CNL-14-229, American Society of Mechanical Engineers Request for Relief RP-07

American Society of Mechanical Engineers Request for Relief RP-07

ML14365A207
Person / Time
Site:	Sequoyah
Issue date:	12/31/2014
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-14-229
Download: ML14365A207 (6)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga , Tennessee 37402 CNL-14-229 December 31 , 2014 10 CFR 50.4 10 CFR 50 .55a ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

American Society of Mechanical Engineers Request for Relief RP-07 In accordance with 10 CFR 50 .55a , "Codes and standards," the Tennessee Valley Authority (TVA) requests NRC approval of the enclosed Request for Relief RP-07 for the Sequoyah Nuclear Plant (SQN) , Units 1 and 2. The Code of Record for the current third 10-year interval is the 2001 Edition through 2003 Addenda of the American Society of Mechanical Engineers (ASME) , "Code for Operation and Maintenance of Nuclear Power Plants" (OM Code) .

TVA seeks to perform future inservice pump testing at SQN , in a manner consistent with the requirements stated in ASME OM Code Case OMN-21 . Specifically, testing of the pumps identified in the enclosure will be performed such that flow rate, or differential pressure, is adjusted as close as practical to the reference value and within tolerance limits of +2% I -1%

for flow rate, or +1% I -2% for differential pressure .

TVA requests approval of the proposed alternative by December 31 , 2015. The proposed alternative will be utilized for the remainder of the third 10-year interval , and for the entire fourth 10-year interval.

There are no new regulatory commitments contained in this letter. Please address any questions regarding this submittal to Erin Henderson at (423) 843-7170 .

J. W. Shea Vice President, Nuclear Licensing Enclosure cc: See Page 2

U.S. Nuclear Regulatory Commission Page 2 December 31 , 2014

Enclosure:

Request for Relief RP-07 cc (Enclosure) :

NRC Regional Administrator- Reg ion II NRC Senior Resident Inspector - Sequoyah Nuclear Plant

ENCLOSURE TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE RELIEF REQUEST REQUEST FOR RELIEF RP-07

TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNIT 1 and 2 REQUEST FOR RELIEF RP-07 I. ASME Code Components Affected Pump ID Pump Description Pump Type Code OM Class Group 0-PMP-67 -432 Essential Raw Cooling Water Vertical Line 3 A 0-PMP-67 -436 Pumps Shaft 0-PM P-67 -440 0-PMP-67 -444 0-PMP-67 -452 0-PMP-67 -456 0-PMP-67 -460 0-PMP-67 -464 0-PMP-70-51 Component Cooling Water Pumps Centrifugal 3 A 1-PMP-70-38 1-PMP-70-46 2-PMP-70-33 2-PMP-70-59 0-PMP-313-303 Shutdown Board Room Chilled Centrifugal 3 A 0-PMP-313-338 Water Pumps 1-PMP-62-230 Boric Acid Transfer Pumps Centrifugal 3 A 1-PMP-62-232 2-PMP-62-230 2-PMP-62-232 1-PMP-63-1 0 Safety Injection Pumps Centrifugal 2 B 1-PM P-63-15 2-PMP-63-10 2-PMP-63-15 1-PMP-72-1 0 Containment Spray Pumps Centrifugal 2 B 1-PMP-72-27 2-PMP-72-1 0 2-PMP-72-27 1-PMP-3-118 Auxiliary Feedwater (Motor) Pumps Centrifugal 3 A 1-PMP-3-128 2-PMP-3-118 2-PMP-3-128 E-1 of 3

Pump ID Pump Description Pump Type Code OM Class Group 1-PMP-3-142 Auxiliary Feedwater (Steam) Pumps Centrifugal 3 B 2-PMP-3-142 1-PMP-62-104 Centrifugal Charging Pumps Centrifugal 2 A 1-PMP-62-1 08 2-PMP-62-1 04 2-PMP-62-1 08 1-PMP-74-10 Residual Heat Removal Pumps Centrifugal 2 A 1-PMP-7 4-20 2-PMP-74-10 2-PMP-7 4-20 II. ASME Code Edition and Addenda ASME OM Code 2001 Edition through 2003 Addenda Ill. Applicable Code Requirement ISTB-5121 , "Group A Test Procedure": ISTB-5121 (b) states that, "The resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value ."

ISTB-5122 , "Group B Test Procedure": ISTB-5122(c) states that, "System resistance may be varied as necessary to achieve the reference point."

ISTB-5123, "Comprehensive Test Procedure": ISTB-5123(b) states that, "For centrifugal and vertical line shaft pumps, the resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value ."

ISTB-5221 , "Group A Test Procedure": ISTB-5221 (b) states that, "The resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively , the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value ."

ISTB-5222, "Group B Test Procedure": ISTB-5222(c) states that, "System resistance may be varied as necessary to achieve the reference point."

ISTB-5223, "Comprehensive Test Procedure": ISTB-5223(b) states that, "For centrifugal and vertical line shaft pumps, the resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value ."

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IV. Reason for Request Pursuant to 10 CFR 50.55a , "Codes and standards," paragraph (a)(3)(i) , an alternative is proposed to the pump testing reference value requirements of the ASME OM Code for the Sequoyah Nuclear Plant (SQN), Units 1 and 2. The basis for the request is that the proposed alternative provides an acceptable level of quality and safety. Specifically, this alternative is requested for inservice testing of the 1ST Program pumps listed above.

For pump testing , there is difficulty adjusting system throttle valves with sufficient precision to achieve exact flow reference values during subsequent 1ST exams. Section ISTB of the ASME OM Code does not allow for variance from a fixed reference value for pump testing . However, NUREG-1482 , Revision 2, Section 5.3, acknowledges that certain pump system designs do not allow for the licensee to set the flow at an exact value because of limitations in the instruments and controls for maintaining steady flow.

ASME OM Code Case OMN-21 provides guidance for adjusting reference flow/differential pressure to within a specified tolerance during inservice testing . The Code Case states, "It is the opinion of the Committee that when it is impractical to operate a pump at a specified reference point and adjust the resistance of the system to a specified reference point for either flow rate ,

differential pressure or discharge pressure, the pump may be operated as close as practical to the specified reference point with the following requirements. The Owner shall adjust the system resistance to as close as practical to the specified reference point where the variance from the reference point does not exceed +2% or -1% of the reference point when the reference point is flow rate , or +1% or -2% of the reference point when the reference point is differential pressure or discharge pressure."

V. Proposed Alternative and Basis for Use TVA seeks to perform future inservice pump testing at SQN in a manner consistent with the requirements stated in ASME OM Code Case OMN-21. Specifically, testing of the pumps identified in the above table will be performed such that flow rate , or differential pressure, is adjusted as close as practical to the reference value and within tolerance limits of +2% I -1% for flow rate , or +1% I -2% for differential pressure.

Using the provisions of this request as an alternative to the specific requirements of ISTB-5121 ,

ISTB-5122 , ISTB-5123, ISTB-5221 , ISTB-5222 and ISTB-5223 as described above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.

VI. Duration of the Proposed Alternative The proposed alternative will be utilized for the remainder of the third 10-year interval , and for the entire fourth 10-year interval.

VII. Precedents Callaway Plant Unit 1 Relief Request PR-06 (ADAMS No. ML13267A183)

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