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| | number = ML12314A288 | | | number = ML12314A288 |
| | issue date = 12/11/2012 | | | issue date = 12/11/2012 |
| | title = H. B. Robinson Steam Electric Plant, Unit 2 - Relief Request-2 for the Fifth 10-Year Interval Inservice Testing Program Plan (TAC No. ME8259) | | | title = Relief Request-2 for the Fifth 10-Year Interval Inservice Testing Program Plan |
| | author name = Quichocho J F | | | author name = Quichocho J |
| | author affiliation = NRC/NRR/DORL/LPLII-2 | | | author affiliation = NRC/NRR/DORL/LPLII-2 |
| | addressee name = Gideon W R | | | addressee name = Gideon W |
| | addressee affiliation = Carolina Power & Light Co | | | addressee affiliation = Carolina Power & Light Co |
| | docket = 05000261 | | | docket = 05000261 |
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| | page count = 8 | | | page count = 8 |
| | project = TAC:ME8259 | | | project = TAC:ME8259 |
| | stage = Approval | | | stage = Other |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 December 11, 2012 Mr. William R. Gideon, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Hartsville, South Carolina 29550 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 -RELIEF REQUEST-2 FOR THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN (TAC NO. ME8259) | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 11, 2012 Mr. William R. Gideon, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Hartsville, South Carolina 29550 SUB~IECT: H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - RELIEF REQUEST-2 FOR THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN (TAC NO. ME8259) |
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| ==Dear Mr. Gideon:== | | ==Dear Mr. Gideon:== |
| By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16,2012 (Agencywide Documents Access and Management System Accession No. ML 12086A067), as supplemented by letters dated May 10, 2012 (No. ML 12138A041), June 4,2012 (No. ML 12165A261) and September 20,2012 (No. ML 12278A124), Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).
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| The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of the safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety. The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1 , the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21,2012, and ends on February 18, 2022. As discussed with the licensee on July 9,2012, the NRC staff is concerned with the amount of information provided in the submittal that required revision after review by and questions from the NRC staff, and your request for multiple concurrent reviews with a short review timeframe.
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| The uncharacteristic inattention to detail observed in the submittal resulted in the need to focus limited resources to address mostly administrative issues. Additional attention to ensure a high quality submittal would allow for a more efficient use of review resources, and better ability of the NRC staff to accommodate requests for a shortened review timeframe.
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| : w. Gideon -The details of the NRC staff review are included in the enclosed SE. Section 50.55a(f) of 10 CFR, "Inservice Testing Requirements," requires in part, that the 1ST of certain ASME OM Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements.
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| Therefore, the licensee's proposed alternative for 1ST-RR-2 is authorized for the fifth 10-year 1ST interval at HBRSEP, which started on July 21, 2012, and ends on February 18, 2022. Sincerely, e F. Quic ocho, Acting Chief lant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.
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| Safety cc w/encl: Distribution via
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| ",I>." REG U{ UNITED STATES .;:,v" "'I;, ",... , NUCLEAR REGULATORY COMMISSION t:i c-WASHINGTON, D.C. 20555-0001 o:( 0 ... '" r:;\"';. §i+.., ...0 ****"" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN RELIEF REQUEST-2 CAROLINA POWER & LIGHT COMPANY H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. 50-261
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| ==1.0 INTRODUCTION==
| | By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16,2012 (Agencywide Documents Access and Management System Accession No. ML12086A067), as supplemented by letters dated May 10, 2012 (No. ML12138A041), June 4,2012 (No. ML12165A261) and September 20,2012 (No. ML12278A124), Carolina Power & Light Company (the licensee), |
| | doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP). |
| | The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of the safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety. |
| | The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1, the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21,2012, and ends on February 18, 2022. |
| | As discussed with the licensee on July 9,2012, the NRC staff is concerned with the amount of information provided in the submittal that required revision after review by and questions from the NRC staff, and your request for multiple concurrent reviews with a short review timeframe. |
| | The uncharacteristic inattention to detail observed in the submittal resulted in the need to focus limited resources to address mostly administrative issues. Additional attention to ensure a high quality submittal would allow for a more efficient use of review resources, and better ability of the NRC staff to accommodate requests for a shortened review timeframe. |
| | : w. Gideon - 2 The details of the NRC staff review are included in the enclosed SE. Section 50.55a(f) of 10 CFR, "Inservice Testing Requirements," requires in part, that the 1ST of certain ASME OM Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements. |
| | Therefore, the licensee's proposed alternative for 1ST-RR-2 is authorized for the fifth 10-year 1ST interval at HBRSEP, which started on July 21, 2012, and ends on February 18, 2022. |
| | Sincerely, e F. Quic ocho, Acting Chief lant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261 |
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| By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12086A067), as supplemented by letters dated May 10, 2012 (No. ML 12138A041), June 4,2012 (No. ML 12165A261) and September 20,2012 (No. ML 12278A124), Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).
