment spray pumps 1-CS-P-1 A and 1-CS~P-1 B. The containment spray pumps provide a cooled, chemically treated, borated spray to reduce containment pressure following a loss-of-coolant accident. These pumps are.

classified as ASME Class 2, Group B pumps in the 1ST Program.

Reason for Request

The containment spray pumps take suction from the refueling water storage tank (RWST) and discharge back to the RWST. With the test loop in the Containment Spray System (see Figure P-5.1, Containment Spray System of the application ADAMS Accession No. ML13128A104 ), it is difficult to consistently achieve reference flow rates that are within 20 percent of the pump design flow rate of 2000 gpm. Therefore, relief from the ASME OM Code requirement is requested for Surry, Unit 1.

The containment spray system resistance limits a single pump delivery flow to 2000 gpm at 238.6 total developed head (TDH) in feet. This TDH corresponds to the accident analysis conditions when a containment spray pump starts and is subject to its most limiting operating conditions.* Specifically, the Surry accident analysis assumes a minimum pump flow rate of 2000 gpm when the RWST, which is the containment spray suction source, is at the Technical Specifications minimum allowable level and the containment is at the design pressure of 45 psig.

As containment pressure decreases during a design basis accident (DBA) following spray actuation, the containment spray pump TDH will decrease and the flow will increase above 2000 gpm as the pump operating point moves out on the pump curve. The pump response along the pump curve as modeled in the accident analysis is for a degraded pump. The actual pump head performance at 1600 gpm (the approximate test flow rate) is well above the corresponding head of the accident analysis degraded pump curve requirement.

A model of the containment spray system hydraulic circuit for each pump has confirmed the limiting accident analysis assumptions for containment spray pump flow versus head.

An additional consideration is that the containment spray pumps are expected to operate for less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after a DBA. Accident analyses demonstrate that the RWST is exhausted quickly, depending on the number of containment spray and safety injection pumps that are running. The operators stop the containment spray pumps when RWST level reaches less than 3 percent indication.

Surry has determined that thecontainment spray pump design flow rate is 2000 gpm based on the plant safety analyses. The ASME OM Code requires that the containment spray pump flow be tested within 80% of the design flow rate, or 1600 gpm. The average test flow rate for tests conducted since 2004 is 1593 gpm for Unit 1. The containment spray system is a fixed resistance system and the test flow rates tend to vary several gpm based on initial RWST level.

Although the Unit 1 pumps have met the ASME OM Code requirements, there are tests where 1600 gpm cannot be achieved.

During the construction period, the containment spray headers were fitted with blind flanges that allowed the connection of temporary drain lines for initial testing of the subsystem. After the subsystem was completely installed, temporary connections between the spray headers were made using blind flanges on the spray headers, and pipe plugs were placed in the spray nozzle sockets. The containment spray pumps were started and operated over a range of flows, circulating water through the spray header supply line to the spray headers, out the temporary drain connections and to the opposite s~ray headers'. The water was then directed to the RWST through the 4" recirculation line. Although the preoperational test did not produce full flow conditions, it provided a full-system capability test and demonstrated that the pumps wer~

operating on the manufacturer pump curve. It also flushed the system to remove any particulate matter that could plug the spray nozzles at a future time. At the completion of this test, the temporary drain connections were removed, the blind flanges replaced, the pipe plugs removed, the nozzle pipe nipple inspected, and the spray nozzles installed.

In addition to the pre-operational testing performed on the containment spray system, a special RWST/Chemical Addition Tank draw down test was performed on April 30, 1980, using pump 2-CS-P-1 A at flow rates substantially greater than the current achievable test flow rates. The purpose of the draw down test was to validate the analytical model used to perform the Surry site boundary dose analysis. Temporary 8" discharge piping was installed from the bonnet of

' check valve 2-CS-13, located downstream of the pump and inside containment at elevation 15' 9", to the reactor cavity at elevation 48' 1". Flow rates up to 2133 gpm were achieved during the test. This test demonstrates that the containment spray pump 2-CS-P-1A has been operated at design flow conditions in its installed configuration. The four containment spray pumps on Surry, Units 1 and 2, are essentially identical, so the conclusion from the Unit 2 containment spray pump test that pump 2-CS-P-1A can achieve the design flow rate is applicable to the Unit 1 pumps.

In addition to the testing described above, the containment spray pumps are included in the Surry Predictive Maintenance Program. For the containment spray pumps, this program employs predictive monitoring techniques, such as vibration monitoring and analysis beyond that required by ISTB, and oil sampling and analysis.

If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may include:

increased monitoring to establish rate of change, review of component specific information to identify cause, and removal of the pump from service to perform maintenance.

Testing the containment spray pumps at or near 1600 gpm will detect degradation in performance and verify that the pumps are operating acceptably. The 1600 gpm point (50 percent of the point of best efficiency of approximately 3200 gpm) is in a portion of the pump curve where degradation will be detected. Also, there is significant margin available above the minimum acceptable pump curve when testing the pump on the test loop. For pump 1-CS-P-1 A, the margin is approximately 20 feet of TDH and for pump 1-CS-P-1 B the margin is approximately 18 feet. A decrease in the available margin is detectable before the pump performance becomes unacceptable.

Figure P-5.2 of the licensee's application shows the nominal vendor pump curve for 1-CS-P-1 A, a typical test point, the minimum test point below which is unacceptable performance, and the design point (2000 gpm at 238.6 feet TDH). Figure P-5.3 of the licensee's application shows the same information for 1-CS-P-1 B. The proposed alternative to ISTB-3300( e)( 1) provides an acceptable level of quality and safety.

