ML20189A003

Relief Request PR-3 for Fourth 10-Year Pump and Valve Inservice Testing Program

ML20189A003
Person / Time
Site:	Perry
Issue date:	07/10/2020
From:	Robert Kuntz Plant Licensing Branch III
To:	Payne F Energy Harbor Nuclear Corp
Wall S
References
EPID L-2019-LLR-0111
Download: ML20189A003 (8)

Text

July 10, 2020 Mr. Frank R. Payne Site Vice President Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant P.O. Box 97, SB306 Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - RELIEF REQUEST PR-3 FOR FOURTH 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM (EPID L-2019-LLR-0111)

Dear Mr. Payne:

By letter dated December 16, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19351C732), FirstEnergy Nuclear Operating Company (FENOC),

submitted revised pump relief request PR-3 to the U.S. Nuclear Regulatory Commission (NRC).

The licensee requested an alternative test plan in lieu of certain inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the IST program at Perry Nuclear Power Plant.

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(z)(1),

the licensee requested to use proposed alternatives PR-3 on the basis that the alternatives provide an acceptable level of quality and safety. During NRC staff review of the request PR-3, Revision 1, the staff noted that the request will be reviewed in accordance with 10 CFR 50.55a(z)(2) on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.

The NRC staff finds that the proposed alternatives described in request PR-3, Revision 1, provide reasonable assurance that the standby liquid control pumps listed in Table 1 of the enclosed safety evaluation are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2) for requests PR-3, Revision 1. Therefore, the NRC staff authorizes the use of the alternative requests PR-3, Revision 1, for the fourth 10-year IST program interval, which began on May 18, 2019 and is scheduled to end on May 17, 2029.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable.

F. Payne If you have any questions, please contact the Project Manager, at 301-415-2855 or e-mail at Scott.Wall@nrc.gov.

Sincerely, Digitally signed by Robert F. Robert F. Kuntz Date: 2020.07.10 Kuntz 12:28:12 -04'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-440

Enclosure:

Safety Evaluation cc: ListServ

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 10 CFR 50.55a REQUEST PR-3, REVISION 1 RELIEF REQUEST FOR PUMP AND VALVE INSERVICE TESTING PROGRAM FOURTH 10-YEAR INSERVICE TESTING INTERVAL PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated December 16, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19351C732), First Energy Nuclear Operating Company (FENOC, the licensee), submitted alternative request to the U.S. Nuclear Regulatory Commission (NRC).

The licensee requested an alternative test plan in lieu of certain inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the IST program at Perry Nuclear Power Plant, Unit No. 1 (PNPP), during the fourth 10-year IST program intervals. Specifically, the licensee requested to implement proposed alternative PR-3, Revision 1, related to the testing of standby liquid control (SLC) pumps A and B on the basis that the alternative provides an acceptable level of quality and safety.

By order dated December 2, 2019 (ADAMS Accession No. ML19303C953), the NRC staff approved the direct and indirect transfers of several FENOC-owned and operated plants, including PNPP. By letter dated December 3, 2019 (ADAMS Accession No. ML19337B181),

FENOC indicated that the entities taking control of the plants, which had previously been referred to as New Hold Co, OwnerCo, and OpCo would be named Energy Harbor Corp.,

Energy Harbor Nuclear Generation LLC, and Energy Harbor Nuclear Corp., respectively. Under this new set-up, Energy Harbor Corp. would indirectly own the plants as a parent company, Energy Harbor Nuclear Generation LLC would directly own the plants, and Energy Harbor Nuclear Corp. would have authority to operate the plants.

On February 20, 2020, FENOC informed the NRC (ADAMS Accession No. ML20054B733) that:

Upon completion of the license transfer, Energy Harbor Nuclear Corp. will adopt and endorse the outstanding commitments, licensing actions, applications, and similar items on the aforementioned docket numbers. Energy Harbor Nuclear Corp. requests NRC continuation of the regulatory reviews and actions on these items.

Enclosure

On February 27, 2020, Energy Harbor Nuclear Corp., informed the NRC that the transaction closed on February 27, 2020, and that it adopted and endorsed the outstanding commitments, licensing actions, applications and similar items on dockets submitted by FENOC on behalf of the licensees (ADAMS Accession No. ML20058D315). On February 27, 2020 (ADAMS Accession No. ML20030A440), the NRC staff issued Amendment No. 187 to reflect the license transfer. Accordingly, Energy Harbor Nuclear Corp. is now authorized to act as agent for Energy Harbor Nuclear Generation, LLC, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility at PNPP.

2.0 REGULATORY EVALUATION

The NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 55a(f)(4), Inservice testing standards requirement for operating plants, states, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the IST requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv),

to the extent practical within the limitations of design, geometry, and materials of construction of the components.

