View source for GO2-14-104, Response to Request for Additional Information Related to Relief Requests for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing Program

{{Adams
| number = ML14212A397
| issue date = 07/21/2014
| title = Response to Request for Additional Information Related to Relief Requests for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing Program
| author name = Javorik A
| author affiliation = Energy Northwest
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000397
| license number = 
| contact person = 
| case reference number = GO2-14-104, TAC MF3851, TAC MF3854, TAC MF3856
| document type = Letter type:GO
| page count = 19
| project = TAC:MF3851, TAC:MF3854, TAC:MF3856
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Em-0 Alex L.Javorik C0ombla Genereig Stathon P.O. Box 968, PE04 RkNlOd, WA 09352-096M Ph. 609.377.8555 I F. 509.377.4150 d*MdkV*0q**wtown G02-14-104 July 21, 2014 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Subject    COLUMBIA GENERATING STATION, DOCKET NO. $0-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO REUEF REQUESTS FOR THE COLUMBIA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM

==References:==
: 1) Letter, G02-14-049, dated April 2, 2014, A. L. Javorlk (Energy Northwest) to NRC, "Relief Requests for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing Program"
: 2) Email, dated July 2, 2014, Andrea George (NRC) to Lisa Williams (Energy Northwest), "Requests for Additional Information - Relief Requests Associated with the Fourth Ten-Year Interval Inservice Testing Program - Columbia Generating Station (TAC NOS. MF3851, MF3854, MF3856, MF3857)"

==Dear Sir or Madam:==

By Reference 1, Energy Northwest submitted for approval the relief requests for the Fourth Ten-Year Inservice Testing Program.
Via Reference 2, the Nuclear Regulatory Commission (NRC) submitted Requests for Additional Information (RAls) to Energy Northwest for relief requests RP01, RP02, RP03, and RP06. Enclosure I provides the requested information. Enclosures 2 and 3 provide clarification revisions to RP02 and RP03 respectively.
This letter and its enclosures contain no regulatory commitments. Ifthere are any questions or if additional information is needed, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REOUESTS FOR THE COLUMBIA GENERATINM STATION FOURTH TEN-YEAR INTERVAL INSERViCE TESTIN PROGRAM Page2o2 o.f I declare         tndpalyot peury thatt" foregoing is true and correct. Executed this Respe-tfutly, Vie President, Engineering

==Enclosures:==
: 1) Response to RAts
: 2) RP02 Revision 1
: 3) RPO3 Revision I cc: NRC RVV Regional Administrator NRC NRR Project Manager NRC Senior Resident tnspector,988C MJones - SPA/1 399 (email)
JO Luce - ESFEC RR Cowley - WDOH (email)

RESPONSE TO REQUEST FOR AUC!flOMAL INFOIMMATION RELATED TO AEUEF REQUESTS FOR THE              U        GENERATlNG STATION FOURTH TEN-YEAR INTERVAL INSERYICN TESTING PROGRAM ENCLOSURE I Page Iod 3 RESPONSE TO REQUEST FOR ADOmONAL INFORMATION (JIUM)
EPNBPRAI-RP-01 -1: Please provide the discharge pressures for standby service water pumps SW-P-1A and SW-P-1B, and standby service water, HPCS pump HPCS-P-2 from the inservice tests for the past year.
The following table contains the one year data requested for SWP-1 Aand SW-P-1 B from the inservice tests.
StMaby             WOW Pwwmp DfohW"g. Pu            Summe (IYR)
DATE        PRESURE SW-PI'A                        5/29/13     204.76        PSIG i WEjCIA                         M1013     204.83        PSIG
           $W-P-A                        W.l26/13     205.78        PS1 SW-P-IA                        1/14/14     210.24        PSIG SW-P-IA                        4/12/14     209.83        PSIG SW#P-IB                         6./713     211.00        P8sI SW-P-1S                        8/18113     210.50        PSIG SW-P-IS                        10/6/13     211.50        P810 sW-P-1B                       10/12/13     213.60        PSIG SW-P-lB                        12/6/13     212.80        P1s0 SW-P-1S                        1/31/14     212.00        PSIG SW-P-1B                        4/27/14     212.00        PSIG