Proposed Alternative The licensee proposed that comprehensive pump test reference flow rate for each pump-be established at or near 80 percent of the pump design flow rate, but not less than 76 percent of design flow rate (1520 gpm). The licensee proposed to perform quarterly ASME OM Code-required testing of the containment spray pumps at or near 80 percent, but not less than 76 percent, of the pump design flow rate. In addition to the flow testing, the containment spray pumps are includ,ed in the Surry Predictive Maintenance Program. This program employs predictive monitoring techniques, such as vibration monitoring and analysis beyond that required by the ASME OM Code, and oil sampling and analysis.

If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded, state, the licensee has stated that appropriate actions will be taken that may include monitoring additional parameters, reviewing component-specific information to identify the cause, or removing the pump from service to perform maintenance.

NRC Staff Evaluation

The containment spray pumps fall within the scope of the ASME OM Code and are defined as Class 2, Group B Pumps. As such, these pumps are subject to quarterly Group B tests and a biennial comprehensive pump test. Pump speed as well as differential pressure' or flow rate are required to be monitored for the Group B test. Additionally, speed, differential pressure, flow rate, discharge pressure, and vibration are required for the comprehensive pump test. ASME OM Code, paragraph ISTB 3300(e)(1) requires the establishment of reference values for the comprehensive pump test to be within +/- 20 percent of pump design flow.

The comprehensive pump test, which first appeared in the 1995 Edition of the ASME OM Code, results in a.more accurate assessment of the pump's operational readiness and performance characteristics at a reduced frequency (once every refueling cycle versus once every 3 months).

The test is intended to be conducted at or near a pump's design flow rate because this area of the pump curve is considered to be most representative of the pump's design performance characteristics.

Currently, the test flows for the containment spray pumps are established near 1520 to 1600 gpm. This is approximately 76 to 80 percent of design flow. A review of the submitted pump curves confirms that they have a well-defined, continuous, negative (non-zero) slope in the areas of the proposed testing. NRC staff notes that testing on portions of the operating curve that have a well-defined, continuous, negative (non-zero) slope aids in the detection of pump degradation and verification that the pumps are operating acceptably. The quarterly Group B test is also performed in this flow range.

In addition to the ASME OM Code-required flow testing, the containment spray pumps are included in the Surry Predictive Maintenance Program. This program employs predictive monitoring techniques, such as vibration monitoring and analysis beyond that required by the ASME OM Code, and oil sampling and analysis. If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, the licensee has stated that appropriate actions will be taken that may include monitoring additional parameters, reviewing component-specific information to identify cause, or removing the pump from service to perform maintenance.

The licensee stated in response to RAI P-5-1 (ADAMS Accession No. ML13316A006) the NRC staff issued to clarify how additional testing and monitoring techniques are performed on containment spray pumps 1-CS-P-1A and 1-CS-P-18, that additional vibration testing is performed on the clutch and the motor of 1-CS-P-1 A and 1-CS-P-1 B. In addition, the licensee stated that the acceptable range, alert range, and required action range are chosen in accordance with the Group A Test requirements in Table ISTB-5121-1. The licensee further stated that the data are reviewed and trended and, if an unusual condition is noted,'a condition report is generated in the station Central Reporting System to track the necessary corrective

. actions. The licensee also stated that oil sampling and analysis is performed quarterly as part of the quarterly pump test, and that the oil analysis is performed as soon as practical following retrieval of the sample.

The NRC staff notes that the proposed alternative test method monitors vibration on a more frequent basis than is currently required by the ASME OM Code for Group B pumps. Increased monitoring of vibration may detect minor imbalances and aids in condition assessment and assessment of pump degradation. The use of lube oil sampling and analysis is a good practice and can also aid in the condition assessment of rotating equipment. The additional monitoring and sampling provides additional confidence in the licensee's ability to detect and respond to mechanical degradation.

Based on the combination of testing the containment spray pumps consistently in the vicinity of 80 percent of design flow on a portions of the pump curve that have a well-defined, continuous, negative (non-zero) slope and the enhanced use of predictive maintenance techniques, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) for comprehensive testing of containment spray pumps 1-CS-P-1A and 1-CS-P-1 B.

The proposed alternative will be used for the Surry, Unit 1, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

3.5 Surry, Unit 1, Alternative Request P-6 In its submittal, the licensee requested an alternative to the comprehensive pump testing requirements of ISTB-5123 and ISTB-5223. ISTB-5123, "Comprehensive Test Procedure" refers to table ISTB-5121-1 which requires an upper required action limit of 1.030r and 1.03~Pr where Or is the reference flow rate and ~Pr is the reference differential pressure.

ISTB-5223, "Comprehensive Test Procedure" refers to table ISTB-5221-1 which requires an upper required action limit of 1.030r and 1.03~Pr where Or is the reference flow rate and ~Pr is the reference differential pressure.

ASME OM Code Case, OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test,"

states, in part, that "a 1.06 times the reference value may be used in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in the ISTB test acceptance criteria tables."

The components affected by this alternative request are listed in Table 2 below.

