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Category:Code Relief or Alternative
MONTHYEARML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23151A3482023-05-30030 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI RA-22-0257, Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-02-17017 February 2023 Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML21259A0992021-11-0404 November 2021 Proposed Alternatives to American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants ML21214A2222021-08-10010 August 2021 Proposed Alternatives to American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants ML21209A9962021-08-0202 August 2021 Proposed Alternative Request IST-RR-8 Related to the Inservice Testing Program ML21202A3982021-07-27027 July 2021 Relief Request Proposed Alternatives to American Society of Mechanical Engineers Operation and Maintenance Code Isolation Valve Seal Water System ML21068A4172021-03-17017 March 2021 Summary of Meeting with Duke Energy Progress, LLC, Regarding a Proposed Relief Request Concerning Containment Inspections of Liners and Moisture Barriers for the H. B. Robinson Steam Electric Plant, Unit 2 ML21029A3352021-02-16016 February 2021 Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML20090F8932020-04-29029 April 2020 Relief Request RA-19-0138 Regarding Proposed Alternative to ASME Code, Section XI Volumetric Examination Frequency Requirements RA-19-0428, Relief Request RA-19-0428 for One-Time Pressure Relief Valve Test Frequency Extension2020-02-0404 February 2020 Relief Request RA-19-0428 for One-Time Pressure Relief Valve Test Frequency Extension ML19098A0342019-04-30030 April 2019 Units 1 and 2; Limerick, Units 1 and 2; Peach Bottom, Units 2 and 3, and Quad Cities, Units 1 and 2 - Revision to Approved Alternative to Use BWR Vessel and Internal Proj Guidelins RA-19-0026, Response to Request for Additional Information (RAI) Regarding Proposed Alternative to the Depth Sizing Qualification Requirement of Appendix Viii, Supplements 2 and 10 (18-GO-001)2019-02-11011 February 2019 Response to Request for Additional Information (RAI) Regarding Proposed Alternative to the Depth Sizing Qualification Requirement of Appendix Viii, Supplements 2 and 10 (18-GO-001) RA-18-0180, Supplement to Relief Request for an Alternative to the Depth Sizing Qualification Requirement of Appendix Viii, Supplements 22018-11-12012 November 2018 Supplement to Relief Request for an Alternative to the Depth Sizing Qualification Requirement of Appendix Viii, Supplements 2 ML17331A0862017-12-26026 December 2017 Alternative to Inservice Inspection Regarding Reactor Pressure Vessel Threads RNP-RA/13-0018, Relief Request (RR)-8 from Fifth Ten-Year Inservice Inspection Program Plan2013-03-13013 March 2013 Relief Request (RR)-8 from Fifth Ten-Year Inservice Inspection Program Plan ML12314A2882012-12-11011 December 2012 Relief Request-2 for the Fifth 10-Year Interval Inservice Testing Program Plan RNP-RA/12-0113, Response to Request for Additional Information Related to Relief Request (RR)-07 from Immediate ASME Code Repair of Refueling Water Storage Tank Drain Value (SI-837) for Fifth Ten-Year Inservice Inspection...2012-10-25025 October 2012 Response to Request for Additional Information Related to Relief Request (RR)-07 from Immediate ASME Code Repair of Refueling Water Storage Tank Drain Value (SI-837) for Fifth Ten-Year Inservice Inspection... RNP-RA/12-0101, Relief Request (RR)-7 from Immediate ASME Code Repair of Refueling Water Storage Tank Drain Value (SI-837) for Fifth Ten-year Inservice Inspection Program Plan2012-10-0505 October 2012 Relief Request (RR)-7 from Immediate ASME Code Repair of Refueling Water Storage Tank Drain Value (SI-837) for Fifth Ten-year Inservice Inspection Program Plan ML12262A3622012-10-0101 October 2012 Relief Request No. 2 for the Fifth 10-Year Interval Inservice Inspection Program Plan RNP-RA/12-0079, Revised Response to NRC Request for Additional Information Related to Relief Request (RR)-2 for the Fifth Ten-Year Interval Inservice Testing Program Plan2012-08-0909 August 2012 Revised Response to NRC Request for Additional Information Related to Relief Request (RR)-2 for the Fifth Ten-Year Interval Inservice Testing Program Plan ML12181A1262012-07-13013 July 2012 Relief Request-4 for the Fifth 10-Year Interval Inservice Inspection Program Plan ML12174A0182012-07-13013 July 2012 Relief Request-1 for the Fifth 10-Year Interval Inservice