NOC-AE-20003700, Proposed Alternatives to ASME OM Code 2012 Edition for the Fourth Inservice Test Interval (Relief Request PRR-01)

Proposed Alternatives to ASME OM Code 2012 Edition for the Fourth Inservice Test Interval (Relief Request PRR-01)

ML20022A318
Person / Time
Site:	South Texas
Issue date:	01/22/2020
From:	Dunn R South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-20003700, PRR-01
Download: ML20022A318 (4)

Text

Nuclear Operating Company South Texas Prolect Electric Generating Station P.O. Box 289 Wadsworth, Teas 77483 January 22,2020 NOC-AE-20003700 10CFR50.55a(z)

STI:34969275 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Proposed Alternatives to ASME OM Code 2012 Edition for the Fourth Inservice Test Interval (Relief Request PRR-01)

Pursuant to 10 CFR 50.55a(z), STP Nuclear Operating Company (STPNOC) hereby requests an alternative to the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition for use during the fourth ten-year Inservice Test (1ST) interval at South Texas Project. The details of the request are attached.

STPNOC request approval of the alternatives by September 1, 2020 to support the fourth ten-year interval starting on September 25,2020.

There are no new commitments in this letter.

If there are any questions regarding this request, please contact N. Boehmisch at 361-972-8172 or me at 361-972-7743.

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Roland Dunn General Manager, Engineering

Attachment:

Relief Request PRR-01, Use of Code Case OMN-18 ec:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511

Attachment NOC-AE-20003700 Page 1 of 3 Attachment Relief Request PRR-01, Use of Code Case OMN-18

1. ASME Code Component(s) Affected 3S141(2)MPA01, Auxiliary Feedwater Pump 11/21 (Class 3) 3S141(2)MPA02, Auxiliary Feedwater Pump 12/22 (Class 3) 3S141(2)MPA03, Auxiliary Feedwater Pump 13/23 (Class 3) 3S141(2)MPA04, Auxiliary Feedwater Pump 14/24 (Class 3) 3R201(2)NPA1(2)01A, Component Cooling Water Pump 1A/2A (Class 3) 3R201(2)NPA1(2)01B, Component Cooling Water Pump 1B/2B (Class 3) 3R201(2)NPA1(2)01C, Component Cooling Water Pump 1C/2C (Class 3) 3V111(2)VPA004, Essential Chilled Water Pump 11A/21A (Class 3) 3V111 (2)VPA005, Essential Chilled Water Pump 11 B/21 B (Class 3) 3V111 (2)VPA006, Essential Chilled Water Pump 11 C/21 C (Class 3) 3R281(2)NPA1(2)01A, Essential Cooling Water Pump 1A/2A (Class 3) 3R281(2)NPA1(2)01B, Essential Cooling Water Pump 1B/2B (Class 3) 3R281(2)NPA1(2)01C, Essential Cooling Water Pump 1C/2C (Class 3) 3R211(2)NPA1(2)01A, Spent Fuel Pool Coding Pump 1A/2A (Class 3) 3R211(2)NPA1(2)01B, Spent Fuel Pool Cooling Pump 1B/2B (Class 3)

Function:

The above pumps are required to perform a specific function in shutting down the reactor to a safe shutdown, maintaining a safe shutdown condition or in mitigating the consequences of an accident.

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.

3. Applicable Code Requirement

ISTB-3400, "Frequency of Inservice Tests", states that an inservice test shall be run on each pump as specified in Table ISTB-3400-1.

Table ISTB-3400-1 requires Group A and Group B tests to be performed quarterly and a comprehensive test to be performed biennially.

Attachment NOC-AE-20003700 Page 2 of 3

4. Reason fprJRequest The ASME Code committees have approved Code Case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly within +/- 20% of Design Flow". This Code Case has been approved for use in Regulatory Guide (RG) 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code", Revision 2.

This Code Case allows the Owner to not perform the comprehensive test with the associated acceptance criteria, if the quarterly test is performed at +/- 20% of design flow and the instrumentation meets the accuracy requirements of Table ISTB-3500-1 for the comprehensive and preservice tests.

