L-19-146, 10 CFR 50.55a Request PR-3, Standby Liquid Control Pump Periodic Verification Test
| ML19351C732 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/16/2019 |
| From: | Payne F FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-19-146 | |
| Download: ML19351C732 (6) | |
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FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant PO. Box 97 10 Center Road Perry, Ohio 44081 Frank Payne Vice President December 16, 2019 L-19-146 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 440-280-5382 10 CFR 50.55a 10 CFR 50.55a Request PR-3, Standby Liquid Control Pump Periodic Verification Test In accordance with the provisions of 10 CFR 50.55a(z)(1 ), FirstEnergy Nuclear Operating Company (FENOC) hereby requests Nuclear Regulatory Commission (NRC) approval of request PR-3, Revision 1, which proposes an alternative to the Mandatory Appendix V Pump Periodic Verification Test.
The enclosed request identifies the affected components, applicable code requirements, and a description and basis for the proposed alternative.
The proposed alternative would be implemented during the fourth 10-year inservice testing interval, which began on May 18, 2019 and ends on May 17, 2029. FENOC requests approval of the proposed alternative by December 31, 2020.
There are no regulatory commitments contained in this submittal. If there are any questions or additional information is required, please contact Mr. Phil H. Lashley, Acting Manager - Nuclear Licensing and Regulatory Affairs, at (330) 315-6808.
Frank R. Payne
Perry Nuclear Power Plant L-19-146 Page 2
Enclosure:
Perry Nuclear Power Plant, Unit 1, 10 CFR 50.55a Request Number PR-3 cc: NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager
L-19-146 Enclosure Perry Nuclear Power Plant, Unit 1 10 CFR 50.55a Request Number PR-3 (3 pages follow)
Perry Nuclear Power Plant, Unit 1 10 CFR 50.55a Request Number PR-3, Revision 1 Page 1 of 3 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
- Alternative Provides Acceptable Level of Quality and Safety -
- 1. ASME Code Component(s) Affected Pump ID Pump Description Code Pump Class Group 1C41-C001A Standby Liquid Control (SLC) Pump A 2
B 1C41-C001 B Standby Liquid Control (SLC) Pump B 2
B
2. Applicable Code Edition and Addenda
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 Requirements
ISTB-1400, Owner's Responsibility, requires, in Part (d), the establishment of a pump periodic verification test program in accordance with Division 1, Mandatory Appendix V.
Division 1, Mandatory Appendix V Pump Periodic Verification Test Program, includes requirements to perform the pump verification test at least once every two years. Section V-2000, provides the following definition of a pump periodic verification test:
pump periodic verification test: a test that verifies a pump can meet the required (differential or discharge) pressure as applicable, at its highest design basis accident flow rate.
4. Reason for Request
The standby liquid control (SLC) pumps inject a boron neutron absorber solution into the reactor if the operator determines the reactor cannot be shut down or kept shut down with the control rods. In accordance with Division 1, Mandatory Appendix V Pump Periodic Verification Test Program, the SLC pumps (A and B) are to be tested to verify the pumps can meet the required discharge pressure at its highest design basis accident flow rate. A minimum required performance flow rate of 32.4 gallons per minute (gpm) is required to meet the highest design basis accident flow rate for each pump, with a maximum operating pressure of 1264 pounds per square inch gauge (psig).
The SLC pumps are reciprocating-type positive displacement pumps. The hydraulic circuits for inservice testing of the SLC pumps have a suction from a common line off a SLC test tank.
Pump discharges are directed through a common test return line back to the test tank.
Perry Nuclear Power Plant, Unit 1 PR-3 Page 2 of 3 Reference conditions are established by throttling a valve (1 C41-F016) in the common test return line.
The test pressure reference point is achieved by throttling valve 1 C41-F016 to a position approximately one quarter turn from full closed. To achieve the maximum operating pressure of 1264 psig, the valve would need to be adjusted to a position even closer to full closed.
