ML17215A007

Relief Requests Associated with Fifth Ten-Year Inservice Testing Interval

ML17215A007
Person / Time
Site:	Calvert Cliffs
Issue date:	08/02/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML17215A007 (22)

Text

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\\ \\ <:\donu1rp.co111 10 CFR 50.55a August2,2017 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Subject:

Relief Requests Associated with Fifth Ten-Year lnservice Testing Interval Attached for your review are relief requests associated with the fifth ten-year lnservice Testing (IST) interval for Calvert Cliffs Nuclear Power Plan (CCNPP), Units 1 and 2. The fifth interval of the CCNPP, Units 1 and 2 IST program complies with the ASME OM Code, 2012 Edition. The fifth ten-year interval for CCNPP, Units 1 and 2 begins on July 1, 2018, and will conclude on June 30, 2028. We request your approval by May 1, 2018.

There are no regulatory commitments contained within this letter.

If you have any questions concerning this letter, please contact Mr. David Neff at (610) 765-5631.

Since~~~

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Relief Requests Associated with the Fifth Ten-Year Interval for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 cc: USNRC Region I, Regional Administrator USNRC Project Manager, CCNPP USNRC Senior Resident Inspector, CCNPP S. T. Gray, Maryland Department of Natural Resources

ATTACHMENT Relief Requests Associated with the Fifth Ten-Vear Interval for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Relief Request No. Description GV-RR-01, Revision 0 Safety and Relief Valve Hold Times RC-RR-01, Revision O Pressurizer Safety Valve Temperature Testing Sl-RR-01, Revision O Low Pressure Safety Injection Pump

EXELON GENERATION COMPANY, LLC IST PROGRAM- RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times

1. ASME Code Component(s) Affected Refer to Tables: GV-RR-01-1, CCNPP U1 and Common, and GV-RR-01-2, CCNPP U2 Valves

2. Applicable Code Edition and Addenda

The fifth 10-year interval of the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2, lnservice Testing (IST) Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition with no Addenda.

3. Applicable Code Requirement

Mandatory Appendix I, lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants, paragraph 1-8110, Steam Service, (h) Time Between Valve Openings, states, "A minimum of 5 min shall elapse between successive openings."

Mandatory Appendix I, paragraph 1-8120, Compressible Fluid Services Other Than Steam, (h)

Time Between Valve Openings, states, "A minimum of 5 min shall elapse between successive openings."

Mandatory Appendix I, paragraph 1-8130, Liquid Service, (g) Time Between Valve Openings, states, "A minimum of 5 min shall elapse between successive openings."

4. Reason for Request

Pursuant to 10 CFR 50.55a(z)(1 ), an alternative is proposed to the relief valve requirements of the ASME OM Code listed above. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety. This is a generic request for all Class 1, 2, and 3 safety and relief valves listed in Tables 1 and 2. This relief request is not applicable to the Main Steam Safety Valves (MSSVs) and the Pressurizer Safety Valves (PSVs). For these valves, the requirement for verifying temperature stability, by waiting 5 minutes between successive openings, and adds no value. In accordance with 1-811 O(a), l-8120(a), and l-8130(a), the test medium used for the relief valve testing will be the same as the normal system operating fluid. For liquid service this will be water. For compressible fluid services other than steam this will be nitrogen. In either case, the test stand and surrounding environment ambient temperature conditions are relatively fixed with negligible changes occurring over the set pressure and seat tightness test determinations. There is negligible effect on valve setpoint due to minor temperature deviations that might occur at these conditions.

Numerous Class 1, 2, and 3 safety/relief valves associated with contaminated systems are bench-tested in the "hot shop," located within the Radiologically Controlled Area (RCA) in the Auxiliary Building, to prevent the spread of contamination. These tests are performed under ambient conditions using a test medium at ambient conditions. Therefore, there is no source of thermal imbalance that might affect the test results.

Page 1 of 7

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times

4. Reason for Request (cont.)

Entry into the hot shop testing facility requires full Anti-Contamination clothing (Anti-C's).

During the test, personnel are exposed to background radiation levels present in the Auxiliary Building hot shop as well as the radiation levels associated with the specific valve being tested. The proposed elimination of the hold time between successive tests for Class 1, 2, and 3 safety/relief valves listed in Tables 1 and 2 that are tested under ambient conditions using a test medium at ambient conditions reduces the duration of each test. Most importantly, reducing the hold times reduces the length of time that the test personnel must spend in close proximity to the valve. As a result, personnel radiation exposure is reduced.

For all safety and relief valves, including those located in "clean areas" that are bench-tested in the Mechanical Maintenance Shop, the proposed elimination of the hold time between successive tests will reduce the duration of each test. Since there are numerous safety/relief valve tests for both units and most require at least two people, the proposed elimination of the hold time between successive tests is expected to also result in a significant cumulative reduction in limited manpower resources.

Additionally, empirical data based on CCNPP plant experience supports the conclusion that the minimum hold time between successive tests has no value for safety/relief valves tested under ambient conditions using test medium at ambient conditions.

The net result of having to wait 5 minutes between successive openings is an increase in manpower and time to perform the tests, and an increase in radiation exposure when located in radiation areas, without a commensurate increase in test accuracy.

5. Proposed Alternative and Basis for Use For Class 1, 2, and 3 safety and relief valves, excluding the MSSVs and PSVs, tested under ambient conditions using test medium at ambient conditions, the 5-minute hold requirement between successive openings specified in paragraphs 1-8110, 1-8120, and 1-8130, will be deleted.

Using the provisions of this request as an alternative to the specific requirements described above, will result in a reduction in personnel radiation exposure and a significant cumulative reduction in limited manpower resources and still provide acceptable relief valve test accuracy and continue to provide an acceptable level of quality and safety.