Further, the ISTB allows the Owner to categorize the pumps in their program. As such, an Owner could categorize a pump that otherwise meets the requirements of Group B, as a Group A pump, and test according to the provision of Code Case OMN-18. However, in doing so additional data (vibration and flow or differential pressure) is obtained quarterly, rather than once every two years Guidelines set forth in Code Case OMN-18 Revision 1 , "Use of a Pump Curve for Testing,"

will be followed. This Code Case has been approved for use per RG 1.192 Revision 2 for the ASME OM Code, 2012 Edition, however the associated Code Case applicability statement included in the 2012 Edition reflects 1994 and subsequent editions and addenda through the 2006 Addenda.

The upper end values of the Group A Test Acceptable Ranges for flow and differential pressure (or, discharge pressure) must be 1.06Qr and 1 .06APr (or 1.06Pr), respectively, as applicable to the pump type. The high values of the Required Action Ranges for flow and differential pressure (or discharge pressure) must be >1.06Qr and >1.06APr (or 1.06Pr),

respectively, as applicable to the pump type. This condition is listed in Table 2 of RG 1.192, and will be included in the test procedures at South Texas Project (STP).

Code applicability for Code Case OMN-18 lists OM Code 1994 Addenda, and subsequent Editions and Addenda through the 2006 Addenda. STPNOC is implementing the 2012 Edition of the OM Code.

5. Proposed Alternative and Basis for Use STPNOC proposes to employ the provisions of Code Case OMN-18 to perform a quarterly Group A test in lieu of performing a biennial comprehensive test and apply the acceptance criteria associated with the Group A test. As an alternative to utilizing the acceptance criteria associated with the Group A test, STPNOC will specify the acceptance criteria associated with the upper limit as 1.06% in lieu of the 1.10% allowed by Table ISTB-5121-1. This alternative testing is applicable to only those pumps with full flow testing capability. This alternative testing is also in compliance with the NRC Condition in Table 2 of RG 1.192, Revision 2, March 2017. The pressure instrumentation used during the tests shall have an accuracy of at least 0.5%.

Using the provisions of this relief request as an alternative to the requirements of ISTB-3400 provides a reasonable alternative to the ASME OM Code requirements. Based on this determination, the proposed alternative provides an acceptable level of quality and safety.

The 2012 Edition of the OM Code, ISTB-5000(b) allows for substitution of a comprehensive test for a Group A test.

Attachment NOC-AE-20003700 Page 3 of 3

Conclusion:

In summary, STPNOC proposes to test the pumps listed in this request by implementing the requirements ofASME OM Code Case OMN-18 per the NRC Condition listed in RG 1.192, Revision 2, Table 2, in lieu of ISTB-3400 and Table ISTB-3400-1.

Using the provisions of this request would provide adequate detection of component degradation and would continue to provide reasonable assurance of the operational readiness of affected components. Therefore, compliance with the requirements of ASME OM Code Case OMN-18 would result in an acceptable level of quality and safety pursuant to10CFR50.55a(z)(1).

6. Duration of Proposed Alternative The proposed alternative, if approved, would be implemented from the end of the Third Interval (September 25, 2020) until the end of the Fourth Interval (September 25, 2030).

7. Precedent NRC Safety Evaluation approving an STP pump relief request for the second ten-year interval of the 1ST program for STP (Reference 3).

NRC Safety Evaluation approving an STP pump relief request for the third ten-year interval of the 1ST program for STP (Reference 4).

8. References

1. ASME OM Code-2012, Code Case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly within +/- 20% of Design Flow"

2. Regulatory Guide 1.192, Revision 2, "Operation and Maintenance Code Case Acceptability, ASME OM Code", March 2017, ML16321A337

3. Letter from R.A. Gramm, NRC, to J.J. Sheppard, STPNOC, "South Texas Project (STP),

Units 1 and 2 - Evaluation of Relief Requests Related to the Second 10-Year Inservice Testing Program (TAG. Nos. MB2136 and MB2137)", May 2, 2003 (ML031220730)

4. Letter from M.T. Markley, NRC, to E.D. Halpin, STPNOC, "South Texas Project (STP),

Units 1 and 2 - Relief Request Nos. VRR-01, PRR-01, PRR-02, and PRR-03 for the Third 10-Year Inservice Testing Program Interval (TAG Nos. ME3515, ME3516, ME3517, ME3518, ME3519, ME3520, ME3521, and ME3522); September 2, 2010 (ML102150077)