ML18205A176

Response to Request for Additional Information for Alternative Requests Associated with the In-Service Testing Program for Pumps, Valves, and Snubbers Fifth and Fourth 10-Year Interval Updates for Units 2 and 3

ML18205A176
Person / Time
Site:	Millstone
Issue date:	07/19/2018
From:	Gerald Bichof Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
18-258
Download: ML18205A176 (7)

Text

Dominion Energy Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 ~Dominion Dominion Energy.com

~ Energy July 19, 2018 U.$. Nuclear Regulatory Commission Serial No.18-258 Attention: Document Control Desk _NRA/WDC RO Washington, DC 20555 Docket.Nos. 50-336/423 License Nos. DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR ALTERNATIVE REQUESTS ASSOCIATED WITH THE IN-SERVICE TESTING PROGRAM FOR PUMPS, VALVES, AND SNUBBERS FIFTH AND FOURTH 10-YEAR INTERVAL UPDATES FOR UNITS 2 AND 3 By letter dated March 1, 2018, Dominion Energy Nuclear Connecticut, Inc. (DENG) requested Nuclear Regulatory Commission (NRG) approval of the alternative requests associated with the In-service Testing Program for Pumps, Valves, and Snubbers, Fifth and Fourth 10-Year Interval Updates for Millstone Power Station Unit 2 (MPS2) and Millstone Power Station Unit 3 (MPS3). In an email dated June 20, 2018, the NRG transmitted a request for additional information (RAI) related to the alternative requests.

The RAI *contained three questions. The attachment to this letter provides DENC's response to RAI question.s RAI 2P-02-1 and 3P-03-1.

• DENG plans to submit the response to the remaining RAI question, 3P-05-1, by August 6, 2018.

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

Sincerely,

fJ;£7lk-6 Gerald T. Bischof Senior Vice President - Nuclear Operations & Fleet Performance

Attachment:

Response to Request for Additional Information for Alternative Requests Associated with the In-service Testing Program for Pumps, Valves, and Snu,bbers, Fifth and Fourth 10-Year Interval Updates for MPS2 and MPS3 - RAI 2P-02-1 and RAI 3P-03-1

Serial No.18-258 Docket Nos. 50-336/423 Page 2__ of 2 Commitments made in this letter: None cc: U.S: Nuclear Regulatory Commission Region I 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713 Richard V. Guzman Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C 2 11555 Rockville Pike Rockville, MD 20852-2738 NRG Senior Resident Inspector Millstone Power Station

Serial No.18-258 Docket Nos. 50-336/423 ATTACHMENT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR ALTERNATIVE REQUESTS ASSOCIATED WITH THE IN-SERVICE TESTING PROGRAM FOR PUMPS, VALVES, AND SNUBBERS, FIFTH AND FOURTH 10-YEAR INTERVAL UPDATES FOR MPS2 AND MPS3 -

RAI 2P-02-1 and RAI 3P-03-1 MILLSTONE POWER STATION UNITS 2 AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

Serial No.18-258 Docket Nos. 50-336/423 Attachment, Page 1 of 4 By letter dated March 1, 2018, Dominion Energy Nuclear Connecticut, Inc. (DENG) requested Nuclear Regulatory Commission (NRC) approval of the alternative requests associated with the In-service Testing Program for Pumps, Valves, and Snubbers, Fifth and Fourth 10-Year Interval Updates for Millstone Power Station Unit 2 (MPS2) and Millstone Power Station Unit 3 (MPS3). In an *email dated June 20, 2018, the NRC transmitted a request for additional information (RAI) related to the alternative requests.

The RAI contained three questions .. This attachment provides DENC's response to RAI questions RAI 2P-02-1 and 3P-03-1.

Background

GOG 35, "Emergency core cooling," states that a system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts. The GOG also requires that suitable redundancy in components and features, and suitable interconnections, leak detection, isolation,

• and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

GOG 37, "Testing of emergency core cooling system," states that the emergency core cooling system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the c;1ssociated cooling water system.

NUREG-1482, "Guidelines for /nservice Testing at Nuclear Power Plants: lnservice Testing of Pumps and Valves and lnservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants," Revision 2, Section 2.5.3, Page 2-21, last paragraph, states that to improve the effectiveness and efficiency of the relief request process NE/ developed a white paper entitled "Standard Format for Requests from The Commercial Reactor Licensees Pursuant to 10 CFR 50. 55a, Revision 1,"

dated June 7, 2004 (ML070100400) for the guidance for the industry. This NE/

guideline states that each affected components is to be listed in relief request. Template 1 of the NE/ document states:

1. ASME Code Component(s) Affected

[Provide a description of, the class type, and the quantity of ASME Code components affected. Ensure that each affected component, weld, etc. is

Serial No.18-258 Docket Nos. 50-336/423 Attachment, Page 2 of 4 fisted, not just referenced generically. For example, include the component number, the weld identification numbers, etc.]

NUREG-1482, Revision 2, Section 5.12 states that "the NRC has authorized alternative vibration acceptance criteria for smooth-running pumps on a case-by-case basis in accordance with 10 CFR 50.55a(a)(3). Alternative requests for smooth-running pumps should specify a minimum vibration reference value(= 0.05 inch per second), and these smooth-running pumps must be included in a predictive maintenance (PdM) program."