Since this pressure exceeds 90 percent of the 1400 psig nameplate pressure for the SLC pump A and B relief valves (1 C41-F029A and 1 C41-F029B, respectively), the relief valves could begin to leak. If valve 1 C41-F016 needs to be fully closed to achieve a maximum operating pressure of 1264 psig, the resulting pressure increase with the positive displacement SLC pumps operating could open the relief valve or potentially challenge the system piping if the relief valve failed to open.
5. Proposed Alternative and Basis for Use
FirstEnergy Nuclear Operating Company (FENOC) proposes that in lieu of performing a Mandatory Appendix V Pump Periodic Verification Test at least once every two years, a comprehensive test be performed quarterly for the Perry Nuclear Power Plant (PNPP). The comprehensive test will determine test parameters in Table ISTB-3000-1, with instrument accuracy specified in Table ISTB-3510-1, against the acceptance criteria listed in Table ISTB-5321-2 for reciprocating positive displacement pumps. The Mandatory Appendix V Pump Periodic Verification Test would not be required.
For the fourth 10-year inservice testing (1ST) interval, which began on May 18, 2019, a comprehensive test has been used for a Group B test quarterly as allowed by ISTB-S000(a).
The comprehensive test is performed at a reference point of 1220 psig, with a reference value of 43.0 gpm for both SLC Pump A and SLC Pump B. Because the pumps are positive displacement pumps, they deliver essentially the same flowrate against any differential pressure. This characteristic is demonstrated by the pump curves, where only a 0.1 gpm difference was recorded at a discharge pressure of 1200 psig versus a discharge pressure of 1400 psig.
The comprehensive test is substituted for a Group B test as allowed by Subsection ISTB-51 00(a). With the improved accuracy, consistent testing methodology, and the addition of quarterly vibration monitoring, deviations in actual pump performance that are indicative of impending degradation are more easily recognized during quarterly performance trending activities and historical testing data. The comprehensive test also provides sufficient information to verify each pump can meet the required discharge pressure at its highest design basis accident flow rate without potentially challenging the system piping if the relief valve failed open.
The instrument accuracy, testing methodology, and addition of quarterly vibration monitoring for the comprehensive test is consistent with the testing performed for SLC Pump A and SLC Pump B in the third 10-year 1ST interval, during which a modified Group A test was performed as allowed by a previous relief request. Based on historical 1ST testing for SLC Pump A and SLC Pump B, over 10 years of data is available to evaluate pump performance.
In conclusion, the proposed alternative to perform the comprehensive test in lieu of the Mandatory Appendix V Pump Periodic Verification Test provides a reasonable alternative to
Perry Nuclear Power Plant, Unit 1 PR-3 Page 3 of 3 the Code requirements specified in ISTB-1400(d) and Mandatory Appendix V Section V-2000.
This is based on the determination that the proposed alternative continues to provide reasonable assurance of the operational readiness of the pumps and provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(z)(1 ).
6. Duration of Proposed Alternative
The proposed alternative identified in this request shall be utilized during the fourth 10-year 1ST interval, which began on May 18, 2019, and ends on May 17, 2029.
- 7. Precedent This is the first relief request for periodic verification testing of design basis accident flow rate pressure in accordance with the 2012 Edition of the ASME OM Code, Mandatory Appendix V.
The following precedent, while not specific to the 2012 Edition of the ASME OM Code, is similar in that the Nuclear Regulatory Commission (NRC) found the modified Group A test acceptable for the SLC pumps at PNPP. For the 2012 Edition of the ASME OM Code, the comprehensive test is equivalent to this modified Group A test.
- 1. NRC Letter, "Perry Nuclear Power Plant, Unit No. 1 - Relief Request PR-3 for Third 10-Year Pump and Valve lnservice Testing Program (TAC No. ME0820)," dated October 8, 2009 (ADAMS Accession No. ML092640690)