Testing Program ML12174A0102012-07-13013 July 2012 Relief Request -3 for Fifth 10-Year Interval Inservice Testing Program Plan ML12167A2152012-07-13013 July 2012 Relief Request (RR)-6 for the Fifth 10-Year Interval Inservice Inspection Program Plan ML12115A0692012-05-0404 May 2012 Request for Additional Information Related to Relief Requests RR-5 and RR-6 for the Fifth Ten-Year Interval Inservice Inspection Program Plant RNP-RA/08-0129, Request for Extension for Implement Ion of License Amendment Related to Control Room Habitability2009-01-0707 January 2009 Request for Extension for Implement Ion of License Amendment Related to Control Room Habitability ML0827302702008-10-22022 October 2008 Request for Relief from ASME Code, Section XI, Appendix Viii, Supplement 2 and Supplement 10 Weld Examination Requirements ML0427400822004-09-29029 September 2004 Third 10-Year Interval Inservice Inspection Program Plan Request for Relief No. 34 ML0411702632004-04-21021 April 2004 Relief, ASME Code, Section XI, Appendix Viii, Supplement 10, Qualification Requirements for Inspection of Dissimilar Metal Piping Welds, for the Fourth 10-year Inservice Inspection (ISI) Interval, MC1639 RNP-RA/03-0125, Inservice Testing Program, Relief Request IST-RR-8 for Comprehensive Tests2003-10-0707 October 2003 Inservice Testing Program, Relief Request IST-RR-8 for Comprehensive Tests ML0233101712002-11-26026 November 2002 Relief, Examination of Control Rod Drive Mechanism Housing Seal Weld 2023-09-25
[Table view] Category:Letter type:RNP
MONTHYEARRNP-RA/21-0035, Duke Energy Progress, Inc - Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-18018 February 2021 Duke Energy Progress, Inc - Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report RNP-RA/20-0234, Independent Spent Fuel Storage Installation, Registration of Use of Spent Fuel Casks2020-07-23023 July 2020 Independent Spent Fuel Storage Installation, Registration of Use of Spent Fuel Casks RNP-RA/20-0199, Registration of Use of Spent Fuel Casks2020-06-25025 June 2020 Registration of Use of Spent Fuel Casks RNP-RA/18-0063, Request for Extension of Due Date for Seismic Probabilistic Risk Assessment Submittal2018-11-29029 November 2018 Request for Extension of Due Date for Seismic Probabilistic Risk Assessment Submittal RNP-RA/18-0060, Transmittal of Core Operating Limits Report2018-10-17017 October 2018 Transmittal of Core Operating Limits Report RNP-RA/18-0050, Response to Supplemental Request for Additional Information Regarding License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Change2018-08-0101 August 2018 Response to Supplemental Request for Additional Information Regarding License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Change RNP-RA/18-0044, Supplement to License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transform2018-07-11011 July 2018 Supplement to License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transformers RNP-RA/18-0039, Transmittal of Emergency Procedure Revisions and 10 CFR 50.54(q) Summary of Analysis2018-06-27027 June 2018 Transmittal of Emergency Procedure Revisions and 10 CFR 50.54(q) Summary of Analysis RNP-RA/18-0041, Independent Spent Fuel Storage Installation - Register as User for Cask2018-06-13013 June 2018 Independent Spent Fuel Storage Installation - Register as User for Cask RNP-RA/18-0036, Response to Request for Additional Information (RAI) Regarding Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use ...2018-05-16016 May 2018 Response to Request for Additional Information (RAI) Regarding Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specification 3.8.1, AC Sources - Operating and the Use ... RNP-RA/18-0029, Submittal of 2017 Annual Radiological Environmental Operating Report2018-05-0808 May 2018 Submittal of 2017 Annual Radiological Environmental Operating Report RNP-RA/18-0031, (Hbrsep), Unit 2 - 2017 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Revision 352018-04-23023 April 2018 (Hbrsep), Unit 2 - 2017 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Revision 35 RNP-RA/18-0015, Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequently Requirements to a Licensee Controlled Program2018-04-16016 April 2018 Application for Technical Specifications Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequently Requirements to a Licensee Controlled Program RNP-RA/18-0024, Report of Changes Pursuant to 10 CFR 50.59(d)(2)2018-04-0202 April 2018 Report of Changes