Based on the determination that waiting 5 minutes between successive openings for safety/relief valves tested under ambient conditions using test medium at ambient conditions, adds no value, and can be eliminated while maintaining acceptable relief valve test accuracy and continue to provide an acceptable level of quality and safety, this proposed alternative is being requested pursuant to 10 CFR 50.55a(z)(1 ).

6. Duration of Proposed Alternative This request, upon approval, will be applied to the CCNPP Fifth 10-Year Interval, which is scheduled to begin July 1, 2018, and conclude on June 30, 2028.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times

7. Precedent This relief request was previously approved for the fourth 10-year interval at CCNPP, Units 1 and 2, as documented in NRG Safety Evaluation, Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Relief Requests for the Fourth 10-Year Interval lnservice Testing Program for Pumps and Valves (TAC Nos. MD5998 through MD6011 ), dated June 18, 2008 (ML081410070).

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times Table 1: GV-RR-01 CCNPP U1 and Common Valves Component Description Class Cat.

O-CC-6501-RV RC Evaporators Distillate Pump Sample Coolers RV 3 c O-CC-6503-RV RC Evaporators Distillate Pump Sample Coolers RV 3 c O-CC-6512-RV Unit 1 CC Oxygen Analyzer Sample Cooler RV 3 c O-CC-6530-RV Misc. Waste Evaporators Dist. Pump Sample Coolers RV 3 c O-CC-6533-RV Misc. Waste Evaporators Dist. Pump Sample Coolers RV 3 c 1-CC-3823-RV 11 CC Heat Exchanger Shell-Side RV 3 c 1-CC-3825-RV 12 CC Heat Exchanaer Shell-Side RV 3 c 1-CC-3827-RV 11 Shutdown CoolinQ Heat ExchanQer CC Inlet RV 3 c 1-CC-3829-RV 12 Shutdown Coolina Heat Exchanaer CC Inlet RV 3 c 1-CC-3831-RV Letdown Heat Exchanaer RV 3 c 1-CC-3843-RV Waste Gas Compressors After-Coolers Return Header RV 3 c 1-CC-6450A-RV NSSS Sample Cooler Outlet RV 3 c 1-CC-6471-RV 11 Steam Generator Slowdown Sample Coolers RV 3 c 1-CC-6472-RV 12 Steam Generator Slowdown Sample Coolers RV 3 c 1-CVC-125-RV Boric Acid Pump Recirculation RV 2 c 1-CVC-132-RV Boric Acid Storaae Tank Discharae RV 2 c 1-CVC-133-RV Boric Acid Pump DischarQe RV 2 c 1-CVC-141-RV Boric Acid Storaae Tank Discharae RV 2 c 1-CVC-149-RV Boric Acid Pump Recirculation RV 2 c 1-CVC-150-RV Boric Acid Pump Discharge RV 2 c 1-CVC-157-RV Boric Acid Pump Common Discharae RV 2 c 1-CVC-160-RV Boric Acid Strainer Inlet RV 2 c 1-CVC-171-RV Boric Acid Strainer Outlet RV 2 c 1-CVC-311-RV CharQing Pump Suction RV 2 c 1-CVC-315-RV Charaina Pump Suction RV 2 c 1-CVC-318-RV Charaina Pump Suction RV 2 c 1-CVC-321-RV CharainQ Pump Suction RV 2 c 1-CVC-324-RV Charging Pump Discharge RV 2 c 1-CVC-325-RV Charaina Pump Discharae RV 2 c 1-CVC-326-RV Charaina Pump Discharae RV 2 c 1-RV-10243 Diesel 1A1 StartinQ Air Receiver 11 RV 3 c 1-RV-10246 Diesel 1A1 Starting Air Receiver 12 RV 3 c 1-RV-10273 Diesel 1A2 Startina Air Receiver 11 RV 3 c 1-RV-10276 Diesel 1A2 Startina Air Receiver 12 RV 3 c 1-Sl-211-RV Safety Injection Tank RV 2 c 1-Sl-221-RV Safety Injection Tank RV 2 c 1-Sl-231-RV Safety Injection Tank RV 2 c 1-Sl-241-RV Safety lniection Tank RV 2 c 1-Sl-409-RV Hiah Pressure Safety Injection Header RV 2 c 1-Sl-417-RV Hiah Pressure Safety Injection Header RV 2 c 1-Sl-430-RV Shutdown Cooling Recirculation to HPSI Pump RV 2 c Page 4 of 7

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times Table 1: GV-RR-01 CCNPP U1 and Common Valves Component Description Class Cat.

1-Sl-431-RV Shutdown Cooling Recirculation to HPSI Pump RV 2 c 1-Sl-439-RV Low Pressure Safety Injection Header RV 2 c 1-Sl-446-RV Safety Injection Leak-Off RV 2 c 1-Sl-468-RV Shutdown Cooling Return Header RV 2 c 1-Sl-469-RV Shutdown Cooling Isolation Valve RV 1 c 1-Sl-6302-RV Auxiliary HPSI Pump 11 Discharge Header RV 2 c 1-SRW-1575-RV 11 A Service Water Heat Exchanger RV 3 c 1-SRW-1576-RV 11 B Service Water Heat Exchanger RV 3 c 1-SRW-1577-RV 12A Service Water Heat Exchanaer RV 3 c 1-SRW-1578-RV 128 Service Water Heat Exchanaer RV 3 c 1-SRW-1582-RV 11 Containment Air Cooler Service Water Discharge RV 3 c 1-SRW-1585-RV 12 Containment Air Cooler Service Water Discharge RV 3 c 1-SRW-1588-RV 1B Diesel Generator Service Water Suoolv/lnlet RV 3 c 1-SRW-1590-RV 13 Containment Air Cooler Service Water Discharge RV 3 c 1-SRW-1593-RV 14 Containment Air Cooler Service Water Discharge RV 3 c 1-SRW-1596-RV 11 Spent Fuel Pool Cooler Service Water RV 3 c 1-SRW-4084-RV 12 Steam Generator Slowdown Heat Exchanger RV 3 c 1-SW-5205-RV ECCS Pump Room Air Coolers Saltwater RV 3 c 1-SW-5206-AV CC Heat Exchanaers Saltwater RV 3 c 1-SW-5207-RV ECCS Pump Room Air Coolers Saltwater RV 3 c 1-SW-5208-RV CC Heat Exchangers Saltwater Relief Valve 3 c 1-SW-5209-AV SAW Heat Exchangers Inlet RV 3 c 1-SW-5210-RV SRW Heat Exchangers Inlet RV 3 c 1-SW-5211-RV SRW Heat Exchangers Inlet RV 3 c 1-SW-5212-RV SAW Heat Exchangers Inlet RV 3 c Page 5 of 7