Regulation 10 CFR 50.55a(z) states, in part, that alternatives to the requirements of 10 CFR 50.55a(f) may be used, when authorized by the NRC, if the licensee demonstrates:

(1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

3.0 TECHNICAL EVALUATION

3.1 System Description The 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. The SLC pumps are reciprocating-type positive displacement pumps. The hydraulic circuits for IST 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 3.2 Affected Components Table 1 Pump ID Function Class Group 1C41-C001A SLC Pump A 2 B 1C41-C001B SLC Pump B 2 B 3.3 Applicable ASME OM Code Requirements The applicable ASME OM Code edition for the fourth IST program interval at PNPP is ASME OM Code, 2012 Edition.

Paragraph ISTB-1400(d) of the ASME OM Code, 2012 Edition, state that the Owners responsibly includes:

establishing a pump periodic verification test program in accordance with Division 1, Mandatory Appendix V.

Division 1, Mandatory Appendix V Pump Periodic Verification Test Program, 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.

ISTB-3000, General Testing Requirements, and Table ISTB-3000-1, Inservice Test Parameters, define and compare parameters (e.g., pressure flow rate, vibration) measured during Group A, Group B, and Comprehensive pump tests.

ISTB-3510(a), "Accuracy", states that "Instrument accuracy shall be within the limits of Table ISTB-3510-1. Table ISTB-3510-1, "Required Instrument Accuracy," requires that Comprehensive and Preservice Test pressure instrument accuracy to be +/- 0.5 percent.

Table ISTB-5321-2, Reciprocating Positive Displacement Pump Test Acceptance Criteria, defines the required acceptance criteria for reciprocating positive displacement pumps for Group A. Group B and comprehensive tests.

3.4 Proposed Alternative The licensee is proposing an alternative to perform the Mandatory Appendix V Pump Periodic Verification Test at least once every two years. The pumps applicable to this request are listed in Table 1 of this safety evaluation (SE). The licensee states that a comprehensive test will be performed quarterly using the 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.

3.5 NRC Staff Evaluation The ASME OM Code Mandatory Appendix V requires safety-related pumps have a periodic verification test program where the pumps are tested at their highest design basis accident flow rate and pressure (differential or discharge as applicable). The test shall be completed at least once every 2 years.

Typical reciprocating positive displacement pumps move fluid using one or more oscillating pistons, plungers, or membranes (diaphragms), while valves restrict fluid motion to the desired direction. This type of pump can deliver a constant flow regardless of system pressure. The licensee has stated that currently the pump is being tested at a reference point at or near pump design pressure. Setting the reference point requires throttling the discharge valve until reference pressure is achieved. The licensee states that the throttle valve is nearly closed (one quarter turn from full close) to meet the test reference point pressure. To meet the required

design pressure requirement for Mandatory Appendix V, the valve will have to be closed further.

This raises several concerns:

1) It may be necessary to fully close the valve in order to achieve the required design pressure. This could challenge the system piping should the safety relief valves fail.

2) The reciprocating action of the pump can cause pressure spikes during pump operation.

The pressure spike action could cause the safety relief valves in the system piping to chatter which can lead to damage of the safety relief valve seat and plug.

3) The safety relief valves may be challenged, lift, and not reseat.

In lieu of performing the periodic verification test once every two years per Mandatory Appendix V, the licensee has proposed to perform quarterly comprehensive testing per 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 quarterly comprehensive test requires more accurate pressure monitoring instrumentation with a tighter acceptance band, flow measurement, and vibration monitoring for trending. The test is performed at a reference value taken at or near pump design pressure. These pumps have a good performance history and data to support the continued testing following the comprehensive test requirements. This type of test can detect degradation of pump performance over time and ensures that the pumps are operationally ready.

The licensee requested this alternative on the basis of 10 CFR 50.55a(z)(1), the proposed alternative would provide an acceptable level of quality and safety. However, the licensees primary reason for the alternative proposal was the performance of the test requirements may challenge the components and piping system. Attempting to test the pumps at the highest design pressure and flow represents an undue hardship without an increase in the level of quality and safety which is applicable to 10 CFR 50.55a(z)(2). Testing the pumps via comprehensive pump requirements provides reasonable assurance that they are operationally ready. Because of this, the NRC staff reviewed the alternative request in accordance with 10 CFR 50.55a(z)(2) on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.

4.0 CONCLUSION

As set forth above, the NRC staff determined that the proposed alternative PR-3, Revision 1, provides reasonable assurance that the components listed in Table 1 of this safety evaluation are operationally ready. The NRC staff also determined that compliance with the testing requirements in the ASME OM Code (2012 Edition) for these SLC pumps would result in hardship without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(z)(2). Therefore, the NRC staff authorizes the proposed alternative PR-3, Revision 1, for the fourth 10-year IST interval at PNPP which began on May 18, 2019, and is currently scheduled to end on May 17, 2029.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable.

Principal Contributor: Michael Farnan, NRR Date: July 10, 2020

ML20189A003 *via e-mail **via memo OFFICE NRR/DORL/LPL3/PM* NRR/DORL/LPL3/LA* NRR/DEX/EMIB/BC** NRR/DORL/LPL3/BC*

NSalgado NAME SArora SRohrer ABuford (RKuntz for)

DATE 07/06/2020 07/07/2020 06/22/2020 07/10/2020