Pursuant to 10 CFR 50.59(d)(2) RNP-RA/18-0020, Notification of Change in Licensed Operator Status2018-02-20020 February 2018 Notification of Change in Licensed Operator Status RNP-RA/18-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2018-01-23023 January 2018 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report RNP-RA/17-0085, Request for Additional Information Regarding Application to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2018-01-0808 January 2018 Request for Additional Information Regarding Application to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0086, Transmittal of Emergency Procedure Revision and 10 CFR 50.54(q) Summary of Analyses2017-12-14014 December 2017 Transmittal of Emergency Procedure Revision and 10 CFR 50.54(q) Summary of Analyses RNP-RA/17-0081, Submittal of Change in Licensed Operators Medical Status2017-12-11011 December 2017 Submittal of Change in Licensed Operators Medical Status RNP-RA/17-0079, Operator License Renewal Application2017-12-0707 December 2017 Operator License Renewal Application RNP-RA/17-0071, Independent Spent Fuel Storage Installation (ISFSI) Registration for Use of General License Spent Fuel Casks2017-10-19019 October 2017 Independent Spent Fuel Storage Installation (ISFSI) Registration for Use of General License Spent Fuel Casks RNP-RA/17-0068, Response to NRC Request for Additional Information Related to License Amendment Request Regarding Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-09-28028 September 2017 Response to NRC Request for Additional Information Related to License Amendment Request Regarding Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0037, License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specifications 3.8.1, AC Sources-Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transformers2017-09-27027 September 2017 License Amendment Request Proposing to Add a Qualified Offsite Circuit to Technical Specifications 3.8.1, AC Sources-Operating and the Use of Load Tap Changers in the Automatic Mode of Operation on the Startup Transformers RNP-RA/17-0043, Relief Request (RR)-12 for Relief from Volumetric/Surface Examination Frequency Requirements of ASME Code Case N-729-42017-09-22022 September 2017 Relief Request (RR)-12 for Relief from Volumetric/Surface Examination Frequency Requirements of ASME Code Case N-729-4 RNP-RA/17-0065, Refueling Outage 30 Steam Generator Tube Inspection Report2017-09-18018 September 2017 Refueling Outage 30 Steam Generator Tube Inspection Report RNP-RA/17-0060, Notification of Change in Licensed Operator Status2017-08-10010 August 2017 Notification of Change in Licensed Operator Status RNP-RA/17-0058, Notification of Change in Licensed Operator Status2017-08-0303 August 2017 Notification of Change in Licensed Operator Status RNP-RA/17-0055, Transmittal of Core Operating Limits Report for Cycle 312017-07-26026 July 2017 Transmittal of Core Operating Limits Report for Cycle 31 RNP-RA/17-0042, Submittal of the PWROG-14048-P, Revision 1, to Satisfy the Regulatory Commitment Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals2017-06-29029 June 2017 Submittal of the PWROG-14048-P, Revision 1, to Satisfy the Regulatory Commitment Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals RNP-RA/17-0051, Submittal of Nine Day Inservice Inspection Summary Report2017-06-29029 June 2017 Submittal of Nine Day Inservice Inspection Summary Report RNP-RA/17-0041, Transmittal of Technical Specifications Bases Revisions2017-05-23023 May 2017 Transmittal of Technical Specifications Bases Revisions RNP-RA/17-0038, (Hbrsep), Unit No. 2 - 2016 Annual Radiological Environmental Operating Report2017-05-0909 May 2017 (Hbrsep), Unit No. 2 - 2016 Annual Radiological Environmental Operating Report RNP-RA/17-0034, Modification of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles (MF9544)2017-05-0202 May 2017 Modification of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles (MF9544) RNP-RA/17-0036, (Hbrsep), Unit No. 2 - 2016 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Current Revision 342017-04-25025 April 2017 (Hbrsep), Unit No. 2 - 2016 Annual Radioactive Effluent Release Report and Offsite Dose Calculation Manual, Current Revision 34 RNP-RA/17-0031, Provides Additional Information Regarding License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler 522, Revision 02017-04-20020 April 2017 Provides Additional Information Regarding License Amendment Request