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times Table 2: GV-RR-01-2-CCNPP U2 Valves Component Description Class Cat.

2-CC-3823-RV 21 CC Heat Exchanoer Shell-Side RV 3 c 2-CC-3825-RV 22 CC Heat Exchanger Shell-Side RV 3 c 2-CC-3827-RV 21 Shutdown Coolino Heat Exchanoer CC Inlet RV 3 c 2-CC-3829-RV 22 Shutdown Coolinq Heat Exchanoer CC Inlet RV 3 c 2-CC-3831-RV Letdown Heat Exchanger RV 3 c 2-CC-6450A-RV NSSS Sample Cooler Outlet RV 3 c 2-CC-6471-RV 21 Steam Generator Slowdown Sample Coolers RV 3 c 2-CC-6472-RV 22 Steam Generator Slowdown Sample Coolers RV 3 c 2-CVC-125-RV Boric Acid Pump Recirculation RV 2 c 2-CVC-132-RV Boric Acid Storaoe Tank Discharoe RV 2 c 2-CVC-133-RV Boric Acid Pump DischarQe RV 2 c 2-CVC-141-RV Boric Acid Storaoe Tank Discharoe RV 2 c 2-CVC-149-RV Boric Acid Pump Recirculation RV 2 c 2-CVC-150-RV Boric Acid Pump Discharge RV 2 c 2-CVC-157-RV Boric Acid Pump Common Discharoe RV 2 c 2-CVC-160-RV Boric Acid Strainer Inlet RV 2 c 2-CVC-171-RV Boric Acid Strainer Outlet RV 2 c 2-CVC-311-RV Charoino Pump Suction RV 2 c 2-CVC-315-RV CharQinQ Pump Suction RV 2 c 2-CVC-318-RV CharQing Pump Suction RV 2 c 2-CVC-321-RV Charoino Pump Suction RV 2 c 2-CVC-324-RV CharoinQ Pump DischarQe RV 2 c 2-CVC-325-RV Charging Pump Discharge RV 2 c 2-CVC-326-RV Charoino Pump Dischame RV 2 c 2-Sl-211-RV Safetv Injection Tank RV 2 c 2-Sl-221-RV Safety Injection Tank RV 2 c 2-Sl-231-RV Safety Injection Tank RV 2 c 2-Sl-241-RV Safetv Injection Tank RV 2 c 2-Sl-409-RV HiQh Pressure Safetv Injection Header RV 2 c 2-Sl-417-RV HiQh Pressure Safety Injection Header RV 2 c 2-Sl-430-RV Shutdown Cooling Recirculation to HPSI Pump RV 2 c 2-Sl-431-RV Shutdown Coolino Recirculation to HPSI Pump RV 2 c 2-Sl-439-RV Low Pressure Safetv Injection Header RV 2 c 2-Sl-446-RV Safetv Injection Leak-Off RV 2 c 2-Sl-468-RV Shutdown Cooling Return Header RV 2 c 2-Sl-469-RV Shutdown Coolino Isolation Valve RV 1 c 2-Sl-6302-RV Auxiliarv HPSI Pump 21 Discharoe Header RV 2 c 2-SRW-1575-RV 21A Service Water Heat Exchanaer RV 3 c 2-SRW-1576-RV 21 B Service Water Heat Exchanaer RV 3 c 2-SRW-1577-RV 22A Service Water Heat ExchanQer RV 3 c 2-SRW-1578-RV 22B Service Water Heat Exchanger RV 3 c 2-SRW-1582-RV 21 Containment Air Cooler Service Water Discharge RV 3 c Page 6 of 7

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

GV-RR-01, Rev. 0, Safety and Relief Valve Hold Times Table 2: GV-RR-01 CCNPP U2 Valves Component Description Class Cat.

2-SRW-1585-RV 22 Containment Air Cooler Service Water Discharge RV 3 c 2-SRW-1587-RV 28 Diesel Generator Service Water Supply/Inlet RV 3 c 2-SRW-1588-RV 2A Diesel Generator Service Water Supply/Inlet RV 3 c 2-SRW-1590-RV 23 Containment Air Cooler Service Water Discharae RV 3 c 2-SRW-1593-RV 24 Containment Air Cooler Service Water Discharae RV 3 c 2-SRW-1598-RV 12 Spent Fuel Pool Cooler Service Water RV 3 c 2-SRW-4084-RV 22 Steam Generator Slowdown Heat Exchanger RV 3 c 2-SW-5205-RV ECCS Pump Room Air Coolers Saltwater RV 3 c 2-SW-5206-RV CC Heat ExchanQers Saltwater RV 3 c 2-SW-5207-RV ECCS Pump Room Air Coolers Saltwater RV 3 c 2-SW-5208-RV CC Heat Exchanaers Saltwater Relief Valve 3 c 2-SW-5209-RV SAW Heat ExchanQers Inlet RV 3 c 2-SW-5210-RV SAW Heat Exchangers Inlet RV 3 c 2-SW-5211-RV SAW Heat Exchanaers Inlet RV 3 c 2-SW-5212-RV SAW Heat Exchangers Inlet RV 3 c Page 7 of 7