RESPONSE TO REQUEST FOR ADO WONAL INFORMATION RELATED TO REAEF REQUESTS FOR THE COLUMIA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE I Page 2 of 3 The following table contains the one year data requested for HPCS-P-2 from the inservice tests.
Stanb SwrvW Wwr Pump. Olcharp Pinse Summar DATE          PRESSURE 4PCP            .     . 4/20/13          80              PSIG HPCS-P.2                      6/9/13          80              PSIG NPCS'"                       6/17/13          60              PSG RPCS.6.0          '          7/12113          60              PSIG HPC$4                        10/5/13          58              PSIG NPCSP*4                     12/28/13          60              PSIG
              ,PCSP4                    3/18/14          59              PSIG EPNB-RAI-RP-02-1: It appears that this alternative request is requesting the use of parts of Code Case OMN-16 for the standby service water pumps and the standby service water, HPCS pump. Please confirm if this Is correct. If this is correct, please explain how your proposed testing differs from Code Case OMN-16 and provide justification for the differences.
The intent of Columbia Generating Station (Columbia) relief request RPO2 is to follow all of the requirements of OM Code Case OMN-1 6. RP02 has been revised to clarify all the requirements specified in OM Code Case OMN-16 will be followed. Enclosure 2 contains Revision I to RP02.
NffRC booem EPNB-RAI-RP-03-1: Relief request RP-03 lists several elements that are used to develop and Implement the provided reference pump curves. Relief request RP-03

STO            REQUEST FOR ADCOONAL INFORMATION RELATED TO RELIEF REOUESTI FOR THE COLUMBIA GENERATIPG STATION FOUNT" TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE I Page 3 of 3 states that these elements "follow the guidance of Code Case OMN-16." Please clarify what portions of ASME OM Code Case OMN-16 are being followed, Also, please explain any deviations from ASME OM Code Case OMN-16 that are being requesled in relief request RR.03.
Intent of Columbia relief request AP03 is to follow all the guidance of Code Case OMN-16 for testing of pumps LPCS-P-I, RHR-P-2A/WC, HPCS-P-1 and RCIC-P-1. RP03 has been revised to clarify that all requirements of Code Case OMN-16 will be used for testing of these pumps. Enclosure 3 contains Revision I to RP03.
EPNbRAI-:P-06-1: Alternative request RP-0 provides a table that compares the test flow rate to the design basis accident flow rate. Please provide a table that compares test differential pressure and design basis differential pressure for the pumps for which an alternative Is requested.
Enwmv         mlhetIllmn The intent of prvding the table comparing test flow rates to the design basis accident flow rates Isto satisfy requirements of Note 1 under Division 1, Mandatory Appendix V, Pump Periodic Verification Test Program, of the ASME OM Code 2012 Edition. Per note 1, "TheOwner is not required to perform a pump periodic verification test, Ifthe design basis accident flow rate inthe Owners safety analysis is bounded by the comprehensive pump test or Group Ateat." Since Columbia's Design Basis Accident flow rates are bounded by the test flow rates, Columbia Isnot required to perform pump periodic verification tests per Note I in Appendix V.

