ML15033A381

From kanterella
Jump to navigation Jump to search

Response to Request for Additional Information Regarding License Amendment Request for Proposed Technical Specification Change to the Auxiliary Feedwater System
ML15033A381
Person / Time
Site: Millstone Dominion icon.png
Issue date: 01/26/2015
From: Mark D. Sartain
Dominion, Dominion Nuclear Connecticut
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15033A381 (8)


Text

-A,

,JOB-0 Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 Dominioilllf Web Address: www.dom.com January 26, 2015 U.S. Nuclear Regulatory Commission Serial No.14-618 Attention: Document Control Desk NSSL/MLC RO Washington, DC 20555 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR PROPOSED TECHNICAL SPECIFICATION CHANGE TO THE AUXILIARY FEEDWATER SYSTEM By letter dated August 19, 2014, Dominion Nuclear Connecticut, Inc. (DNC) submitted a license amendment request (LAR) for Millstone Power Station Unit 3 (MPS3). The proposed amendment would revise Technical Specification (TS) 3/4.7.1.2, "Auxiliary Feedwater System," Surveillance Requirement 4.7.1.2.1.b. In an email dated December 15, 2014, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) to DNC related to the LAR. to this letter provides DNC's response to the NRC's RAI.

If you have any questions regarding this submittal, please contact Wanda Craft at (804) 273-4687.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering CRAIG D SLY I Notary Public E I Commonwealth of Virginia COMMONWEALTH OF VIRGINIA ) jri eg. # 7518653 2 t MyCommission Expires December_31,_20L

)

COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this ý,01 day of ,T,, (VQ ,2015.

My Commission Expires: . !p4* 31, 1O/6 "Notary Public AOO I PY

Serial No.14-618 Docket No. 50-423 Page 2 of 2 Commitments made in this letter: None Attachments:

1. Response to Request for Additional Information Regarding License Amendment Request For Proposed Technical Specification Change To The Auxiliary Feedwater System
2. 10 CFR 50.55a Request Number P-003, Use of Code Case OMN-6 for Digital Instruments cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 M. C. Thadani Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-B 1 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.14-618 Docket No. 50-423 ATTACHMENT I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR PROPOSED TECHNICAL SPECIFICATION CHANGE TO THE AUXILIARY FEEDWATER SYSTEM DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.14-618 Docket No. 50-423 Attachment 1, Page 1 of 2 By letter dated August 19, 2014, Dominion Nuclear Connecticut, Inc. (DNC) submitted a license amendment request (LAR) for Millstone Power Station Unit 3 (MPS3). The proposed amendment would revise Technical Specification (TS) 3/4.7.1.2, "Auxiliary Feedwater System," Surveillance Requirement (SR) 4.7.1.2.1.b. In an email dated December 15, 2014, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) to DNC related to the LAR. This attachment provides DNC's response to the NRC's RAI.

RAI EPNB-1 SR 4.7.1.2. 1.b currently states required minimum total heads, in feet, for the turbine-driven auxiliary feedwater (TDAFW) pump and the two motor-driven auxiliary feedwater (MDAFW) pumps. Provide the required minimum differential pressures, in pounds per square inch, for each pump.

DNC Response SR 4.7.1.2.1.b states the minimum required head for the motor-driven auxiliary feedwater (MDAFW) pumps, 3FWA*P1A/B, is 3385 feet (ft). The minimum required differential pressure, using a density at 40 OF, is 1467.3 pounds per square inch (psid).

SR 4.7.1.2.1.b states the minimum required head for the turbine driven auxiliary feedwater (TDAFW) pump, 3FWA*P2, is 3780 ft. The minimum required differential pressure, using a density at 40 OF, is 1638.7 psid.

RAI EPNB-2 For each pump, provide the inservice test flow rate reference point value and the differentialpressure reference value for the quarterly test and the comprehensive test.

DNC Response For each pump, see the table provided below for the inservice test flow rate reference point value and the differential pressure reference value for the quarterly test and the comprehensive test.

Serial No.14-618 Docket No. 50-423 Attachment 1, Page 2 of 2 Auxiliary Quarterly Quarterly Test Comprehensive Comprehensive Feedwater Test Flow Differential Test Flow Rate Test Flow Pump ID Rate Pressure Reference Differential Reference Reference Value Pressure Value Value (GPM) Reference (GPM) (PSID) Value (PSID) 3FWA*P1A 48.5 1489.6 544.5 1299.0 3FWA*P1B 50.4 1480.5 542.0 1294.6 3FWA*P2 96.0 1736.9 1072.5 1386.3 RAI EPNB-3 In the first paragraphof Section 3.3, it is stated that "The frequency of test performance may change based on equipment performance." Please provide more detail as to what this means.