| | ==Enclosure:== |
| The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of this safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety. The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1 , the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21, 2012, and ends on February 18, 2022.
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| ==2.0 REGULATORY EVALUATION==
| | Safety Evaluation cc w/encl: Distribution via Listserv |
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| Section 50.55a(f) of 10 CFR, "Inservice Testing ReqUirements," requires in part, that the 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety. Paragraph 50.55a(a)(3) of 10 CFR states, in part, that alternatives to the requirements of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of
| | ",I>." REG U{ UNITED STATES |
| -2 quality and safety or if (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The licensee requested authorization in IST-RR-2 of an alternative to the requirements of the ASME OM Code pursuant to 10 CFR 50.55a(a)(3)(i). | | .;:,v" "'I;, |
| The NRC staff has previously authorized IST-RR-2 for the third 1ST 1 O-year interval on July 15, 1994 (ADAMS Legacy Library No. 9407250145) and for the fourth 1ST 10-year interval on June 27,2002 (ADAMS Accession No. ML031780245) for HBRSEP. 3.0 TECHNICAL EVALUATION The NRC staff has evaluated the information provided by the licensee in support of IST-RR-2 for relief from, and alternative to, the ASME OM Code requirements and the bases for disposition are documented below. 3.1 IST-RR-2 3.1.1 ASME Code Requirements The applicable ASME OM Code edition and addenda for HBRSEP is the 2004 Edition through the 2006 Addenda. Table ISTB-351 0-1, "Required Instrument Accuracy,>>
| | ",... , O~ NUCLEAR REGULATORY COMMISSION t:i c- WASHINGTON, D.C. 20555-0001 0 |
| requires that flow rate instrumentation used for Group A, Group B, comprehensive, and preservice tests have an accuracy of plus or minus 2 percent. 3.1.2 Component for which Relief is Requested The licensee requested to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the following pumps: Table 3-1: Components for which Relief is Requested Pump Description Category Type CCW-PMP-A CCW (Component Cooling Water) Pump A Group A Horizontal Centrifugal CCW-PMP-B CCW Pump B Group A Horizontal Centrifugal CCW-PMP-C CCWPumpC Group A Horizontal Centrifugal SI-PMP-A Safety Injection (SI) Pump A Group B Horizontal Centrifugal SI-PMP-B SI Pump B Group B Horizontal Centrifugal SI-PMP-C SI PumpC Group B Horizontal Centrifugal SW-PMP-A SW (Service Water) Pump A Group A Vertical Line Shaft SW-PMP-B SW Pump B Group A Vertical Line Shaft 3.1.3 Licensee's Basis for Relief Request The original plant design of HBRSEP Unit 2 occurred prior to the issuance of 1ST requirements, and the plant design did not include flow rate measurement instrumentation that met subsequent ASME OM Code requirements.
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| Since that time, flow instrumentation that meets
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| -ASME OM Code requirements has been installed.
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| However, the pumps listed in Table 3-1 have flow instrumentation that may be difficult to replace with certified instruments within the allotted Technical Specification (TS) limiting condition for operation (LCO). In order to calibrate the flow instruments, a reference standard must be utilized and a calibration certificate obtained.
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| HBRSEP is not equipped to perform this type of calibration and the instruments are sent to a certified vendor. The vendor is no longer capable of calibrating these instruments without the use of a test facility, which must be reserved in advance prior to use. The time it takes to complete the calibration process varies from 2 to 6 weeks. The TS LCO time period would not be sufficient to facilitate diagnostics, instrument transport, repairs, calibration, reinstallation, and certification upon discovery that a calibrated instrument is found to be deficient.
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| Also, for the SW and CCW pumps, this turnaround time could force the licensee to use noncalibrated flow instruments in consecutive quarterly tests. The licensee is attempting to replace the ultrasonic flow meters with permanent indicators that require less user interface.