AEtPONU TO AQUEST FOR ADOfONAL NFOKMATION                             "ELATEDTO RELEF REQUESTS FOR THE COLUMBIA GENERATING STATION FOURTH TEN-YEAR ITERVAL INSERVMCE TESTING PROGRAM ENOLOSURE 2 Page I of 6 RPO2 Rewlef    -
In Acrdwdmoe wkt 10 CPA OAW#Pb(N           I)
                               - Insevice Testing Mpractcality -
code     Pu    .. P& D .                   System(s)
Cumss    Group          Number      ___.               ....
8W-P-1A            3        A        M524, SH i           Standby Service Water SW-P-1B            3        A         M524, SH 2          Standby Service Water HPCS-P-2            3        A         M824, SH 1          Standby Service Water, HPCS high" 9M9EdM" The 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code.
Subeto ITB-22(b MnW iU-                        . The resftance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to the reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rats determined and compared to the reference flow rate value.
Relief is required for Group Aand Comprehensive Pump Tests.
The establishment of specific reference values is Impractical for these vertical line shaft centrifugal pumps.

RESPONSE TO REQUEST FOR ADDmONAL INFORMATION RELATED TO RELIEF REQUEST$ FOR THE COLUMBIA GENERATING STATION FOURTM TENYEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE 2 Page 2 of 6 I     Service Water systems are designed such that the total pump flow cannot be adjusted to one finite value for the purpose of testing without adversely affecting the system flow balance and Technical Specification operability requirements. Thus, these pumps must be tested In a manner that the Service Water loop remains properly flow balanced during and after the testing and each supplied load remains fully operable to maintain the required level of plant safety.
: 2. The Service Water system loops are not designed with a full flow test line with a single throttle valve. Thus the flow cannot be throttled to a fixed reference value. Total pump flow rate can only be measured using the total system flow Indication installed on the common return header. Although there are valves in the common return line that are used for throttling total system flow during pre-service testing, use of these valves is impractical for regular testing due to the potential effect on the flow balance for the safety related loads. Each main loop of service water supplies 17-18 safety related loads, all piped in parallel with each other. The HPCS-P-2 pump loop supplies four loads, each in parallel. Each pump is independent from the others (i.e., no loads are common between the pumps). Each load Is throttled to a calculation and surveillance required flow range which must be satisfied for the loads to be operable. All loads are aligned in parallel, and all receive service water flow when the associated service water pump Is running, regardless of whether the served component Itself is in service.
During power operation, all loops (subsystems) of service water are required to be operable per Technical Specifications. A loop of service water cannot be taken out of service for testing without entering an Action Statement for a Umiting Condition for Operation (LCO) per Technical Specification 3.7.1.
: 3. Each loop of Service Water is flow balanced annually to ensure that all loads are adequately supplied. A flow range is specified for each load. Once properly flow balanced, very little flow adjustment can be made for any one particular load without adversely impacting the operability of the remaining loads (increasing flow for one load reduces flow for all the others). Each time the system is flow balanced, proper individual component flows are produced, but this in turn does not necessarily result in one specific value for total flow. Because each load has an acceptable flow range, overall system full flow (the sum of the individual loads) also has a range. Total system flow can conceivably be Inthe ranges of approximately 9,200 - 10,200 gallons per minute (gpm) for SW-P-1A and SW-P-1B pumps and approximately 1,112 - 1,203