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

RC-RR-01, Rev. 0, Pressurizer Safety Valve Temperature Testing

1. ASME Code Component(s) Affected Component Description Class CateQorv 1-RC-200-RV Pressurizer Safety Valve 1 c 1-RC-201-RV Pressurizer Safety Valve 1 c 2-RC-200-RV Pressurizer Safetv Valve 1 c 2-RC-201-RV Pressurizer Safetv Valve 1 c

2. Applicable Code Edition and Addenda

The fifth 10-year interval of the CCNPP Units 1 and 2, lnservice Testing (IST} Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition with no Addenda.

3. Applicable Code Requirement

Mandatory Appendix I, lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants, paragraph 1-8110, Steam Service, (d) Thermal Equilibrium, states, in part, "Valves insulated in service shall be insulated in a like manner during testing."

4. Reason for Request

Pursuant to 10 CFR 50.55a(z)(1 ), an alternative is proposed to the relief valve requirements of the ASME OM Code listed above. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety. Changes in safety/relief valve body temperature can change the lift setpoint measured during inservice testing. Changes in ambient temperature or modifications to insulation also may change the lift setpoint by virtue of the resulting effect on the valve body temperature. The purpose of paragraph 1-811 O(cf) is to ensure the effect of temperature variations is minimized. Requiring insulation to be installed during testing is clearly intended to also ensure the valve body's temperature, and therefore its performance, is similar to that under normal operating circumstances. CCNPP has determined the normal operating temperature profile for the pressurizer safety valves by instrumenting each valve body at several locations and recorded empirical data during normal operation.

CCNPP has previously commissioned testing using the valves' actual operating temperature profile at a national vendor's testing facility to determine the impact of having the insulation removed versus installed during testing of the pressurizer safety valves. This testing demonstrated that pressurizer safety valves, which have had their setpoints satisfactorily verified in-situ, will perform satisfactorily two years later in a laboratory setting if the valve body's actual operating temperature profile is recreated. The test was conducted using two valves adjusted to their respective setpoints (which differ by only 65 pounds per square inch (psi)).

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

RC-RR-01, Rev. 0, Pressurizer Safety Valve Temperature Testing

4. Reason for Request (cont.)

The first series of tests was performed with each valve uninsulated. Prior to setpoint testing, each valve was thermally stabilized at the specified temperature profile to match normal operating conditions. The valves performed within their as-found setpoint tolerance.

The second series of tests was performed with each valve insulated (using the actual insulation from the plant normally installed on each valve). Prior to setpoint testing, each valve was thermally stabilized. However, due to the test configuration, the valve could not be thermally stabilized at the actual operating temperature profile. Instead, it could only be stabilized at a higher temperature. The overall impact of the higher temperature profile is that the lift pressure for the valves is lower than when at the correct temperature profile. This is a non-conservative error because, if the valves were adjusted to lift at their operating setpoint under these conditions, they would then be set to lift by as much as approximately 2% high when returned to their normal plant installation.

The third series of tests was performed with each valve insulated and with the ambient temperature being varied. The variations in ambient temperature had little effect on the valve's lift pressure.

Because of differences in the test configuration and the normal plant configuration, the vendor was unable to stabilize the valves' temperature profile when insulated consistent with the one specified for normal plant operating conditions. Rather, the temperatures measured at all the points being monitored, most notably the upper and lower bonnet, were higher.

The higher temperature profile for the insulated valves in the testing configuration occurred because, when installed in the plant, these valves are attached to long runs of piping with numerous associated piping supports which serve as heat sinks for the valves, but in the testing facility these long runs of piping are no longer attached. In the plant, these heat sinks allow the valves to stabilize at a lower temperature profile even when insulated, as compared to the temperature profiles when insulated in the vendor test facility. Additionally, the presence of forced ventilation in the field increases the heat transfer out of each valve body through the insulation for the same ambient temperature when compared to the stagnant conditions present in the test configuration.

In other words, the heat input and heat output of the insulated valves in a stagnant environment cannot be balanced in the testing facility until the valves are hot enough to create the necessary heat transfer rate through the insulation needed to offset the heat input. Since the heat transfer out of the valve to the attached piping is lost, more heat output through the insulation is required. This effect is additionally aggravated by the lack of forced ventilation.

As a result, the valves stabilize at a higher temperature and the lift pressure measured was lower (by as much as approximately 2%) with the valves insulated and at these higher temperatures.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

RC-RR-01, Rev. 0, Pressurizer Safety Valve Temperature Testing

5. Proposed Alternative and Basis for Use OM-2012 Code, Mandatory Appendix I, paragraph l-8110(e) requires the ambient temperature of the operating environment to be simulated during the set pressure test. Additionally, if the effect of ambient temperature on set pressure can be established for a particular valve type, then Appendix I allows set pressure tests to be performed using an ambient temperature different from the operating ambient temperature as long as applicable correlations between the operating and testing ambient temperatures are used.