to Adopt Technical Specifications Task Force (TSTF) Traveler 522, Revision 0 RNP-RA/17-0033, Flood Hazard Mitigating Strategies Assessment (MSA) Report Submittal2017-04-12012 April 2017 Flood Hazard Mitigating Strategies Assessment (MSA) Report Submittal RNP-RA/17-0014, Resubmittal of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-04-0303 April 2017 Resubmittal of Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0028, Submittal of Engineering Calculation in Support of a Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2017-04-0303 April 2017 Submittal of Engineering Calculation in Support of a Request for Technical Specification Change to Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/17-0021, Transmittal of Core Operating Limits Report2017-03-13013 March 2017 Transmittal of Core Operating Limits Report RNP-RA/17-0019, Supplemental Submittal to Correct Marked Up Technical Specifications (TS) Pages Transmitted with Application for Technical Specification Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Revision 22017-03-0808 March 2017 Supplemental Submittal to Correct Marked Up Technical Specifications (TS) Pages Transmitted with Application for Technical Specification Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Revision 2 RNP-RA/17-0015, Independent Spent Fuel Storage Installations - Letter Regarding Report of Changes Pursuant to 10 CFR 72.482017-02-22022 February 2017 Independent Spent Fuel Storage Installations - Letter Regarding Report of Changes Pursuant to 10 CFR 72.48 RNP-RA/17-0016, Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report2017-02-22022 February 2017 Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report RNP-RA/17-0015, H.B. Robinson Steam Electric Plant & ISFSIs - Report of Changes Pursuant to 10 CFR 72.482017-02-22022 February 2017 H.B. Robinson Steam Electric Plant & ISFSIs - Report of Changes Pursuant to 10 CFR 72.48 RNP-RA/16-0100, Response to Apparent Violation in NRC Inspection Report 05000261/2016404, EA-16-2272017-01-24024 January 2017 Response to Apparent Violation in NRC Inspection Report 05000261/2016404, EA-16-227 RNP-RA/16-0097, Transmittal Letter for Response to Inspection Report Temporary Instruction 2201/004, Inspection of Implementation of Interim Cyber Security Milestones 1-7, Inspection Report 05000261/20154052016-12-15015 December 2016 Transmittal Letter for Response to Inspection Report Temporary Instruction 2201/004, Inspection of Implementation of Interim Cyber Security Milestones 1-7, Inspection Report 05000261/2015405 RNP-RA/16-0089, Request for Withdrawal of License Amendment Request for Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles2016-11-10010 November 2016 Request for Withdrawal of License Amendment Request for Change Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles RNP-RA/16-0090, Notification of Rescheduled Date for 2017 Emergency Preparedness Graded Exercise2016-11-10010 November 2016 Notification of Rescheduled Date for 2017 Emergency Preparedness Graded Exercise RNP-RA/16-0087, Technical Specifications Section 5.6.6 Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors2016-10-31031 October 2016 Technical Specifications Section 5.6.6 Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors RNP-RA/16-0078, Technical Specifications Section 5.6.6, Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors2016-10-0505 October 2016 Technical Specifications Section 5.6.6, Post Accident Monitoring Instrumentation Report for Inoperable High Range Containment Area Radiation Monitors RNP-RA/16-0079, Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants.2016-10-0505 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Light Water Reactor Electric Generating Plants. 2021-02-18
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q 10 CFR 50.55a Lb ProgressEnergy Serial: RNP-RA/03-0125 OCT 072003 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 INSERVICE TESTING PROGRAM RELIEF REQUEST IST-RR-8 FOR COMPREHENSIVE TESTS Ladies and Gentlemen:
In accordance with 10 CFR 50.55a(s)(3)(i), H. B. Robinson Steam Electric Plant (HBRSEP),
Unit No. 2, requests relief from the requirements of the American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (OM Code),
1995 Edition with 1996 Addenda. Specifically, relief is requested from Subsection ISTB 4.2(c),
which requires performance of Comprehensive Tests in accordance with ISTB 5.2.3 at an inservice test frequency specified by Table ISTB 5. l-l.