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| However, two flow instrument installations are not functioning properly and will require additional modifications.
| | ****"" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN RELIEF REQUEST-2 CAROLINA POWER & LIGHT COMPANY H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. 50-261 |
| One permanent flow meter used to support the CCW pump 1ST is working properly, however, the licensee feels it would be prudent to monitor this flow meter installation to ensure that long term performance continues to be accurate and repeatable.
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| If the new flow meter produces erratic results, an ultrasonic flow meter could be used in accordance with HBRSEP procedures to obtain accurate flow measurements in order to assess pump operational readiness.
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| ====3.1.4 Licensee's==== | | ==1.0 INTRODUCTION== |
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| Proposed Alternative Examination In the unlikely event that a flow rate measurement device for the pumps listed in Table 3-1 failed to operate properly and a calibrated flow rate instrument, composed of a meter and a set of transducers that have been previously paired during off-site calibration, is not available for replacement, an uncalibrated ultrasonic flow measurement device, composed of a meter and a set of transducers that have not been previously paired during off-site calibration, can be installed in accordance with specific instructions to ensure proper operation and provide accurate measurement of flow rate. Generally, spare instruments are maintained and certified, but may not be available, or rendered inoperable.
| | By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12086A067), as supplemented by letters dated May 10, 2012 (No. ML12138A041), June 4,2012 (No. |
| When calibrated flow instruments are not available, backup uncalibrated flow measurement instruments can be installed and verified in accordance with a detailed procedure in order to provide a high level of assurance relative to the proper operation of the flow rate device. Based on past experience, unsatisfactory pump performance can be determined through the use of noncalibrated ultrasonic flow rate instruments when the instruments are properly installed and verified in accordance with site specific procedures.
| | ML12165A261) and September 20,2012 (No. ML12278A124), Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP). |
| An acceptable level of quality and safety is maintained and the use of this alternative would be prudent in the unlikely event of this emergent condition.
| | The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of this safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety. |
| The licensee has used noncalibrated flow measurement instruments on occasion during the HBRSEP fourth 10-year 1ST program interval.
| | The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1, the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21, 2012, and ends on February 18, 2022. |
| For SW pump A, they were used two times between July 2009 and January 2010; for SW pump B, they were used five times bewteen July 2009 and January 2010; for SI pump C, they were used once. Table 3-2 shows the approximate Acceptable Range margin currently available and the flow reference value for each pump.
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| Table 3-2 Pump Approximate Acceptable Range Margin, gallons per minute (gpm) Reference Flow, gpm CCW-PMP-A 2400 5300 CCW-PMP-B 2400 5250 jCW-PMP-C 1200 5440 I-PMP-A 45 335 SI-PMP-B 55 340 SI-PMP-C 60 320 SW-PMP-A 450 7260 SW-PMP-B 650 6880 This alternative is not intended to be used repeatedly as a testing convenience.
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| The licensee will make efforts to obtain an acceptable calibrated flow instrument for use during the next pump test. Documentation of the flow measurements taken will be available for an onsite NRC review. 3.1.5 NRC Staff's Evaluation The licensee has proposed an alternative in lieu of the requirements found in the 2004 Edition through 2006 Addenda of the ASME OM Code, Table ISTB-3510-1. | |
| Specifically, the licensee proposed to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the pumps listed in Table 3-1. Table ISTB-3510-1 of the OM Code requires that flow rate instruments have an accuracy of plus or minus 2 percent for Group A, Group B, and comprehensive tests. The licensee currently uses externally mounted ultrasonic flow meters to measure flow rate during 1ST for the pumps listed in Table 3-1. If one of these flow meters is out of calibration, the licensee must send it to a vendor for calibration, and the process can take 2 to 6 weeks to complete, which is longer than the TS LCO. The NRC staff previously authorized this alternative for the HBRSEP Unit 2 third 1ST 10-year interval on July 15, 1994, and fourth 1ST 10-year interval on June 26, 2003. The licensee stated that in the fourth 10-year 1ST interval, noncalibrated flow instrumentation has been used two times between July 2009 and January 2010 for SW pump A. five times between July 2009 and January 2010 for SW pump B, and once for SI pump C. During this time, it became evident to the licensee that the permanent meter for SW pumps A and B was erratic. To eliminate this issue, the licensee purchased and calibrated two new ultrasonic flow meters, and the vendor was brought in to help install and test the new devices. Also, SW pump B was being tested at an increased frequency (every 45 days) during this interim period. In Table 3-2, the licensee provided the Acceptable Range flow rate margin for each pump, based on the most recent pump test results. This data shows that the flow rate margin is sufficient so that the use of a noncalibrated instrument would not mask pump degradation that would require a pump to enter the Alert Range or Required Action Range. | |
| -The licensee is also attempting to replace the calibrated ultrasonic flow meters with permanent indicators that require less user interface. | |
| The licensee will not use noncalibrated flow measurement instruments as a testing convenience.