The intent of using the normally installed insulation per paragraph 1-811 O(d) and testing using the operating ambient temperature (or test ambient temperature with the appropriate correlation) is to ensure the valve performance during the test is indicative of its expected performance under service conditions. However, CCNPP has shown through comparative laboratory and in-situ tests that controlling the actual temperature profile of the valve body is a more realistic and more effective way of simulating inservice conditions and testing these valves. Additionally, it is much less likely to produce misleading test results that could lead to inappropriate setpoint adjustments. Therefore, CCNPP considers the requirements of paragraph 1-811 O(e) to be satisfied by such testing; and based on the test results obtained at the vendor's laboratory, no correlation factor is applicable.

When testing is performed in a vendor testing facility, vice in-situ testing, the valve body's temperature profile necessary to simulate normal operating conditions for these valves will be specified. The valve shall be stabilized at the required temperature profile per the remaining portion of paragraph l-8110(d) prior to setpoint testing without requiring the valve to be insulated in a like manner to its inservice configuration.

Based on the determination that the actual temperature profile of the valve body is a more realistic and more effective way of simulating inservice conditions and testing these valves; and, this alternate testing will maintain acceptable relief valve test accuracy and continue to provide an acceptable level of quality and safety, this proposed alternative is being requested pursuant to 10 CFR 50.55a(z)(1 ).

6. Duration of Proposed Alternative This request, upon approval, will be applied to the CCNPP Fifth 10-Year Interval, which is scheduled to begin July 1, 2018, and conclude on June 30, 2028.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

RC-RR-01, Rev. 0, Pressurizer Safety Valve Temperature Testing

7. Precedence

1. This relief request was previously approved for the fourth 10-year interval at CCNPP, Units 1 and 2, as documented in NRG Safety Evaluation, Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Relief Requests for the Fourth 10-Year Interval lnservice Testing Program for Pumps and Valves (TAC Nos. MD5998 through MD6011 ), dated June 18, 2008 (ML081410070).

2. This relief request was previously approved for the third 10-year interval at CCNPP, Units 1 and 2, as documented in NRG Safety Evaluation, Safety Evaluation of the lnservice Testing Program Third Ten-Year Interval for Pumps and Valves - Calvert Cliffs Nuclear Power Plant, Units 1and2 (TAC Nos. M98523 and M98524), dated February 11, 1998 (ML9802270162).

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

1. ASME Code Component(s) Affected Component Description Class Group 11 LPSI Low Pressure Safety Injection Pump 11 2 A/B 12 LPSI Low Pressure Safety Injection Pump 12 2 A/B 21 LPSI Low Pressure Safety lniection Pump 21 2 A/B 22 LPSI Low Pressure Safety Injection Pump 22 2 A/B

2. Applicable Code Edition and Addenda

The fifth 10-year interval of the Calvert Cliffs Nuclear Power Plant (CCNPP}, Units. 1 and 2, lnservice Testing (IST} Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition with no Addenda.

3. Applicable Code Requirement

ISTB-1400, Owner's Responsibility, paragraph (b}, states, in part, "A pump that meets both Group A and Group B pump definitions shall be categorized as a Group A pump."

4. Reason for Request

Pursuant to 10 CFR 50.55a(z)(1 }, CCNPP requests approval of an alternative to the requirement of ASME OM Code ISTB-1400(b). This alternative will result in testing the Low Pressure Safety Injection (LPSI) pumps as Group B pumps during power operations (Modes 1-4) versus Group A. As discussed below, this proposed alternative will result in a lower potential for pump degradation due to pump wear while still being capable of monitoring pump performance. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety.

Bases for Proposed Alternative to the ASME OM-2012 Code LPSI Pump Group Classification ASME OM-2012 Code, Subsection ISTB, lnservice Testing of Pumps in Light-Water Reactor Nuclear Power Plants - Pre-2000 Plants, paragraph ISTB-2000, Supplemental Definitions, defines Group A pumps as, "pumps that are operated continuously or routinely during normal operation, cold shutdown, or refueling operations," and Group B pumps as, "pumps in standby systems that are not operated routinely except for testing." The LPSI pumps clearly meet the definition of Group B pumps during normal operation in Modes 1-4. However, in Modes 5-6, the LPSI pumps are used for shutdown cooling and meet the definition of Group A pumps.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

4. Reason for Request (cont.)

Subsection ISTB, paragraph ISTB-1400(b) states, in part, that "A pump that meets both Group A and Group B pump definitions shall be categorized as a Group A pump." This means that the LPSI pumps would be classified as Group A and would be subjected to the same quarterly test requirements as continuously operated pumps.

The LPSI pumps are tested quarterly using the minimum recirculation flow path from each pump through the minimum recirculation flow common header and back to the refueling water tank. The common header is instrumented with an ultrasonic flow meter. However, flow is not throttled during the quarterly test to eliminate the potential for pump overheating and damage should flow inadvertently be throttled below that required to ensure adequate pump cooling.

The LPSI pumps are also tested at a substantial flow rate (approximately 3000 gallons per minute (gpm)) during every refueling outage, as well as during planned and unplanned cold shutdown periods when plant conditions and circumstances permit. These tests are the OM Code Comprehensive Pump Tests (CPTs) (formerly known at CCNPP as "Large Flow Rate" tests). The CPT flow rate meets the OM-2012 Code, Mandatory Appendix V, Pump Periodic Verification Test (PPVT) Program, requirements.

NUREG/CP-0137, Volume 1, Proceedings of the Third NRC/ASME Symposium on Valve and Pump Testing, includes a paper entitled, "Description of Comprehensive Pump Test Change to ASME OM Code, Subsection ISTB." This paper describes the philosophy of classifying pumps in one group or the other (Group A vs. Group B). According to this paper, the intent of having different test requirements for the different pump groups is to relate the amount and degree of quarterly performance monitoring required to the amount of degradation expected due to pump operation.