In this regard, please find attached the supporting details and technical information associated with HBRSEP, Unit No. 2, Relief Request IST-RR-8. This relief, if approved, would obviate the need for Comprehensive Tests for pumps that are tested within &20% of design flow during the quarterly Group A test.
In order to support timely implementation of forthcoming tests in February 2004, it is respectfully requested that NRC review of this relief request be completed by January 16,2004.
If you have any questions regarding this matter, please contact me.
Sincerely, C. T. Baucom Supervisor - Licensing/Regulatory Programs Progress Energy Carolinas, Inc.
Hohnson Nuclear Plant 158 I West fntrance Road ti<3rtsLlle, SC 29550
United States Nuclear Regulatory Commission Serial: RNP-RA/03-0125 Page 2 of 2 CTB/jwv Attachment c: Mr. L. A. Reyes, NRC, Region II Mr. C. P. Patel, NRC, NRR NRC Resident Inspectors
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/03-0125 Page 1 of 5 PROGRESS ENERGY CAROLINAS, INC.
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 10 CFR 50.55a RELIEF REQUEST IST-RR-8 RELIEF REQUESTED IN ACCORDANCE WITH 10 CFR 50.55a(a)(3)(i)
--PROPOSED ALTERNATIVE WOULD PROVIDE AN ACCEPTABLE LEVEL OF QUALITY AND SAFETY--
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/03-0125 Page 2 of 5
- 1. ASME Code Components Affected Service Water Pump A (SW-A)
Service Water Pump B (SW-B)
Service Water Pump C (SW-C)
Service Water Pump D (SW-D)
Service Water Booster Pump A (SWBP-A)
Service Water Booster Pump B (SWBP-B)
Component Cooling Water Pump A (CCW-A)
Component Cooling Water Pump B (CCW-B)
Component Cooling Water Pump C (CCW-C)
Boric Acid Transfer Pump A (BA-A)
Boric Acid Transfer Pump B (BA-B)
Safety Injection Pump A (SI-A)
Safety Injection Pump B (SI-B)
Safety Injection Pump C (SI-C)
Containment Spray Pump A (CS-A)
Containment Spray Pump B (CS-B)
Chemical Volume Control System Charging Pump A (CVCS-A)
Chemical Volume Control System Charging Pump B (CVCS-B)
Chemical Volume Control System Charging Pump C (CVCS-C)
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Code for Operations and Maintenance of Nuclear Power Plants (OM Code), 1995 Edition with 1996 Addenda.
3. Applicable Code Requirement
The ASME OM Code, Subsection ISTB 4.2(c), requires performance of Comprehensive Tests in accordance with ISTB 5.2.3 at an inservice test frequency specified by Table ISTB 5.1-1.
4. Reason for Request
H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, requests relief from the requirements of ISTB 4.2(c), such that the Comprehensive Test requirements may be eliminated for those pumps that are tested to within +/-20% of design flow during the quarterly Group A test.
The ASME OM Code, ISTB 5.2.3, requires that a Comprehensive Test be conducted at a specified reference point. ISTB 4.3(e)(1) requires that this reference point be established
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/03-0125 Page 3 of 5 within +/-20% of the design flow rate. The test must be conducted biennially in accordance with Table ISTB 5.1-1.
In addition to the requirement to conduct the Comprehensive Test at design flow rate, the Comprehensive Test requirements differ from the Group A hydraulic test requirements as follows:
- The Comprehensive Test requirements specify that the pressure and differential pressure measurements be accurate to 0.5%, instead of 2% (OM Code, Table ISTB 4.7.1-1).
- The Comprehensive Test requirements employ more restrictive acceptance criteria, primarily for upper limits (improved performance) (OM Code, Tables ISTB 5.2.1-2 and ISTB 5.2.3-1).
The ASME OM Code requires pumps to be tested every two years within 20% of design flow conditions to provide increased assurance of pump operational readiness.