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| If usage of noncalibrated instruments is required, the licensee will make an effort to obtain a calibrated flow measurement instrument for subsequent tests. The licensee's alternative request was based on applying the rule of 10 CFR 50.55a(a)(3)(i), "The proposed alternatives would provide an acceptable level of quality and safety." However, the alternative method described in IST-RR2 is more in line with 10 CFR 50.55a(a)(3)(ii), "Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety." Therefore, the NRC finds that the proposed alternative provides reasonable assurance that the pumps listed in Table 3-1 are operationally ready.
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| ==4.0 CONCLUSION== | | ==2.0 REGULATORY EVALUATION== |
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| The NRC staff finds that the proposed alternative, described in alternative request IST-RR-2, provides reasonable assurance that the pumps listed in Table 3-1 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(a)(3)(ii), and is in compliance with the ASME OM Code's requirements.
| | Section 50.55a(f) of 10 CFR, "Inservice Testing ReqUirements," requires in part, that the 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. |
| All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests remain applicable.
| | In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety. Paragraph 50.55a(a)(3) of 10 CFR states, in part, that alternatives to the requirements of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of |
| Therefore, the NRC authorizes the alternative, described in IST-RR-2, for the HBRSEP, 10-year 1ST interval, which began on July 21,2012, and is currently scheduled to end on July 20, 2022. Principle Contributor:
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| Robert Wolfgang Date of issuance:
| | -2 quality and safety or if (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. |
| December 11, 2012 W. Gideon -The details of the NRC staff review are included in the enclosed SE. Section 50.55a(f) of 10 CFR, "Inservice Testing Requirements," requires in part, that the 1ST of certain ASME OM Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements.
| | The licensee requested authorization in IST-RR-2 of an alternative to the requirements of the ASME OM Code pursuant to 10 CFR 50.55a(a)(3)(i). The NRC staff has previously authorized IST-RR-2 for the third 1ST 1O-year interval on July 15, 1994 (ADAMS Legacy Library No. 9407250145) and for the fourth 1ST 10-year interval on June 27,2002 (ADAMS Accession No. ML031780245) for HBRSEP. |
| Therefore, the licensee's proposed alternative for IST-RR-2 is authorized for the fifth 10-year 1ST interval at HBRSEP, which started on July 21, 2012, and ends on February 18, 2022. Sincerely, IRA! Jessie F. Quichocho, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. | | |
| Safety cc w/encl: Distribution via Listserv DISTRIBUTION:
| | ==3.0 TECHNICAL EVALUATION== |
| PUBLIC LPL2-2 R/F RidsAcrsAcnw_MailCTR SDarbali, NRR RidsNrrDeEptb RidsRg n2 MailCenter RWolfgang, NRR RidsNrrDeEicb RidsNrrDorlLpl2-2 RidsNrrPMRobinson RidsNrrLABClayton RidsOgcRp SKennedy, EDO ADAMS Accession No.: ML 12314A288
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| * Via Memo OFFICE 2/PM LPL2-2/LA DE/EPTB/BC* | | The NRC staff has evaluated the information provided by the licensee in support of IST-RR-2 for relief from, and alternative to, the ASME OM Code requirements and the bases for disposition are documented below. |
| DE/EICB/BC* | | 3.1 IST-RR-2 3.1.1 ASME Code Requirements The applicable ASME OM Code edition and addenda for HBRSEP is the 2004 Edition through the 2006 Addenda. |
| NAME ABillochCol6n BClayton AMcMurtray | | Table ISTB-351 0-1, "Required Instrument Accuracy,>> requires that flow rate instrumentation used for Group A, Group B, comprehensive, and preservice tests have an accuracy of plus or minus 2 percent. |
| ..IThorp DATE 11/08112 11/14112 11/15/12 11/29/12 LPL2-2/BC ABiliochCol6n 12/11/12 OFFICIAL RECORD COPY}} | | 3.1.2 Component for which Relief is Requested The licensee requested to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the following pumps: |