Table 2: Pumps Affected by Alternative Request P-6, Unit 1 Design Pump System Code Pump Description Basis PPV Test Group Class Type Flow Required Rate (gpm) 1-CC-P-1A Component 3

Centrifugal Component Cooling None No 1-CC-P-1 B Cooling Water Pump 1-CC-P-2A Component 3

Centrifugal Component Cooling 30 Yes 1-CC-P-2B Cooling Water Pump to Charging Pump 1-CH-P-1A Chemical and 2

Centrifugal High Head Safety 436 1-CH-P-1 B Volume Control Injection I Charging 1-CH-P-1C I Safety Pump Injection 1-CH-P-2A Chemical and 2

Centrifugal Boric Acid Transfer None 1-CH-P-28 Volume Control Pump 1-FW-P-2 Auxiliary 3

Centrifugal Auxiliary Feedwater 400 Feedwater Motor Driven Pump 1-FW-P-3A Auxiliary 3

Centrifugal Auxiliary Feedwater 300 1-FW-P-38 Feedwater Motor Driven Pump 1-RH-P-1A Residual Heat 2

Centrifugal Residual Heat Removal None 1-RH-P-18 Removal Pump 1-RS-P-1A Recirculation 3

Vertical Inside Containment 3100 1-RS-P-18 Spray Line Shaft Recirculation Spray Centrifugal Pump 1-RS-P-2A Recirculation 3

Vertical Outside Containment 2900 1-RS-P-28 Spray Line Shaft Recirculation Spray Centrifugal Pump 1-SI-P-1A Safety Injection 3

Vertical Low Head Safety 2901 1-SI-P-1 B Line Shaft Injection Pump Centrifugal 1-SW-P-1A Service Water 3

Vertical Emergency Service 14550 1-SW-P-1 B Line Shaft Water Pump 1-SW-P-1C Centrifugal 1-SW-P-Service Water 3

Centrifugal Service Water Pump to 42 10A Charging Pump 1-SW-P-108 1-VS-P-1A Ventilation 3

Centrifugal Main Control Room Air None 1-VS-P-1 B Conditioning System 1-VS-P-1C Condenser Water Pump 1-VS-P-1D Ventilation 3

Centrifugal Main Control Room Air None 1-VS-P-1 E Conditioning System Condenser Water Pump 1-VS-P-2A Ventilation 3

Centrifugal Main Control Room Air None 1-VS-P-28 Conditioning System 1-VS-P-2C Chilled Water Pump 1-VS-P-2D Ventilation 3

Centrifugal Main Control Room Air None 1-VS-P-2E Conditioning System Chilled Water Pump

Reason for Request

For some pump tests, Surry has had difficulty implementing the upper required action range limit of 1.03 percent above the established hydraulic parameter reference value for the comprehensive pump test. The difficulty arises when normal data scatter yields (1) a low measured reference value, and (2) high measured values for subsequent inservice tests. In these cases, some of the test data trend high near the upper required action range limit and Yes No Yes Yes No Yes Yes Yes Yes Yes No No No No may exceed the upper limit on occasion. The problem can be more severe for pumps with low differential pressures (50 psid or less) due to the smaller acceptable range.

Proposed Alternative For the pumps listed in Table 2, the licensee proposed the use of an upper required action limit of 1.06 percent times the reference value for comprehensive pump tests in accordance with ASME OM Code Case OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test."

In addition, the licensee will perform a pump periodic verification (PPV) test for pumps that have a DBA flow rate as indicated in Table 2.

For the pumps listed in Table 2, an upper required action limit of 1.06 percent times the reference value will be applied to the comprehensive pump test in accordance with ASME OM Code Case OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test." Also, for pumps that have a DBA flow rate, a PPV test will be performed. Table 2 identifies the pumps that have a DBA flow rate and indicates that a PPV test will be performed for these pumps.

Table 2 includes all of the ASME Code Class pumps in the Surry 1ST program except for the containment spray (CS) pumps. The DBA flow rate cannot be achieved for the CS pumps with the existing test loop configuration. Therefore, the upper limit of 1.03 percent times the reference value will still be applied to the comprehensive pump test for the CS pumps. The reason the remaining pumps are included in the alternative request is that data scatter can affect future tests for any of these pumps.

The following requirements shall be applied to the PPV test:

1 ).

Apply the PPV test to pumps with a DBA flow rate as identified in Table 2.

2)

Perform the PPV test at least once every 2 years.

3)

Determine if a PPV test is required before declaring a pump operable following replacement, repair, or maintenance on the pump.

4)

Declare the pump inoperable if the PPV test flow rate and associated differential pressure cannot be achieved.

5).

Maintain the necessary records for PPV test, including the applicable test parameters (e.g., flow rate and the associated differential pressure and speed for variable speed pumps) and their basis.

6)

Account for the PPV test instrument accuracies in the test acceptance criteria.

NRC Staff Evaluation

The ASME OM Code Case OMN-19 allows the use of a multiplier of 1.06 times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in Table ISTB-5121-1 and Table ISTB-5221-1. Code Case OMN-19 has not been added to Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," and the 2011 Addenda of the ASME OM Code has not been incorporated by reference into 10 CFR 50.55a.

The NRC staff reviewed the proposed alternative OMN-19 published in the ASME OM Code 2011 Addenda, which the licensee proposed as an alternative, along with the requirements the licensee will apply to the punip periodic verification test. The licensee has stated that when implementing a pump periodic verification test program, the licensee shall:

(a)

Identify those certain applicable pumps with specific DBA flow rates in the licensee's credited safety analysis (e.g., technical specifications, technical requirements program, or updated safety analysis report) for inclusion in this program.

(b)

Perform the pump periodic verification test at least once every two years.

(c)

Determine whether the pump periodic verification test is required before declaring the pump operable following replacement, repair, or maintenance on the pump.

(d)

Declare the pump inoperable if the pump periodic verification test flow rate and associated differential pressure (or discharge pressure for positive displacement pumps ) cannot be achieved.

(e)

Maintain the necessary records for the pump periodic verification tests, including the applicable test parameters (e.g., flow rate and associated differential pressure, or flow rate and associated discharge pressure, and speed for variable speed pumps) and their basis.

(f)

Account for the pump periodic verification test instrument accuracies in the test acceptance criteria.