The conduct of the quarterly Group A test at design flow rates provides a better continuous overall assessment of functional capability when compared to the Code-required quarterly test at flow conditions other than +/-20% of design flow rate, even when supplemented with the biennial Comprehensive Test.
The test requirements for vibration, including the acceptance limits applicable to the Comprehensive Test and Group A tests, are identical. Using test flow rates within +/-20% of the design flow rates will improve detection capabilities because at lower flow rates flow noise may adversely impact the ability to detect degrading pump condition. Testing at flow rates within +/-20% of the design flow rates improves detection capabilities associated with mechanical and hydraulic condition.
The required action limits are identical for the Comprehensive Test and Group A vibration test requirements. In addition, the required action low limits are identical for Comprehensive Test and Group A hydraulic test requirements. However, the Comprehensive Test hydraulic acceptance criteria contain smaller band alert thresholds that are dependent on the pump type. If measured test parameters exceed the alert range limits, the frequency of Comprehensive Tests must be doubled until the cause is determined and the condition is corrected.
The Comprehensive Test and Group A test hydraulic upper acceptance limits comprise the most significant difference. The Comprehensive Test upper hydraulic acceptable limit is 1.03 times the reference value, while the Group A test upper acceptable limit is 1.10 times the reference value.
Prior to the 1990 OM Code, the ASME Code established a limit of 1.03 times the reference value for quarterly tests, which was subsequently increased to the current 1.10 times the reference value for non-comprehensive testing.
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/03-0125 Page 4 of 5 An upper limiting value of 3% above the reference value does not support improvements to detection of a degrading pump condition. Additionally, this criteria can create undue hardship because the OM Code does not allow pumps that exceed the acceptance limit to return to operable status unless the cause for the deviation is known and the condition is corrected. It is often difficult to determine a specific cause for the condition when a pump marginally exceeds the upper limit. In addition to nominal test uncertainties (meter increments, parallax error, test condition deviations, and fluctuation of data during acquisition), a reference value may have been established with the instrument biased on the low side of the allowable range. Subsequent tests may use the same or similar instruments biased on the high side of the allowable span. The singular or cumulative effects of these conditions make the imposition of a 3% upper limit impractical and unwarranted.
Implementation of a Group A test and Comprehensive Test at identical reference conditions creates the potential situation where a quarterly Group A test is completed and found within the established test acceptance criteria. However, if the test data falls outside the allowable range established for the Comprehensive Test, even though the Comprehensive Test was not being performed, there is no clear direction on how to proceed.
Group A and Comprehensive Test reference values at different operating points could create an adverse effect during maintenance when post maintenance tests may be required for both test points to confirm or establish reference values, leading to increased use of manpower, additional equipment cycling, and a reduction in the overall availability of safety-related equipment.
The list of components affected includes two Group B pumps (Containment Spray Pumps A and B). These pumps are currently being tested in accordance with the more restrictive Group A requirements, although a Comprehensive Test for these pumps has not yet been completed and is due to be performed during the Spring 2004 refueling outage. The Group A and Group B test intervals are the same, and the difference between the Group A and Group B test parameters is that Group B does not require vibration measurements for centrifugal pumps during a non-comprehensive test. However, because HBRSEP, Unit No. 2, is currently testing these pumps to the more restrictive Group A parameters, these pumps are also included in the requested relief.
The proposed alternative will allow HBRSEP, Unit No. 2, to more adequately and uniformly assess pump performance. Therefore, the performance of a routine Group A test conducted at +/-20%
design flow rate provides an acceptable level of quality and safety.
United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/03-0125 Page 5 of 5
- 5. Proposed Alternative and Basis for Use HBRSEP, Unit No. 2, will conduct the quarterly Group A pump tests at the flow rates specified by ISTB 4.3(e)(1) for the Comprehensive Test. For pumps tested to these conditions, the Comprehensive Test requirements specified by ISTB 4.2(c) and Table ISTB 5.1-1 will not be conducted. Based on the information presented in the Reason for Request, there is reasonable assurance that operational readiness of the affected pumps will be maintained and that the proposed alternative provides an acceptable level of quality and safety.
- 6. Duration of Proposed Alternative This proposed alternative will be utilized for the duration of the Fourth Ten-Year Interval which began February 19, 2002.
- 7. Precedents None identified.