NRC is unable to authorize relief requests for all pumps without knowing their IDs and actual vibration values, which are = 0. 05 inch per second.

RAI - 2P-02-1

Background:

In Unit 2 alternative request P-02, the licensee requested an alternative to the requirements in ASME OM Code paragraphs ISTB-3300, /STB-5100, ISTB-5200, and ISTB-5300 for pumps whose vibration reference value is less than 0. 05 inches per second (ips). The licensee refers to these pumps as "smooth running" pumps.

Issue: The licensee did not identify the specific pumps with vibration reference values less than 0. 05 ips.

Request: Identify the specific pumps affected by the alternative request.

DNC Response The following MPS2 pumps currently have at least one vibration reference value less than 0.05 ips:

Pump Pump ID Pump Name Class Group P-13A 'A' Spent Fuel Pool Cooling Pump 3 A P-138 'B' Spent Fuel Pool Cooling Pump 3 A P-198 'B' Boric Acid Pump 2 A P-41A 'A' High Pressure Safety Injection Pump 2 B P-418 'B' High Pressure Safety Injection Pump 2 B P-41C 'C' High Pressure Safety Injection Pump 2 B P-42A 'A' Low Pressure Safety Injection Pump 2 A P-428 'B' Low Pressure Safety Injection Pump 2 A

Serial No.18-258 Docket Nos. 50-336/423 Attachment, Page 3 of 4 RAI - 3P-03-1

Background:

In Unit 3 alternative request P-03, the licensee requested an alternative to.

the requirements in ASME OM Code paragraphs ISTB-3300, ISTB-5100, ISTB-5200, and ISTB-5300 for pumps whose vibration reference value is less than 0. 05 inches per second (ips). The licensee refers to these pumps as "smooth running" pumps.

Issue:

• The licensee did not identify the specific pumps with vibration reference values Jess than 0. 05 ips.

Request: Identify the specific pumps affected by the alternative request.

DNC Response The following MPS3 pumps currently have at least one vibration reference value less than 0.05 ips:

Pump Pump ID Pump Name Class Group 3CCE*P1A Charging Pump Seal Cooling Pump, P1A 3 A 3CCE*P1 B Charging Pump Seal Cooling Pump, P1 B 3 A 3CCl*P1A Safety Injection Cooling Pump, P1A 3 B 3CCl*P1B Safety Injection Cooling Pump, P1 B 3 B.

3CCP*P1A Reactor Plant Component Cooling Pump, P1A 3 A 3CCP*P1B Reactor Plant Component Cooling Pump, P1 B 3 A 3CCP*P1C Reactor Plant Component Cooling Pump, P1 C 3 A.

3CHS*P2A Boric Acid Transfer Pump, P2A 3 A 3CHS*P2B Boric Acid Transfer Pump, P2B 3 A 3CHS*P3A Chemical Volume Control Charging Pump, P3A 2 A 3CHS*P3B Chemical Volume Control Charging Pump, P3B 2 *A 3CHS*P3C Chemical Volume Control Charqinq Pump, P3C 2 A 3EGF*P1A 'A' Emergency Gen Fuel Oil Transfer Pump, P1A 3 B 3EGF*P1B 'B' Emerqency Gen Fuel Oil Transfer Pump, P1 B 3 B 3EGF*P1C 'A' Emergency Gen Fuel Oil Transfer Pump, P1 C 3 B 3EGF*P1D 'B' Emergency Gen Fuel Oil Transfer Pump, P1 D 3 B 3FWA*P1A Motor Driven Steam Generator Aux Feedwater Pump, P1A 3 B 3FWA*P1B Motor Driven Steam Generator Aux Feedwater Pump, P1 B 3 B 3FWA*P2 Turbine Aux Feedwater Pump, P2 3 B 3HVK*P1A Control Building Chill Water Pump, P1A 3 A 3HVK*P1 B Control Building Chill Water Pump, P1 B 3 A 3QSS*P3A Quench Spray Pump, P1A 2 B 3QSS*P3B Quench Spray Pump, P1 B 2 B 3RHS*P1A Residual Heat Removal Pump, P1A 2 A 3RHS*P1B Residual Heat Removal Pump, P1 B 2 A 3SFC*P1A Fuel Pool Coolinq Pump, P1A 3 A

Serial No.18-258 Docket Nos. 50-336/423

.,. Attachment, Page 4 of 4 Pump Pump ID Pump Name Class Group 3SIH*P1A Safety Injection Pump, P1A 2 B 3SIH*P1 B Safety Injection Pump, P1 B 2 B 3SWP*P1A Service Water Pump, P1A 3 A 3SWP*P2A Control Buildinq Air Cond Booster Pump, P2A 3 A 3SWP*P2B Control Building Air Cond Booster Pump, P2B 3 A 3SWP*P3A MCC and Rod Control Area Air Cond Booster Pump, P3A 3 B 3SWP*P3B MCC and Rod Control Area Air Cond Booster Pump, P3B 3 B