The NRC staff notes that the licensee is not required to perform a pump periodic verification test if the DBA flow rate in the licensee's safety analysis is bounded by the comprehensive pump test or Group A test.

The licensee will perform a PPV test that meets the requirements listed above on pumps that have a design basis flow rate as listed in Table 2 every 2 years. NRC staff determined that licensees choosing to implement OMN-19 must implement a pump periodic verification test program to verify that a pump can meet the required (differential or discharge) pressure as applicable, at its highest DBA flow rate. The performance of this test provides reasonable assurance that these pumps will perform at design basis conditions when needed and provides reasonable assurance that the licensee can detect and monitor pump degradation. The licensee's proposed alternative will perform the pump periodic verification test along With ASME OM Code Case OMN-19 requirements. Based on the licensee's proposed alternative to perform a pump periodic verification test on pumps with a design basis flow rate along with ASME OM Code Case OMN-19 requirements, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) to the specific requirements of ISTB-5123 and ISTB-5223, and Table ISTB-5121-1 and Table ISTB-5221-1.

The proposed alternative will be used for the Surry, Unit 1, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

3.6 Surry, Unit 2, Alternative Request P-1 In its submittal, the licensee proposed an alternative to the ASME OM Code vibration testing requirements for the pumps listed in Table 3 below. The licensee requests an alternative to the requirements of ASME OM Code paragraphs ISTB-3300, ISTB-5120, ISTB-5121, ISTB-5123, and ISTB-5220, ISTB-5221, ISTB-5223, and Table ISTB-5121-1 and Table ISTB-5221-1 for the pumps listed in Table 3.

ISTB-3300, "Reference Values," defines the requirements for obtaining reference values for the inservice testing of pumps.

ISTB-3300, "Reference Values," (a) states that "initial reference values be determined from the results of testing meeting the requirements of ISTB-31 00, "Preservice Testing," or from the results of the first inservice test."

ISTB-3300, "Reference Values," (d) states that "reference values shall be established at point(s) of operation (reference point) readily duplicated during subsequent testing."

ISTB-3300, "Reference Values," (f) states that "all subsequent test results shall be compared to these initial reference values or to new reference values established in accordance with ISTB-3310, ISTB-3320, or ISTB-6200(c)."

ISTB-5120, "lnservice Testing" (Centrifugal Pumps, Except Vertical Line Shaft Centrifugal Pumps), ISTB-5121, "Group A Test Procedure," (e), and ISTB-5123,"Comprehensive Test Procedure", (e), state that all deviations from the reference values shall be compared with the ranges of Table ISTB-5121-1 and corrective action taken as specified in ISTB-6200. The vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5121-1.

ISTB-5220, "lnservice Testing" (Vertical Line Shaft Centrifugal Pumps), ISTB-5221, "Group A Test Procedure," (e) and ISTB-5223, "Comprehensive Test Procedure," (e), state that all deviations from the reference values shall be compared with the ranges of Table ISTB-5221-1 and corrective action taken as specified in ISTB-6200. The vibration measurements shall be compared to both the relative and absolute criteria shown in the alert and required action ranges of Table ISTB-5221-1.

Table 3: Pumps Affected by Alternative Request P-1, Unit 2 Pump System Code OM Description GrouR_

Class Group 1-CC-P-1C Component 3

A Component Cooling Water Pump 1-CC-P-1 D Cooling 2-CC-P-2A Component 3

A Component Cooling Water Pump 2-CC-P-28 Cooling to Charging Pump 2-CH-P-1A Chemical and 2

A High Head Safety Injection I 2-CH-P-18 Volume Control I Charging Pump 2-CH-P-1C Safety Injection 1-CH-P-2C Chemical and 2

A Boric Acid Transfer Pump 1-CH-P-2D Volume Control 2-FW-P-3A Auxiliary 3

B Auxiliary Feedwater Motor Driven Feedwater Pump 2-RH-P-1A Residual Heat*

2 A

Residual Heat Removal Pump 2-RH-P-1 B Removal 2-SW-P-10A Service Water 3

A Service Water Pump to Charging 2-SW-P-108 Pump The pumps listed in Table 3 have at least one Vr that is currently less than 0.05 inches per second (ips). Small values for Vr produce small acceptable ranges for pump operation. The acceptable ranges are defined in Tables ISTB-5121-1 and ISTB-5221-1 as less than or equal to 2.5Vr. Based on a small acceptable range, a smooth running pump could be subject to unnecessary corrective action if the measured vibration parameter exceeds this acceptable range.

For very small reference values, hydraulic noise and instrument error can be a significant portion of the reading and affect the repeatability of subsequent measurements. Also, experience gathered from the North Anna preventive maintenance program has shown that changes in vibration levels in the range of 0.05 ips do not normally indicate significant degradation in pump performance.

To avoid unnecessary corrective action, a minimum value for Vr of 0.05 ips has been established for velocity measurements. This minimum value will be applied to individual vibration locations for the pumps listed in Table 3 where the measured reference value is less than 0.05 ips.

When new reference values are established per ISTB-3310, ISTB-3320 or ISTB-6200(c), the measured parameters will be evaluated for each location to determine if the provisions of this relief re.quest still apply.

In addition to the requirements of ISTB, the pumps in the ASME 1ST Program are included in the Surry Predictive Maintenance Program. The Surry Predictive Maintenance Program currently employs predictive monitoring techniques such as:

vibration monitoring and analysis beyond that required by ISTB, and oil sampling and analysis where applicable (e.g., for pumps with sufficiently large oil reservoirs).

If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may include:

increased monitoring to establish rate of change, review of component specific information to identify cause, and removal of the pump from service to perform maintenance.