REPONSE TO REQUEST FOR A00lONAL INFORMATION AELATED TO REUIEF REQUESTS FOR THE COLUMBIA GENERATNG STATION FOURTH TPN-YEAR INTERVAL          INTERVICE TESTING PROGRAM ENCLOSURE 2 Page 3of6 gpm for HPCS-P-2 pump. Consequently, the requirement to quarterly adjust service water loop flow to one specific flow value for the performance of inservice testing conflicts with system design and component operability requirements (i.e., flow balance) as required by Technical Specification.
As discussed above, it is impractical to return to a specific value of flow rate or discharge pressure for testing of these pumps. As stated In NUREG-1482, Rev 2 Section 5.2, some system designs do not allow for testing at a single reference point or a set of reference points. In such cases, it may be necessary to plot pump curves to use as the basis for variable reference points. Code Case OMN-16, "Use of a Pump Curves for Testing," Is included in draft Revision 1 of Regulatory Guide (RG) 1.192, "Operations and Maintenance Code Case Acceptability, ASME OM Code." Flow rate and discharge pressure are measured during inservice testing and compared to an established reference curie. Discharge pressure instead of differential pressure is used to determine pump operational readiness as described in Relief Request RP01. All requirements specified in Code Case OMN-16 will be followed in developing and implementing the reference pump curves. The following information is provided for existing pump curves developed during the third ten year test interval.
: 1.      SW-P-1A and SW-P-1B were replaced with new pumps In2005 and HPCS-P-2 was replaced in 2008. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs. discharge pressure) was established for all three pumps using the preservice test data.
: 2.      Pump curves are based on five or more test points beyond the flat portion of the curve (between 6000 gpm and 10200 gpm for SW-P-1A and 18 pumps and between 650 and 1200 gpm for HPCS-P-2 pump). The pumps are being tested near full design flow rate.
: 3.      Temporary test gauges (t 0.5% full scale accuracy) were installed to take discharge pressure test data in addition to plant installed gauges, and Transient Data Acquisition System (TOAS). TOAS data averages 100 readings with a reading taken each second.
All Instruments used either met or exceeded the Code required accuracy for Group A and comprehensive pump test.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUESTS FOR THE COUMSA GENERATING STATION FOURTH TENYEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE S Page 4 of 6
: 4. The reference pump curves are based on flow rate vs. discharge pressure.
Acceptance criteria curves are based on differential pressure limits given in Table ISTB-5121-1 for applicable test type. Setting the Code Acceptance Criteria on discharge pressure using differential limits is slightly more conservative for these pump installations with suction lift (Relief Request RP01). See the attached sample SW-P-IA pump Acceptance Criteria sheet for Group A test Area 1-2-5.6 is the acceptable range for pump performance. Area 3-4-5-6 defines the Alert Range, and the area outside 1-2.3-4 defines the required Action Range.
S. Similar reference curves are used for comprehensive pump tests using the applicable acceptance criteria and instrument accuracy and range requirements.
: 6. Only a small portion of the established reference curve is being used to bind the flow rate variance due to flow balancing of various system loads. See the attached sample SW-P-1 A pump Acceptance Criteria sheet for Group A test.
: 7. A single reference value shall be assigned for each vibration measurement location.
The selected reference value shall be at the minimum data over the narrow range of pump curves being used as required by Code Case OMN-16.
: 8. When the repair, replacement, or routine servicing of a pump may have affected a reference curve, a new reference curve shall be determined, or the existing reference curve reconfirmed, in accordance with pars. 1643310 of Code Case OMN-16.
: 9. If it is necessary or desirable, for some reason other than that stated in para. 16-3310 of Code Case OMN-16, to extend the current pump curve or establish an additional reference curve, the new curve(s) must be determined in accordance with para. 16-3320 of Code Case OMN-16.
The design of the Columbia. Generating Station Service Water system and the Technical Specification requirements make it Impractical to adjust system flow to a fixed reference value for inservice testing without adversely affecting the system flow balance and Technical Specification operability requirements. The proposed alternate testing using a reference pump curve for each pump provides adequate assurance and accuracy in monitoring pump

RESPONSE TO REOUEST FOR AO0111ONAL INFORMATION RELATED TO RELIEF REQUESTS FOR THE COLUMBIA GENERATING STATION FOURTH TENYEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE 2 Page 5 of 6 condition to assess pump operational readiness and shall adequately detect pump degradation. Alternate testing will have no adverse Impact on plant and public safety.
Fourth 10 year Interval.
Similar relief was granted for the third 10 year interval. NRC approval was documented in a fetter dated May 15, 2007 (ADAMS Accession Number ML071010344, TAC No. M03540) for Relel Request No. RP03.