| | Table 3-1: Components for which Relief is Requested Pump Description Category Type CCW-PMP-A CCW (Component Cooling Water) Pump A Group A Horizontal Centrifugal CCW-PMP-B CCW Pump B Group A Horizontal Centrifugal CCW-PMP-C CCWPumpC Group A Horizontal Centrifugal SI-PMP-A Safety Injection (SI) Pump A Group B Horizontal Centrifugal SI-PMP-B SI Pump B Group B Horizontal Centrifugal SI-PMP-C SI PumpC Group B Horizontal Centrifugal SW-PMP-A SW (Service Water) Pump A Group A Vertical Line Shaft SW-PMP-B SW Pump B Group A Vertical Line Shaft 3.1.3 Licensee's Basis for Relief Request The original plant design of HBRSEP Unit 2 occurred prior to the issuance of 1ST requirements, and the plant design did not include flow rate measurement instrumentation that met subsequent ASME OM Code requirements. Since that time, flow instrumentation that meets |
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| | - 3 ASME OM Code requirements has been installed. However, the pumps listed in Table 3-1 have flow instrumentation that may be difficult to replace with certified instruments within the allotted Technical Specification (TS) limiting condition for operation (LCO). |
| | In order to calibrate the flow instruments, a reference standard must be utilized and a calibration certificate obtained. HBRSEP is not equipped to perform this type of calibration and the instruments are sent to a certified vendor. The vendor is no longer capable of calibrating these instruments without the use of a test facility, which must be reserved in advance prior to use. |
| | The time it takes to complete the calibration process varies from 2 to 6 weeks. The TS LCO time period would not be sufficient to facilitate diagnostics, instrument transport, repairs, calibration, reinstallation, and certification upon discovery that a calibrated instrument is found to be deficient. Also, for the SW and CCW pumps, this turnaround time could force the licensee to use noncalibrated flow instruments in consecutive quarterly tests. |
| | The licensee is attempting to replace the ultrasonic flow meters with permanent indicators that require less user interface. However, two flow instrument installations are not functioning properly and will require additional modifications. One permanent flow meter used to support the CCW pump 1ST is working properly, however, the licensee feels it would be prudent to monitor this flow meter installation to ensure that long term performance continues to be accurate and repeatable. If the new flow meter produces erratic results, an ultrasonic flow meter could be used in accordance with HBRSEP procedures to obtain accurate flow measurements in order to assess pump operational readiness. |
| | 3.1.4 Licensee's Proposed Alternative Examination In the unlikely event that a flow rate measurement device for the pumps listed in Table 3-1 failed to operate properly and a calibrated flow rate instrument, composed of a meter and a set of transducers that have been previously paired during off-site calibration, is not available for replacement, an uncalibrated ultrasonic flow measurement device, composed of a meter and a set of transducers that have not been previously paired during off-site calibration, can be installed in accordance with specific instructions to ensure proper operation and provide accurate measurement of flow rate. Generally, spare instruments are maintained and certified, but may not be available, or rendered inoperable. When calibrated flow instruments are not available, backup uncalibrated flow measurement instruments can be installed and verified in accordance with a detailed procedure in order to provide a high level of assurance relative to the proper operation of the flow rate device. Based on past experience, unsatisfactory pump performance can be determined through the use of noncalibrated ultrasonic flow rate instruments when the instruments are properly installed and verified in accordance with site specific procedures. An acceptable level of quality and safety is maintained and the use of this alternative would be prudent in the unlikely event of this emergent condition. |
| | The licensee has used noncalibrated flow measurement instruments on occasion during the HBRSEP fourth 10-year 1ST program interval. For SW pump A, they were used two times between July 2009 and January 2010; for SW pump B, they were used five times bewteen July 2009 and January 2010; for SI pump C, they were used once. |
| | Table 3-2 shows the approximate Acceptable Range margin currently available and the flow reference value for each pump. |
| | |