It should be noted that all of the pumps in the 1ST Program will remain in the Predictive Maintenance Program even if certain pumps have very low vibration readings and are considered to be smooth running pumps. The licensee states this alternative to the requirements of ISTB-3300, ISTB-5120 and ISTB-5220, and Table ISTB-5121-1 and Table ISTB-5221-1 provides an acceptable level of quality and safety.

Proposed Alternative The licensee proposed an alternative to the reference value requirements of ISTB-3300 for the pumps listed in Table 3, whereas pumps with a measured reference value below 0.05 ips for a particular vibration measurement location shall have subsequent test results for that location compared to an acceptable range based on 0.05 ips. The licensee's proposed alternative states it will maintain all pumps in the 1ST Program in the Surry Predictive Maintenance Program as well, regardless of their smooth running status.

NRC Staff Evaluation

The NRC staff notes that pumps with vibration levels of 0.1 ips or less are generally considered "smooth running pumps," and that the licensee's proposed minimum vibration level is well below this point. In addition, as per ASME OM Code Table ISTB-5121-1, the alert range for pumps that operate with a pump speed greater than 600 rpm is 0.325 to 0. 7 ips. Therefore, action is required for vibration greater than 0.7 ips. The pumps listed in Table 3 operate with pump speeds greater than 600 rpm. It is also noted that for reference values smaller than 0.05 ips, hydraulic noise and instrument error can be a significant portion of the reading and therefore affect the repeatability of subsequent measurements. If a very small reference value were utilized, non-repeatable measurements may result in unnecessary testing or maintenance.

Therefore, the NRC staff finds the licensee's proposal to use 0.05 ips as a minimum threshold in the evaluation of vibration velocity is conservative and acceptable.

The licensee has also included the pumps in Table 3 in Surry's Predictive Maintenance Program, which includes additional vibration monitoring and oil sampling and analysis. The NRC staff notes that the performance of these additional monitoring techniques, along with application of the alternative alert and action ranges proposed by the licensee, provides reasonable assurance that the licensee will be able to detect degradation of the pumps listed in Table 3.

Based on the alternative limits proposed by the licensee for vibration monitoring of the pumps listed in Table 3, and the inclusion of these pumps in Surry's Predictive Maintenance-Program, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) for vibration testing of the pumps listed in Section 3.6 of this safety evaluation.

The proposed alternative will be used for the Surry, Unit 2, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014, and end on May 9, 2024.

3. 7 Surry, Unit 2, Alternative Request P-3 In its submittal, the licensee requested relief from Table ISTB-3500-1 and ISTB-351 O(b)(1 ).

Table ISTB-3500-1, "Required Instrument Accuracy," requires that Group A test pressure instrument accuracy shall be within +/- 2 percent.

~

ISTB-351 0, "General," (b )(1) states that the full-scale range of each analog instrument shall be not greater than three times the reference value.

The components affected by this relief request are Boric Acid Transfer Pumps 1-CH-P-2C and 1-CH-P-20. The pumps are classified as Group A pumps in the 1ST Program and function to supply boric acid to the suction of the charging pumps for emergency boration.

Reason for Request

j Calibrating the inlet pressure instruments for the boric acid transfer pumps to an accuracy within

+/- 2 percent has proven difficult and may be impractical in the future with the current instruments. Calibrating the inlet pressure instruments to an accuracy within +/-3 percent would be practical.

The inlet pressure gauges have a full scale range of 0 to 15 pounds per square inch gauge (psig). These instruments were sized by evaluating the static pressures present at the suction side of the pumps and applying the three times rule of ISTB-351 O(b)(1 ). The static pressures range from 6 to 7 psig.

When the pumps are started, the pressure at the suction side of the pumps drops to approximately 2 psig; therefore, the inlet pressure gauges do not meet the three times rule for dynamic inlet pressure.

Using a lower range pressure gauge (i.e. 0 to 5 psig) would meet the three times rule for dynamic inlet pressure; however, the lower range gauge would be repeatedly exposed to an over range condition (static pressures in excess of 5 psig) which would damage the instruments.

Using a lower range temporary gauge on a 'quarterly basis presents a hardship because the process fluid contains boric acid and is contaminated. If contaminated, the temporary instruments would probably become waste material. However, with the current 0 to 15 psig inlet pressure gauges calibrated to +/- 3 percent, a differential pressure can be determined that exceeds the accuracy requirements 'for differential pressure.

Each boric acid transfer pump discharge pressure gauge (0 to 150 psig range) has an instrument loop accuracy of 1.59 percent. Computing the maximum error for differential pressure using the current instrument configuration and an inlet pressure gauge accuracy of

+/- 3 percent, yields an error of 2.85 psid.

Computing the ASME OM Code allowed error for differential pressure for an inlet pressure gauge with a 2 percent accuracy and a 0 to 5 psig range and a discharge pressure instrument with a 2 percent accuracy and a 0 to 150 psig range yields an error of 3.1 psid. With the current instrument configuration, the loop accuracy of each discharge pressure instrument could be as high as 1. 75 percent, which equates to a 3.075 psid error, and still be within the ASME OM Code allowed error of 3.1 psid for differential pressure. Therefore, for purposes of trending pump degradation using differential pressure and flow, the current instrument is adequate as long as the discharge pressure instrument loop accuracies remain at or below 1. 75 percent.

Proposed Alternative The licensee proposed to use inlet pressure gauges with a full-scale range of 0 to 15 psig and calibrated to an accuracy within +/- 3 percent in order to measure dynamic inlet pressures.