Requiring the LPSI pumps to be tested quarterly as Group A pumps during normal operation in Modes 1-4 is contrary to the philosophy of the referenced paper. Quarterly testing subjects the LPSI pumps to increased test requirements, performance monitoring, and potentially more degradation due to low-flow operation at the time when they are standby pumps and would not otherwise be subject to operation-induced degradation. In fact, out of all of the Emergency Core Cooling System (ECCS) and Auxiliary Feedwater (AFW) pumps, the LPSI pumps are the ones, due to their design and test conditions, for which the detrimental effects of cumulative low-flow operation are the most drastic.

CCNPP considers the requirement to test the LPSI pumps as Group A pumps during normal operation in Modes 1-4 to be potentially detrimental on a long-term basis.

Therefore, CCNPP proposes the LPSI pumps be treated as Group B pumps during normal operation in Modes 1-4 and tested accordingly.

Additionally, in Generic Letter (GL) 89-04, Position 9, the NRC determined that, in cases where the pump flow can only be established through a non-instrumented, minimum-flow path during quarterly pump testing, and a path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions, the Page 2 of 9

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

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4. Reason for Request (cont.)

increased interval is an acceptable alternative to the Code requirements. Therefore, the proposed alternative testing of LPSI pumps as Group B during Modes 1-4 and as Group A during Modes 5-6 is consistent with GL 89-04, Position 9.

The impact of obtaining certain test parameters required by OM-2012 Code, Table ISTB-3000-1, "lnservice Test Parameters," ensuring the pumps are run for a minimum of 2 minutes at stable conditions (ISTB-51 OO(a)(1 )) during quarterly Group A testing, and other considerations are discussed below.

Differential Pressure Measurements CCNPP's current quarterly Group A pump test program requires differential pressure to be measured. Group A quarterly ECCS pump tests must be performed using very accurate

(+/- 1/2%) test pressure gauges. These pressure gauges would be installed prior to, and removed after, each test (an annual total of 32 gauge installation/removal evolutions). The OM-2012 Code does not require these very accurate gauges; however, they are necessary because the hydraulic margin available, based on design calculations, is less than the amount of degradation allowed by Subsection ISTB. Using less accurate permanently installed pressure gauges could result in a pump being unnecessarily declared inoperable solely due to pressure gauge uncertainty.

Installation and removal of these test pressure gauges for each LPSI pump every quarter would require significant dedication of manpower, results in significant cumulative annual radiation dose, increased radioactive waste, increased wear on fittings, and additional challenges for possible personnel contamination. CCNPP estimates that eliminating the test pressure gauge installation and removal evolutions will save at least 1/8 man-rem per year and almost 100 man-hours per year.

Quarterly LPSI pump tests are performed using the minimum recirculation flow path under low-flow conditions. In this region, the pumps are operating at or near shut-off head, the pump curves are flat or nearly flat, and pump differential pressure is not very sensitive to pump degradation. Flow rate alone is an adequate indication of possible pump degradation or flow blockage since the minimum recirculation flow path is a fixed-resistance flow path. The conclusion that measurement of pump differential pressure is of minimal value is supported by historical test data.

For testing the LPSI pumps as Group B pumps, the operational readiness is reasonably assured without requiring quarterly differential pressure measurements. This will allow CCNPP to cease these gauge installation and removal evolutions every quarter, while maintaining an acceptable level of quality and safety.

Vibration Measurements CCNPP's current quarterly Group A pump test program requires pump vibration measurements. The overall vibration readings recorded during quarterly low-flow testing Page 3 of 9

EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

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4. Reason for Request (cont.)

have always been relatively "high." These vibration readings have been subject to spectral analysis under the Rotating Machinery Condition Monitoring Program, which is separate from the IST Program. The spectral analyses have consistently confirmed the major contributor to the "high" overall vibration readings occurs at the "blade pass frequency" for each LPSI pump and is not indicative of bearing degradation. However, the OM Code does not require spectral analysis. Therefore, the effects of low-flow operation on a centrifugal pump make the required broadband vibration readings during the current quarterly test of minimal value. This conclusion is supported by the CCNPP historical test data. Under the OM-2012 Code, the operational readiness of Group B pumps is reasonably assured without requiring quarterly vibration measurements.

Based on this, CCNPP feels that an acceptable level of quality and safety is still maintained while many of the burdens and costs associated with vibration testing, including cumulative annual radiation dose and man-power, will be eliminated.

LPSI Pump Bearing Acceptance Criteria During Low-Flow Testing For the fourth IST interval, the surveillance procedures used to perform the CPTs required vibration measurements to be recorded in terms of velocity. CCNPP long ago recognized the benefit of velocity over displacement for analyzing pump vibrations and has included such measurements in the CCNPP Predictive Maintenance (PdM) group's Rotating Machinery Vibration Monitoring Program which conducts periodic vibration monitoring and analysis of numerous pumps and motors (including the LPSI pumps) beyond that required for the IST Program. The Rotating Machinery Vibration Monitoring Program includes spectral analysis of the vibration measurements.

The PdM group's long-term vibration data trend (1995 through present), during quarterly testing of the LPSI pumps using the minimum recirculation flow path shows consistent results and stable performance with no unexplainable significant changes. The quarterly tests are performed at approximately 55-65 gpm, which is between approximately 1.3% -

1.6% of the LPSI pumps' "Best Efficiency Flow Rate." The Best Efficiency Flow Rate is based on the original vendor pump curve. It is used instead of the system's design flow rate because the onset of pump internal recirculation and cavitation is a function of the pump's performance characteristics, not the system's design requirements.