RESPONsE TO REQUEST FOR AcD6ONAL INFORMATION RELATED TO RELIEF REQUESTS FOR THE COLUMUA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTM1N                  PROGRAM ENCLOSURE 2 Page 6 of 6 SAMpLE DATA SEET - Grouo A Test SW -           r lfEAb&E!QRrEA 240 235 230 IS 220 II 215 210 205 I
195 190 185 to6    +0 (44.*4.0i44 9.330      9,40    9%M30     9,6S0      9,730 9830   9930    10,030    10,130      10230 nLOW- (l6P ALERT RANGE P,Are Inskt 3.4-"-              ACTION RANGE . Area Outaide 1-2-3-4

RESPONSE TO REQUEST FOR AVOMONAL lNPORMATON RELATED TO REKIEF REQUESTS FOR THE COLUMSIA GENWIRTINO STAION FOURTH TEN-YVEA MNTERVALNInN"EI TESTINM PROGRAM ENCLOSURES Page Iof 8 RP03 Revlelon !1 InAoordsnoe with 10 CP,n        Jo, uf)(OII
                                   - Inervice Testing Impracticaglty mPUMP     Pu,,,*    *    *
* Group        P&lO Qwg Number           System($)
Sym)
LPCS-P-I              2                8            M520             Low Pressure Core Spray RHR-P-2A              2                A            M521, SH I RHR-P-28              2                A            M521, SH 2       Resdual Hot Removal RHR-.2C LI__liI_..        2                 A            M521, SHJLII
                                                          . 3 HPCS1-I               2               Is           ;MS20            IHigh Pressure Core Spray HRClC-P..l            2               IS             WIB59           Rsector Core Isolation Coln
         -m"ota-twdAM The 2004 Edition and the 2005 and 2006 Addenda of th ASME OM Code.
hNAW gaoe AMMIrOM QXi#-1 (CQedn         ALuPumD:
.QMVR 1.Te         %ust           TB-5122(al, hB-122(h) and ISTM-122W). The pump shall be operated at a speed adjusted to the reference point (+/- 1%) for variable speed drives. The differential pressure or flow rate shall be determined and compared to its reference value.
System resistance may be varied as necessay to achieve the reference point.
CgM hgeM             Tes: Subsection ISTBU!-2361          nd ISTB-5123f.      The pump shall be operated at a speed adjusted to the reference point (+/- 1%) for variable speed drives. The resistance of the system shal be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to ft reference value.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUESTS FOR TWE COLUMSIA GENERATING STATION FOURTH TENYEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE 3 Page 2 of 8 Alternatively, the flow rate shall be vaded until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value.
Other Pumos taVerlicl line Shaft Centrifu&al PumWs.:
Gouo B Test for LPCS-p-.! and HPCSP-:T                                                    ( The differential pressure or flow rate shall be determined and compared to its reference value.
System resistance may be varied as necessary to achieve the reference point.
Guo A Test for RHR-P2A. 2BAND 2C nd ComoMhensiveTest for all -Unos excet RCI1QP,:                 IM.M2(bl and IlB-22(b) The resistance of the system shall
                                                           .ubseion be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to Its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value.
The establishment of specific reference values Is impractical for these pumps.
Reference values are defined as one or more fixed sets of values of quantities as measured or observed when the equipment is known to be operating acceptably. All subsequent test results are to be compared to these reference values. Based on operating experience, flow rate (independent variable during inservice testing) for these pumps cannot be readily duplicated with the existing flow control systems. Flow control for these systems can only be accomplished through the operation of relatively large motor operated globe valves as throttling valves. Because these valves are not equipped with position indicators which reflect percent open, the operator must repeatedly jog the motor operator to try to make even minor adjustments inflow rate. These efforts, to exactly duplicate the reference value, would require excessive valve manipulation which could ultimately result In damage to valves or motor operators.