Also, the licensee's alternative prosed to maintain loop accuracies for the discharge pressure gauges at or below an accuracy of 1.75 percent to ensure that the differential pressure error is below the differential pressure error allowed by the ASME OM Code.

NRC Staff Evaluation

The boric acid transfer pumps 1-CH-P-2C and 1-CH-P-20 supply boric acid to the suction of the charging pumps for emergency boration. The inlet pressures to these boric acid transfer pumps vary significantly between their standby and operating modes. The static inlet pressure available to the pumps during operation is 6 to 7 psig. However, when the pumps are started, the inlet pressure drops to about 2 psig. When the inlet pressure drops to 2 psig, ISTB-351 O(b )( 1) requires that the inlet gauges must have a range of 0 to 6 psig. However, NRC staff notes that the use of a 0 to 6 psig range gauge would be unsuitable at static inlet pressures due to the possibility of damaging the gauge by over-ranging.. To meet the ASME OM Code requirements, the licensee would be required to install temporary instruments at the inlet of the boric acid transfer pumps prior to each quarterly test.

The ASME OM Code, Table ISTB-3500-1 requires that Group A test pressure instrument accuracy be within +/- 2 perbent, and ISTB-351 O(b)(1 ).requires that the full-scale range of each analog instrument not be greater than three times the reference value. The licensee has proposed an alternative to the above ASME OM Code requirements because they have determined that the instruments do not meet the ASME OM Code accuracy and range requirements for boric acid transfer pumps 1-CH-P-2C and 1-CH-P-20. As such, the licensee proposed an alternative to the Table ISTB-3500-1 and ISTB-351 O(b )( 1) requirem13nts that would test the pumps with 0 to 15 psig, full-scale range inlet pressure gauge, accurate to within

+/- 3 percent for the measurement of dynamic inlet pressures. Additionally, the licensee stated that the loop accuracies for the discharge pressure gauges will be maintained at or below an accuracy of 1.75 percent to ensure that the differential pressure error is below the differential pressure error allowed by the ASME OM Code.

Section 5.5.1 of NUREG-1482 states that although instrument modifications are considered practical in the, context of 10 CFR 50.55a(f)(4), the use of available instruments that meet the intent of the ASME OM Code requirements for the actual reading would yield an acceptable level of quality and safety for testing.

The NRC staff reviewed the ASME OM Code Table ISTB-3500-1 and ISTB-3510(b)(1) requirements. The intent of these requirements is to ensure that the range and accuracy readings obtained from flow and pressure instrumentation are within a range small enough to make degradation monitoring meaningful. The licensee's proposed alternative meets the intent of the ASME OM Code requirements, since the combination of errors in the proposed alter11ative results in errors less than the combined errors of instrumentation that strictly meets the ASME OM Code requirements. The licensee has committed to calibrate the accuracy of the 0 to 15 psig range inlet pressure gauges to within +/- 3 percent and will maintain loop accuracies for the discharge pressure gauges at or below an accuracy of 1. 75 percent to ensure that the intent of the ASME OM Code is maintained for testing of boric acid transfer pumps 1-CH-P-2C and 1::.CH-P-20.

Based on the proposed alternative to limit discharge pressure to 1. 75 percent and calibrate the suction gauge to within 3 percent, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55(a)(3)(i) for the 1ST of boric acid transfer pumps 1-CH-P-2C and 1-CH-P-20.

The proposed alternative will be used for the Surry, Unit 2, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

3.8 Surry, Unit 2. Alternative Request P-4 In its submittal, the licensee proposed an alternative to the requirements of IST8-3510(b)(1).

IST8-351 0, "General," (b)( 1) states that "The full-scale range of each analog instrument shall be not greater than three times the reference value."

The components affected by this alternative request are charging pump cooling water pumps 2-CC-P-2A and 2-CC-P-28. The pumps are classified as Group A pumps in the 1ST Program and function to supply cooling water to transfer heat from the charging pump mechanical seals.

Reason for Request

Installed inlet pressure gauges used for the Group A tests have a full scale range of 0 to 3.5 psig. Readings from these inlet pressure gauges over the past year indicate that the dynamic pressures fall within the bottom third of full scale. However, the difference in the error between the 0 to 3.5 psig gauges and gauges that would meet the three times full-scale rule are so small that the 0 to 3.5 psig gauges can be considered to be equivalent in terms of accuracy for determining differential pressure.

For example, inlet pressures as low as 0.8 psig have been recorded for pump 1-CC-P-28. A gauge that meets the three times full-scale rule would have a full scale of 2.4 psig or less. A 2 percent accuracy for the 2.4 psig gauge translates to an error of 0.05 psig. A 2 percent accuracy for the 3.5 psig gauge translates to an error of 0.07 psig. The difference in error of 0.02 psig is insignificant when determining the differential pressures for these pumps which range between 50 and 60 psig. Therefore, the two gauges can be considered to be equivalent in terms of accuracy for determining differential pressure.

Proposed Alternative The licensee proposed to measure pump suction pressure with gauges that have a full scale of 0 to 3.5 psig for charging pump cooling water pumps 2-CC-P-2A and 2-CC-P-28.

NRC Staff Evaluation

The charging pump cooling water pumps 2-CC-P-2A and 2-CC-P-28 are Group A, Class 3 pumps that are part of the CCW System. The pumps supply cooling water to transfer heat from the charging pump mechanical seals. These pumps have been recorded to have inlet pressures as low as 0.8 psig and commonly have differential pressures that range from 50 to 60 psig.

The ASME OM Code, IST8-3510(b)(1) requires that the full-scale range of each analog instrument shall be not greater than three times the reference value. The licensee has requested relief from ASME OM Code requirements because the use of a gauge with a full-scale range of 0 to 3.5 psig would provide an adequate level of quality and safety for the measurement of inlet pressures to the charging pump cooling water pumps 2-CC-P-2A and 2-CC-P-28.