| | -4 Table 3-2 Approximate Acceptable Pump Range Margin, gallons Reference Flow, gpm per minute (gpm) |
| | CCW-PMP-A 2400 5300 CCW-PMP-B 2400 5250 jCW-PMP-C 1200 5440 I-PMP-A 45 335 SI-PMP-B 55 340 SI-PMP-C 60 320 SW-PMP-A 450 7260 SW-PMP-B 650 6880 This alternative is not intended to be used repeatedly as a testing convenience. The licensee will make efforts to obtain an acceptable calibrated flow instrument for use during the next pump test. Documentation of the flow measurements taken will be available for an onsite NRC review. |
| | 3.1.5 NRC Staff's Evaluation The licensee has proposed an alternative in lieu of the requirements found in the 2004 Edition through 2006 Addenda of the ASME OM Code, Table ISTB-3510-1. Specifically, the licensee proposed to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the pumps listed in Table 3-1. |
| | Table ISTB-3510-1 of the OM Code requires that flow rate instruments have an accuracy of plus or minus 2 percent for Group A, Group B, and comprehensive tests. |
| | The licensee currently uses externally mounted ultrasonic flow meters to measure flow rate during 1ST for the pumps listed in Table 3-1. If one of these flow meters is out of calibration, the licensee must send it to a vendor for calibration, and the process can take 2 to 6 weeks to complete, which is longer than the TS LCO. The NRC staff previously authorized this alternative for the HBRSEP Unit 2 third 1ST 10-year interval on July 15, 1994, and fourth 1ST 10-year interval on June 26, 2003. |
| | The licensee stated that in the fourth 10-year 1ST interval, noncalibrated flow instrumentation has been used two times between July 2009 and January 2010 for SW pump A. five times between July 2009 and January 2010 for SW pump B, and once for SI pump C. During this time, it became evident to the licensee that the permanent meter for SW pumps A and B was erratic. To eliminate this issue, the licensee purchased and calibrated two new ultrasonic flow meters, and the vendor was brought in to help install and test the new devices. Also, SW pump B was being tested at an increased frequency (every 45 days) during this interim period. |
| | In Table 3-2, the licensee provided the Acceptable Range flow rate margin for each pump, based on the most recent pump test results. This data shows that the flow rate margin is sufficient so that the use of a noncalibrated instrument would not mask pump degradation that would require a pump to enter the Alert Range or Required Action Range. |
| | |
| | - 5 The licensee is also attempting to replace the calibrated ultrasonic flow meters with permanent indicators that require less user interface. The licensee will not use noncalibrated flow measurement instruments as a testing convenience. If usage of noncalibrated instruments is required, the licensee will make an effort to obtain a calibrated flow measurement instrument for subsequent tests. |
| | The licensee's alternative request was based on applying the rule of 10 CFR 50.55a(a)(3)(i), |
| | "The proposed alternatives would provide an acceptable level of quality and safety." However, the alternative method described in IST-RR2 is more in line with 10 CFR 50.55a(a)(3)(ii), |
| | "Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety." Therefore, the NRC finds that the proposed alternative provides reasonable assurance that the pumps listed in Table 3-1 are operationally ready. |
| | |
| | ==4.0 CONCLUSION== |
| | |
| | The NRC staff finds that the proposed alternative, described in alternative request IST-RR-2, provides reasonable assurance that the pumps listed in Table 3-1 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(a)(3)(ii), and is in compliance with the ASME OM Code's requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests remain applicable. |
| | Therefore, the NRC authorizes the alternative, described in IST-RR-2, for the HBRSEP, 10-year 1ST interval, which began on July 21,2012, and is currently scheduled to end on July 20, 2022. |
| | Principle Contributor: Robert Wolfgang Date of issuance: December 11, 2012 |
| | |
| | ML12314A288 |
| | * Via Memo OFFICE 2/PM LPL2-2/LA DE/EPTB/BC* DE/EICB/BC* LPL2-2/BC NAME ABillochCol6n BClayton AMcMurtray ..IThorp ABiliochCol6n DATE 11/08112 11/14112 11/15/12 11/29/12 12/11/12}} |
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Category:Letter