Operating the LPSI pumps at low flow rates results in a variety of effects (e.g., internal recirculation, cavitation, and force imbalance on the impeller), which contribute to increased vibration. Spectral analysis of the LPSI pump vibration measurements reveals (1) a general increase in the broadband noise levels which is indicative of internal recirculation and cavitation, and (2) discrete spikes at frequencies corresponding to the blade pass frequency which is indicative of force imbalances acting on the impeller. The analysis confirms the presence and effect of these phenomena.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

4. Reason for Request (cont.)

Many of the normal vibration levels experienced when operating the LPSI pumps under low-flow conditions during quarterly testing routinely exceed or challenge the absolute Alert Acceptance Criterion of 0.325 inches per second specified in Table ISTB-5121-1, Centrifugal Pump Test Acceptance Criteria. If the LPSI pumps are classified as group A pumps, applying the OM Code criteria will necessitate either testing at six-week intervals, or a new evaluation each quarter.

The following factors lead to the conclusion that the current vibration levels recorded during LPSI minimum recirculation flow testing are acceptable and are not indicative of any pump mechanical problems or degradation, and, therefore, that the LPSI pumps are operating acceptably.

(1) The long-term stability of the vibration trend based on data from the surveillance tests and CCNPP Rotating Machinery Vibration Monitoring Program obtained during quarterly minimum recirculation flow testing.

(2) Spectral analysis confirmed the major contributor to the overall vibration levels recorded during quarterly minimum recirculation flow testing is consistent with phenomena which are well known to be associated with operation of a centrifugal pump at low flow rates and also well known to cause higher vibrations at these low flow rates.

(3) The overall vibration levels recorded during large flow testing of the LPSI pumps are significantly reduced compared to the levels recorded during the quarterly minimum recirculation flow tests and are consistent with vibration levels experienced while testing centrifugal pumps at substantial flow rates in other systems and applications.

(4) Spectral analysis confirmed that the major contributors to the overall vibration levels observed during quarterly minimum recirculation flow testing which are associated with operation of a centrifugal pump at low flow rates are significantly reduced during large flow testing of the LPSI pumps.

(5) Similar vibration patterns have been observed for the other standby ECCS pumps, although the effects are not as pronounced as they are for the LPSI pump because the LPSI pumps are the pumps which are tested at the lowest flow condition relative to their Best Efficiency Flow Rate.

(6) The LPSI pumps have no history of mechanical failures nor have they required significant maintenance on a regular basis.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

4. Reason for Request (cont.)

The "Large Flow Rate" tests for the LPSI pumps have been in use at CCNPP since approximately 1991. At a minimum, each pump has been tested during each refueling outage since these tests were implemented. Vibration data (in both displacement and velocity) was collected during these tests via the surveillance tests themselves and the CCNPP Rotating Machinery Vibration Monitoring Program. The vibration data recorded during these large flow tests show the overall vibration levels drop significantly, as expected. Furthermore, spectral analysis of these results show the general broadband noise and spikes at discrete frequencies caused by the blade passing are significantly reduced.

The overall vibration levels observed during quarterly LPSI pump minimum recirculation flow testing, augmented by spectral analysis, are not sufficiently high as to prevent detection of increases in the LPSI pump vibration levels, which would be indicative of mechanical degradation. Furthermore, the vibration monitoring during less frequent LPSI CPT, also augmented by spectral analysis, provides even greater opportunities to detect increases in the LPSI pump vibration levels, which would be indicative of mechanical degradation.

CCNPP's experience has shown that spectral analysis of the vibration measurements obtained during quarterly minimum recirculation flow testing is sufficiently sensitive to changes in the pumps' mechanical condition and provides reasonable assurance that mechanical degradation can be detected early.

Performing pump testing at double the normal quarterly frequency when vibration levels exceed the acceptance criteria specified in Table ISTB-5121-1 is physically possible (i.e.,

it is practicable). Such increased frequency testing will potentially reduce LPSI pump reliability and increase the probability of LPSI pump degradation, damage, or failure.

Therefore, such testing is considered impractical because, though it is possible to perform such increased frequency testing, the potential reduction in LPSI pump reliability and potential increase in the probability of LPSI pump degradation, damage, or failure is a result, which is contrary to the intent of the IST Program.

The run time of these pumps during an operating cycle is very limited since operation at low flow rates is detrimental to the pumps. Performing increased frequency testing on a regular basis during the operating cycle would increase the run time of these pumps by as much as approximately 30%. 10 CFR 50.55a(z)(1) and (z)(2) address alternatives when the OM Code requirement would result in a hardship/burden with no commensurate increase in the level of quality or safety [(z)(2)] or an alternative provides an equivalent level of quality and safety [(z)(1 )]. Not only would increased frequency testing of the LPSI pumps be an inefficient use of resources, but such unnecessary testing may actually result in a real potential to reduce the level of quality and safety and; therefore, should be avoided if possible.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

4. Reason for Request (cont.)

Minimum Pump Run-Time If the LPSI pumps are classified as Group B pumps, the two-minute minimum pump run-time for quarterly tests is also eliminated. Eliminating the minimum pump run-time requirement and the requirement to record differential pressure and vibration levels is expected to slightly reduce the length of each pump test. This will help to reduce the cumulative run-time of each LPSI pump under low-flow conditions to support testing, with a commensurate reduction in potential pump wear.

Other Considerations These proposed changes simplify the quarterly IST pump test to allow combining the quarterly IST pump test into the related quarterly engineering safety features actuation logic test for each pump. As a result, the total number of starting demands on each pump motor to support testing may be reduced and the cumulative run-time of each LPSI pump under low-flow conditions to support testing may be further reduced. CCNPP estimates that this course of action could eliminate approximately two hours of operation under low-flow conditions tor each LPSI pump per year.