RESPONSE TO REQUEST FOR AD)ITIONAL INFORMATION RELATED TO RELIEF REQUESTS FOR THE COLUUmA GENERATING STATION FOURTH TEN-YEAR INTERVAL INDERVICE TESTING PROGRAM ENCLOSURE 3 Page 3 of 8 As discussed above, it Is Impractical to return to a specific value of flow rate, or differential pressure for testing of these pumps. As stated in NUREG-1482, Rev. 2 Section 5.2, some system designs do not allow for testing at a single reference point or a set of reference points. In such cases, it may be necessary to plot pump curves to use as the basis for variable reference points. Code Case OMNI1-,          Vse of a Pump Curves for Testing," Is included in draft Revision 1 of RG 1.192, "Operations and Maintenance Code Case Acceptability, ASME OM Code."
Since the independent reference variable (flow rate) for these pumps is Impractical to adjust to a fixed reference value and requires excessive valve manipulation, the maximum variance shall be limited to
* 2% of the reference value. Thus, flow rate shall be adjusted to be within
* 2% of the reference flow rate and the corresponding differential pressure shall be measured and compared to the reference differential pressure value determined from the pump reference curve established for this narrow range of flow rate. Slope of the pump reference curve is not flat even over this narrow range of flow rate. Assuming the flow rate to be fixed over this narrow range can result In additional error in calculating the deviation between the measured and reference differential pressure and at times this deviation can be non.
conservative. Since the dependent variable (differential pressure) can be assumed to vary linearly with flow rate In this narrow range, establishing multiple reference points in this narrow range is similar to establishing a reference pump curve representing multiple reference points. This assumption of linearity between differential pressure and flow rate is supported by the manufacturer pump curves In the stable design flow rate region.
The following elements are used in developing and implementing the mfernce pump curves, These elements follow all the requirements of Code Case OMN-16.
I. RHR-P-28 was replaced with a new pump in 2013. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs.
differential pressure) was established for this pump using the preservice test data. A simliar reference pump curve (flow rate vs differential pressure) has been established for RHR-P-2A and RHR-P-2C pumps from data taken on these pumps when they were known to be operating acceptably. These pump curves represent pump performance almost identical to manufacturers test data.

RESPONSE TO REQUEST FOR ADOIIIONAL 0IFORMATiON RELATED TO RELIEF REQUESTS FOR THE COLUMA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE 3 Page 4 of 8
: 2. For RClC-P-1, a variable speed drive pump, flow rate Is set within
* 2% of the reference flow rate and the reference curve is based on speed with acceptance criteria based on differential pressure. This Is done because of the impracticality of setting speed to a specific reference value to achieve the desired flow rate and pump discharge pressure. See the attached sample RCIC-P-1 pump Acceptance Criteria sheet for Group B test. Additionally, evaluation of the manufacturer pump data, preoperational and special test data used to establish the pump reference curve indicates insignificant change Indifferential pressure with small variation in flow rate.
: 3. HPCS-P-1 was replaced with a new pump In 2007. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs.
differential pressure) was established for this pump using the preservice test data.
: 4. For LPCS-P-1 pump, the reference pump curve is based on preoperational testing using 5 or more test points beyond the flat portion of the curve.
S. Residual Heat Removal (AHR), High Pressure Core Spray (HPCS) and Reactor Core Isolation Cooling (RCIC) pump curves are based on five or more test points beyond the flat portion of the curve. These ECCS pumps have minimum flow rate requirements specified In Technical Specifications and are being tested near these flow rates.
: 6. Temporary test gauges (* 0.5% full scale accuracy) were Installed to take suction and discharge pressure test data in addition to plant Installed gauges and Transient Data Acquisition System (TOAS). TDAS data averages 100 readings with the readings taken at one second intervals. All instruments used either met or exceeded the Code required accuracy for applicable Group A, Group B and comprehensive pump test.
: 7. Review of the pump hydraulic data trend plots Indicates close correlation with the established pump reference curves, thus further validating the accuracy and adequacy of the pump curves to assess pumps operational readiness.
: 8. Acceptance criteria curves are based on differential pressure limits given in applicable Table ISTB-51 21-1 or Table ISTB-5221 -1. See the attached sample RHR-P-2A pump Acceptance Criteria sheet for Group A test. Area 1-2-5-6 is the acceptable range for pump performance.