DNC Response The frequency of test performance refers to the Operations and Maintenance of Nuclear Power Plants Code (OM Code) requirement to increase testing when measured parameters fall into the "Alert" range. The OM Code applicable to MPS3, OM Code 2003a, requires that if the measured test parameter values fall within the "Alert" range of the applicable inservice test table (ISTB-6200), the frequency of the specified testing shall be doubled.

RAI EPNB-4 Provide copies of any approved relief requests for the TDAFW pump and the two MDAFW pumps for the current inservice test (IST) interval.

DNC Response The current MPS3 10-year IST program and relief requests were submitted in a letter dated December 27, 2007 (ADAMS Accession No. ML080020059) and approved in a letter from the NRC dated October 24, 2008 (ADAMS Accession No. ML082470622).

No specific relief requests for the TDAFW pump or the MDAFW pumps were submitted for the current MPS3 10-year inservice test interval. However, Relief Request P-003 is a generic request to use Code Case OMN-6 associated with digital instrument ranges for various digital instruments used for pump tests. A copy of the relief request is attached.

Serial No.14-618 Docket No. 50-423 ATTACHMENT 2 10 CFR 50.55A REQUEST NUMBER P-003 USE OF CODE CASE OMN-6 FOR DIGITAL INSTRUMENTS DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.14-618 Docket No. 50-423 Attachment 2, Page 1 of 2 Serial No. 07-0793 Docket No. 50-423 MPS3 Third IST Interval Program.Plan Attachment 6 Page 23 of 245 10 CFR 50.55a Request Number P-003 Use of Code Case OMN-6 for Digital Instruments Proposed Alternative In Accordance with IOCFR50.55a(a)(3)(i)

Alternative Provides an Acceptable Level of Quality and Safety ASME Code Component(s) Affected Various digital instruments used for IST of pumps

Applicable Code Edition and Addenda

ASME OM Code 2001 Edition through 2003 Addenda Applicable Code Requirement(s)

ISTB-3510(b)(2), "digital instruments shall be selected such that the reference value does not exceed 70% of the calibrated range of the instrument."

Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and Standards", paragraph (a)(3)(i), relief is requested from the requirement of ASME OM Code ISTB-3510(b)(2). This request is to allow the use of ASME Code, Case OMN-6, Alternate Rules for Digital Instruments.

Code Case OMN-6 allows the use of digital instruments where the reference value does not exceed 90% of the calibrated range of the instrument. Code Case OMN-6 applies to the 1990 Edition through the 1997 Addenda. Millstone will implement the 2001 Edition through 2003 Addenda of the ASME OM Code for its third 10-year interval.

Proposed Alternative and Basis for Use By using Code Case OMN-6, greater flexibility in the selection of instruments.would be achieved, thus preventing the installation of multiple instruments to monitor the same parameter during testing. Digital instruments will be selected such that the reference value does not exceed 90 percent of the calibrated range of the instrument.

NUREG-1482, Revision 1, Section 5.5 statesthat .......The NRC has accepted Code Case OMN-6 as specified in Reg Guide 1.192, which allows each digital instrument to be such that the reference values do not exceed 90 percent of the calibrated range of the instrument."

Use of Code Case OMN-6, approved by the. NRC in Reg Guide 1.192, will provide at least equivalent instrumentation accuracy requirements for the required pump testing parameters to be measured in the IST program and will provide results consistent with code requirements. This will provide adequate assurance of acceptable pump performance.

Serial No.14-618 Docket No. 50-423 Attachment 2, Page 2 of 2 Serial No. 07-0793 Docket No. 50-423 MPS3 Third IST Interval Program Plan Attachment 6 Page 24 of 245 10 CFR 50.55a Request Number P-003 Using the provisions of this relief request as an alternative to the specific requirements of ISTB-3510(b)(2) identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i) relief is requested from the specific ISTB requirements identified in this request.

This alternative provides an acceptable level of quality and safety.

Duration of Proposed Alternative This proposed alternative will be utilized for the third 10-year interval.

Precedents Similar relief requests were previously approved; P-RR-3 was previously approved for Diablo Canyon Power Plant on January 30, 2006 (TAC Nos.

MC6632 and MC6633)

RP07 was previously approved for Columbia Generating Station on March 23, 2007 (TAC Nos.MD3537, MD3538, MD3539, MD3541, MD3542, MD3550, MD3551 and MD3552)