(

J The NRC staff has reviewed the ISTB-351 O(b )( 1) requirements and has determined that there would be a negligible accuracy error in determining the differential pressures across these pumps when a 0 to 3.5 psig gauge is used as compared to a gauge that would meet the three times full-scale rule. (a 0 to 2.4 psig gauge). Therefore, the use of the inlet pressure gauge with a full-scale range of 0 to 3.5 psig will provide an acceptable level of quality and safety for the operation of the charging pump cooling water pumps.

Based on the negligible errors introduced by use of an inlet pressure gauge with a full-scale range of 0 to 3.5 psig when compared to differential pressures that range between 50 and 60 psig, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(3)(i) for Group A testing of charging pump cooling water pumps 2-CC-P'-2A and 2-CC-P-2B.

The proposed i31ternative will be used for the Surry, Unit 2, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

3.9 Surrv. Unit 2. Alternative Request P-5 In its submittal, the licensee requested an alternative to the comprehensive pump testing requirements of ISTB-5123 and ISTB-5223.

ISTB-5123, "Comprehensive Test Procedure" refers to table ISTB-5121-1 which requires an upper required action limit of 1.030r and 1.03L1Pr where Or is the reference flow rate and L1Pr is the reference differential pressure.

ISTB-5223, "Comprehensive Test Procedure" refers to table ISTB-5221-1 which requires an upper required action limit of 1.030r and 1.03L1Pr where Or is the reference flow rate and L1Pr is the reference differential pressure.

ASME OM Code Case, OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test,"

states, in part, that "a 1.06 times the reference value may be used in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in the ISTB test acceptance criteria tables."

The components affected by this alternative request are listed in Table 4 below.

Table 4: Pumps Affected by Alternative Request P-5, Unit 2 Design Pump System Code Pump Description Basis PPV Test Group Class Type Flow Required Rate (gpm) 1-CC-P-1C Component 3

Centrifugal Component Cooling None No 1-CC-P-1D Cooling Water Pumps 2-CC-P-2A Component 3

Centrifugal Component Cooling 30 Yes 2-CC-P-2B Cooling Water Pump to Charging Pump

I 2-CH-P-1A Chemical and 2

Centrifugal High Head Safety 436 2-CH-P-1 B Volume Control Injection I Charging 2-CH-P-1C I Safety Pump Injection 1-CH-P-2C Chemical and

• 2 Centrifugal Boric Acid Transfer None 1-CH-P-2D Volume Control Pumps 2-FW-P-2 Auxiliary 3

Centrifugal Auxiliary Feedwater 400 Feedwater Turbine Driven Pump 2-FW-P-3A Auxiliary 3

Centrifugal Auxiliary Feedwater 300 2-FW-P-3B Feedwater Motor Driven Pump 2-RH-P-1A Residual Heat 2

Centrifugal Residual Heat Removal None 2-RH-P-1 B Removal Pump 2-RS-P-1A Recirculation 3

Vertical Inside Containment 3100 2-RS-P-1 B Spray Line Shaft Recirculation Spray Centrifugal Pump 2-RS-P-2A Recirculation 3

Vertical Outside Containment 2900 2-RS-P-2B Spray Line Shaft Recirculation Spray Centrifugal Pump 2-SI-P-1A Safety Injection 3

Vertical Low Head Safety 2901 2-SI-P-1 B Line Shaft Injection Pump Centrifugal

)

2-SW-P-10A Service Water 3

Centrifugal Service Water Pump to 42 2-SW-P-10B Charging Pump

Reason for Request

For some pump tests, Surry has had difficulty implementing the upper required action range limit of 1.03 percent above the established hydraulic parameter reference value for the comprehensive pump test. The difficulty arises when normal data scatter yields (1) a low measured reference value, and (2) high measured values for subsequent inservice tests. In these cases, some of the test data trend high near the upper required action range limit and may exceed the upper limit on occasion. The problem can be more severe for pumps with low differential pressures (50 psid or less) due to the smaller acceptable range.

Proposed Alternative Yes No Yes Yes No Yes Yes Yes Yes For the pumps listed in Table 4, the licensee has proposed the use of an upper required action limit of 1.06 percent times the reference value for comprehensive pump tests in accordance with ASME OM Code Case OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test."

In addition, the licensee will perform a PPV test for pumps that have a DBA flow rate as indicated in Table 4.

For the pumps listed in Table 4, an upper required action limit of 1.06 percent t.imes the reference value will be applied to the comprehensive pump test in accordance with ASME OM Code Case OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test." Also, for pumps that have a DBAt flow rate, a PPV test will be performed. Table 4 identifies the pumps that have a DBAt flow rate and indicates that a PPV test will be performed for these pumps.

Table 4 includes all of the ASME Code Class pumps in the Surry 1ST program except for the containment spray (CS) pumps. The DBA flow rate cannot be achieved for the CS pumps with the existing test loop configuration. Therefore, the upper limit of 1.03 percent times the reference value will still be applied to the comprehensive pump test for the CS pumps. The reason the remaining pumps are included in the alternative request is that data scatter can affect future tests for any of these pumps.

The following requirements shall be applied to the PPV test:

1) Apply the PPV test to pumps with a DBA flow rate as identified in Table 4.

2} Perform the PPV test at least once every 2 years.

3} Determine if a PPV test is required before declaring a pump operable following replacement, repair, or maintenance on the pump.

4) Declare the pump inoperable if the PPV test flow rate and associated differential pressure cannot be achieved.