Relationship to CCNPP Technical Specification (TS) Surveillance Requirement (SR)

The CCNPP TS SR for each pump (SR 3.5.2.3) requires periodic testing of each LPSI pump to verify that the "developed head at the test flow point is greater than or equal to the required developed head." The specified frequency tor the SR is, "in accordance with the lnservice Test Program." CCNPP's TS SR does not contain any additional (explicit or implied) testing requirements for these pumps beyond those required by the IST Program.

This means that, as long as the testing complies with the requirements of the approved IST Program, there is no conflict with CCNPP's TS SR. Therefore, none of the changes to the IST Program requested in this proposed alternative would conflict with any CCNPP's TS SRs.

As previously stated, the LPSI pumps are typically run continuously during cold shutdown and refueling operations, depending on the decay heat rate. As a result, they may be subject to operation-induced degradation in Modes 5-6. Therefore, the LPSI pumps will be treated as Group A pumps during any quarterly test that comes due during cold shutdown or refueling operations. However, typically during Modes 5-6, a CPT is preferable to a Group A test tor the LPSI pumps. This avoids the need to realign the LPSI pumps out of the normal shutdown cooling line-up and also avoids the detrimental effects of testing the LPSI pumps at low-flow conditions. Therefore, CCNPP expects that a CPT will typically be substituted for any Group A test that may be required during Modes 5-6.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

4. Reason for Request (cont.)

Conclusion The ASME OM-2012 Code requirement to classify and test the LPSI pumps as Group A pumps, for all operating modes, is potentially detrimental and not appropriate. Therefore, CCNPP proposes the LPSI pumps be treated as Group B pumps during normal operation in Modes 1-4, and Group A pumps during cold shutdown periods in Modes 5 and 6 and tested accordingly.

Spectral analysis of quarterly minimum flow vibration results and less frequent CPT (large flow) vibration results (in accordance with CCNPP's Rotating Machinery Vibration Monitoring Program) will continue to provide adequate assurance that increases in vibration levels at discrete frequencies, which are not sufficiently large to affect the overall vibration reading, will be detected and analyzed.

Treating the LPSI pumps as Group B pumps during Modes 1-4 eliminates the test gauge installation time required for differential pressure measurements and the 2-minute hold time, thus reducing test duration and the potential for pump degradation. For Group B pump tests, vibration data acquisition is not required under the low-flow test conditions.

Thus, the potential for increased frequency testing, due to OM Code acceptance criteria, and thereby, the potential for additional pump degradation is also eliminated.

5. Proposed Alternative and Basis for Use CCNPP proposes that the LPSI pumps be tested as standby pumps (Group 8) during Modes 1-4, power operation, and as continuously operating pumps (Group A) during Modes 5-6, refueling operations. During refueling operations, the CPT will be substituted for a quarterly Group A test that comes due.

Using the provisions of this request as an alternative to the specific requirements of ISTB-1400(b) 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(z)(1 ), CCNPP requests approval of the proposed alternative to the specific ISTB requirements identified in this request.

6. Duration of Proposed Alternative This request, upon approval, will be applied to the CCNPP Fifth 10-Year Interval, which is scheduled to begin July 1, 2018, and conclude on June 30, 2028.

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EXELON GENERATION COMPANY, LLC IST PROGRAM - RELIEF REQUEST Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 ),

Sl-RR-01, Rev. 0, Low Pressure Safety Injection Pump

7. Precedence

1. This relief request was previously approved for the fourth 10-year interval at CCNPP, Unit Nos. 1 and 2, as documented in NRC Safety Evaluation, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 - Relief Requests for the Fourth 1O Year Interval lnservice Testing Program for Pumps and Valves (TAC Nos. MD5998 through MD6011), dated June 18, 2008 (ML081410070).

2. This relief request was previously approved, as PR-12, for the third 10-year interval at CCNPP, Unit Nos. 1 and 2, as documented in NRC Safety Evaluation, Request for Relief No. PR-12 Associated with the Third 10-Year Interval lnservice Testing Program, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (TAC Nos. MB3782 and MB3783), dated May 16, 2002 (ML021000690).

3. A similar relief request was authorized as PR-04 for the fourth 10-year IST interval at Three Mile Island Nuclear Station, Unit 1 (TMl-1 ), as documented in NRC Safety Evaluation, Relief Requests for the Pump and Valve lnservice Testing (IST) Program (TAC No. MC2558), dated July 7, 2005 (ML051530406).

8. References

1. Letter from Baltimore Gas and Electric Company(Mr. C. H. Cruse) to NRC (Document Control Desk), "Revised and New Relief Requests for the Third Ten Year lnservice Test Program," dated December 30, 1999 (ML003670600).

2. Letter from BGE (Mr. C.H. Cruse) to NRC (Document Control Desk), "Response to Request for Additional Information: Relief Request PR-11 Low Pressure Safety Injection Pumps," dated May 19, 2000 (ML003717862).

3. Letter from Ms. M. Gamberoni (NRC) to Mr. C.H. Cruse (CCNPP, Inc.), "Safety Evaluation of Relief Requests for the Third 10-Year Pump and Valve In-Service Testing Program Calvert Cliffs Nuclear Power Plant Units 1 and 2 (TAC Nos. MA7848 and MA7849)," dated August 22, 2000 (ML003729951).

4. NUREG/CP-0137, Volume1, "Proceedings of the Third NRC/ASME Symposium on Valve and Pump Testing," July 1994; Section: Pump Performance Testing. Hartley, R.

Scott- Description of Comprehensive Pump Test Change to ASME OM Code, Subsection ISTB [Idaho National Engineering Laboratory, EG&G Idaho, Inc.].

5. Generic Letter 89-04, "Guidance on Developing Acceptable lnservice Testing Programs," dated April 3, 1989.

6. CCNPP Technical Specifications, Unit Nos. 1 and 2.

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