RESPONSE TO REQUEST FOR ADITnONAL INFORMATION RELATED TO RELIEF REQUESTS FOR THE COLUNSIA GENERATING STATION FOURTH TENYEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE $
Page 5 of8 Area 3-456.6 defines the Alert Range and the area outside 1-2-3-4 defines the required Action Range. A similar sample RCIC-P-1 pump Acceptance Criteria sheet for Group B test is also attached.
: 9. Similar reference curves will be used for comprehensive pump tests using the applicable acceptance criteria and instrument accuracy and range requirements.
: 10. Only a small portion of the established reference curve Is being used to accommodate flow rate variance. See the attached sample pump Acceptance Criteria sheets.
: 11. A single reference value shall be assigned for each vibration measurement location.
The selected reference value shal be at the minimum data over the narrow range of pump curves being used as required by Code Case OMN-16.
12.When the repair, replacement, or routine servicing of a pump may have affected a reference curve, a new reference curve shall be determined, or the existing reference curve reconfirmed, in accordance with para. 16-3310 of Code Case OMN-16.
13.1f it is neceary or desirable, for some reason other than that stated in pare. 16-3310 of Code Case OMN-16, to extend the current pump curve or establish an additional reference curve, the new curve(s) must be determined In accordance with pare. 16-3320 of Code Case OMN-16.
Walft*      Imeam Due to Impracticality of adjusting independent variables (flow rate, and speed for variable drive RCIC pump) to a fixed reference value for Inservice testing without system modifications, alternate testing to vary the variables over a very narrow range (up to
* 2% of reference values) and using pump reference curves for this narrow range is proposed.
Alternate testing using a reference pump curve for each pump provides adequate assurance and accuracy In monitoring pump condition to assess pump operational readiness and will adequately detect pump degradation. Alternate testing will have no adverse impact on plant and public safety.
Fourth 10 year interval.

RESPONSE TO REQUEST FOR ADoDIrONAL IORMATlON RELATED TO REUEF REQUESTS FOR THE COWUMIA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM ENCL.OSURE 3 Page 6 of 8 Similar relief was granted for the third 10 year interval. NRC approval was documented In a letter dated March 23, 2007 (ADAMS Accession Number ML070600111, TAC No. MD3637) for Relef Request No. RP04.

RESPONSE 10 REQETOS FOR ADOflIAw4                           0iFORMA11ON R*ATED TO RELIEF REQUESTS FOR THE COLUSIA GIENERATING STATION FOURTH T"N-&AR
*INERVALINSERWVCE TESTING PVMGRM ENCLOSMUE S Page 7 of 8 SAMPLE O   DATA SHEET Grouo ATest MUM&6QQgMMG MU 131 130 186 129 322 12O 149 S  123 It' I
U4 Ut6 114 113 II ii, 112 III 133 110 INl 107 106 104 103 1W2 tmmo 100 99                                                                                      6 93 97 9'
9,                  o*"N  -     -fN mit  Ig    NplolN         N  94  4 4   --- -----      1 74900 7       7         7540 "M 7M    755M 756I0     M  75I    790W   M767620 7630 7640 76M0 INDICATED FMW - GPM ALM RANN: Am tt*& 3*04                          AMON OtANSE x Am Out"  1-2-3-4

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO RELIEF REQUESTS FOR THE COLUMBIA GENERATING SATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM ENCLOSURE 3 Page 8 of 8 SAMPLE DATA SHEET - GrouM                BTest RCICV=1 ACCEPTANCE CRITERIA
    -s lus
   'im 121,5
    %u.s 107s 4420 44" 44S0    4470     44"0        4w20        4530  4500 476 4W90 PumfMPTRINE WEEP(RM)
ACTON RANGE a Area Oulsde 1-2-3-4}}