5) Maintain the necessary records for PPV test, including the applicable test parameters (e.g.,

flow rate and the associated differential pressure and speed for variable speed pumps) and their basis.

6) Account for the PPV test instrument accuracies in the test acceptance criteria.

NRC Staff Evaluation

The ASME OM Code Case OMN-19 allows the use of a multiplier of 1.06 times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in Table ISTB-5121-1 and Table ISTB-5221-1. The Code Case OMN-19 has not been added to Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code,'(and the 2011 Addenda of the ASME OM Code has not been incorporated by reference into 10 CFR 50.55a.,

The NRC staff reviewed the proposed alternative OMN-19 published in the ASME OM Code 2011 Addenda, which the licensee proposed as an alternative, along with the requirements the licensee will apply to the pump periodic verification test. The licensee has stated that when implementing a pump periodic verification test program, the licensee shall:

When implementing a pump periodic verification test program, the licensee shall:

(a)

Identify those certain applicable pumps with specific DBA flow rates in the licensee's credited safety analysis (e.g., technical specifications, technical requirements program, or updated safety analysis report) for inclusion i[l this program.

(b)

Perform the pump periodic verification test at least once every two years.

(c)

Determine whether the pump periodic verification test is required before declaring the pump operable following replacement, repair, or maintenance on the pump.

(d)

Declare the pump inoperable if the pump periodic verification test flow rate and associated differential pressure (or discharge pressure for positive displacement pumps ) cannot be achieved.

(e)

Maintain the necessary records for the pump periodic verification tests, including the applicable test parameters (e.g., flow rate and associated differ,ential pressure, or.

flow rate and associated discharge pressure, and speed for variable speed pumps) and their basis.

(f)

Account for the pump periodic verification test instrument accuracies in the test acceptance criteria.

The NRC staff notes that the licensee is not required to perform a pump periodic verification test if the DBA flow rate in the licensee's safety analysis is bounded by the comprehensive pump test or Group A test.

The licensee will perform a PPV test that meets the requirements listed above on pumps that have a design basis flow rate as listed in Table 4 every 2 years. NRC staff determined that licensees choosing to implement OMN-19 must implement a pump periodic verification test program to verify that a pump can meet the required (differential or discharge) pressure as applicable, at its highest DBA flow rate. The performance of this test provides reasonable assurance that these pumps will perform at design basis conditions when needed and provides reasonable assurance that the licensee can detect and monitor pump degradation. The licensee's proposed alternative will perform the pump periodic verification test along with ASME OM Code Case OMN-19 requirements. Based on the licensee's proposed alternative to perform a pump periodic verification test on pumps with a design basis flow rate along with ASME OM Code Case OMN-19 requirements, the NRC staff finds that the licensee's proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) to the specific requirements of ISTB-5123 and ISTB-5223, and Table ISTB-5121-1 and Table ISTB-5221-1 for the pumps listed in Table 4.

The proposed alternative will be used for the Surry, Unit 2, fifth 1 0-year 1ST Interval which is currently scheduled to start on May 10, 2014 and end on May 9, 2024.

4.0 CONCLUSION

As set forth above, the NRC staff finds that the proposed alternatives described in Relief Requests P-1, P-4, P-5, and P-6 for Surry, Unit 1, and P-1, P-4, and P-5 for Surry, Unit 2, provide an acceptable level of quality and safety for the specific pumps in the Chemical Volume and Control System, the Component Cooling Water System, the Containment Spray System, the Auxiliary Feedwater System, the Residual Heat Removal System, the Service Water System, Recirculation Spray System, Safety Injection System, and the Ventilation System described in the relief requests above. 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)(i) for requests P-1, P-4, P-5, and P-6 for Surry, Unit 1, and for requests P-1, P~4, and P-5 for Surry, Unit 2, and is in compliance with the ASME OM Code requirements.

Therefore, the NRC staff authorizes Relief Requests P-1, P-4, P-5, and P-6 for Surry, Unit 1, and Relief Requests P-1, P-4, and P-5 for Surry, Unit 2, for the fifth 10-year 1ST program interval, which is scheduled to begin on May 10, 2014 and end on May 9, 2024.

For Relief Request P-3 on Surry, Unit 1, and Surry, Unit 2, the licensee's submittal requested relief from the ASME OM Code requirements in accordance with 10 CFR 50.55a(a)(3(i) and 10 CFR 50.55a(f)(6)(i) and proposed an alternative to the ASME OM Code requirements. The NRC staff evaluated the licensee's requests as proposed alternatives to the ASME OM Code requirements in accordance with 10 CFR 50.55a(a)(3)(i). As set forth above, the NRC staff determines that for the licensee's request P-3 for Surry, Unit 1, and request P-3 for Surry, Unit 2, the proposed alternatives provide an acceptable level of quality and safety. 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)(i) for request P-3 for Surry, Unit 1, and for request P-3 for Surry, Unit 2, and is in compliance with the ASME Orv1 Code requirements.

Therefore, the NRC staff authorizes Relief Request P-3 for Surry, Unit 1, and P-3 for Surry, Unit 2, for the fifth 1 0-year 1ST program interval, which is scheduled to begin on May 10, 2014 and end on May 9, 2024.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests remain applicable.

Principle Contributor: Jason Carneal, NRR Date: May 9, 2014

ML14125A471 Sincerely,

/RAJ Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

• via e-mail OFFICE NRR/DORL/LPL2-1 /PM NRR/DORL/LPL2-1/LA NRR/EPNB NRR!DORLILPL2-1 /BC NAME MBarillas SFigueroa Tlupold RPascarelli DATE 05/08/14 05/08/14 02/14/14 05/09/14