MONTHYEARIR 05000261/20244012024-09-11011 September 2024 Security Baseline Inspection Report 05000261/2024401 ML24242A2612024-08-29029 August 2024 Operator Licensing Examination Approval 05000261/2024301 IR 05000261/20240052024-08-22022 August 2024 Updated Inspection Plan for H.B. Robinson Steam Electric Plant - Report 05000261/2024005 ML24169A2712024-08-14014 August 2024 – Issuance of Amendment No. 280 to Adopt TSTF-258-A, Revision 4, Regarding Changes to Technical Specification 5.7, High Radiation Area IR 05000261/20240022024-08-0101 August 2024 Integrated Inspection Report 05000261/2024002 ML24183A0972024-07-12012 July 2024 ISFSI; Catawba 1, 2 & ISFSI; McGuire 1, 2 & ISFSI; Oconee 1, 2, 3 & ISFSI; Shearon Harris 1; H. B. Robinson 2 & ISFSI; and Radioactive Package Shipping Under 10 CFR 71 (71-266 & 71-345) – Review of QA Program Changes EPID L-2024-LLQ-0002 IR 05000261/20240112024-06-0303 June 2024 Focused Engineering Inspection- Commercial Grade Dedication Report 05000261/2024011 ML24114A0152024-06-0303 June 2024 Unit 2 – Issuance of Amendment No. 279 Regarding Application of Leak-Before-Break Methodology for Auxiliary Reactor Coolant System Piping IR 05000261/20240012024-05-0909 May 2024 Integrated Inspection Report 05000261/2024001 IR 05000261/20240102024-04-30030 April 2024 Biennial Problem Identification and Resolution Inspection Report 05000261/2024010 IR 05000261/20230062024-02-28028 February 2024 Annual Assessment Letter for H.B. Robinson Steam Electric Plant Unit 2 - Report 05000261-2023006 IR 05000261/20243012024-02-0606 February 2024 – Notification of Licensed Operator Initial Examination 05000261/2024301 ML24033A0592024-02-0202 February 2024 Response to Request for Additional Information License Amendment Request to Exclude the Dynamic Effects of Specific Postulated Pipe Ruptures from the Design and Licensing Basis Based on Leak-Before-Break Methodology IR 05000261/20230042024-01-31031 January 2024 Integrated Inspection Report 05000261/2023004 ML24009A2432024-01-25025 January 2024 Unit, No. 2 - Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0047 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML24009A2712024-01-24024 January 2024 Revision to Reactor Vessel Material Surveillance Capsule Withdrawal Schedule ML23354A0052024-01-0808 January 2024 Request for Withholding Information from Public Disclosure, H. B. Robinson Steam Electric Plant, Unit No. 2 ML23342A0902023-12-0808 December 2023 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection IR 05000261/20234202023-11-30030 November 2023 Security Baseline Inspection Report 05000261/2023420 (Cover Letter with Report) IR 05000261/20230102023-11-28028 November 2023 Fire Protection Team Inspection Report 05000261/2023010 ML23317A3462023-11-14014 November 2023 Duke Fleet - Correction Letter to License Amendment Nos. 312 & 340 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000261/20230032023-11-0707 November 2023 Integrated Inspection Report 05000261 2023003 and 07200060 2023001 ML23226A0862023-10-12012 October 2023 Issuance of Amendment No. 277 Regarding Revision of TSs to Add High-High Steam Generator Level Function to Table 3.3.2-1 and Remove Obsolete Content from TSs 2.1.1.1 and 5.6.5.b ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 ML23235A0552023-08-23023 August 2023 Notification of an Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000261/2023010) and Request for Information (RFI) IR 05000261/20230052023-08-21021 August 2023 Updated Inspection Plan for H.B. Robinson Steam Electric Plant (Report 05000261/2023005) IR 05000261/20230022023-08-0707 August 2023 Integrated Inspection Report 05000261/2023002 IR 05000261/20234022023-05-30030 May 2023 Cyber Security Inspection Report 05000261/2023402 ML23145A1602023-05-25025 May 2023 Submittal of Updated Final Safety Analysis Report (Revision No. 30), Independent Spent Fuel Storage Installation Safety Analysis Report (Revision No. 28), Technical Specifications Bases Revisions, Quality IR 05000261/20230012023-05-0202 May 2023 Integrated Inspection Report 05000261/2023001 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 ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility IR 05000261/20220062023-03-0101 March 2023 Annual Assessment Letter for H.B. Robinson Steam Electric Plant, Unit 2 (Report 05000261/2022006) ML23047A4512023-02-21021 February 2023 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000261/2023402 ML23041A2272023-02-13013 February 2023 2022 Q4 Robinson_Workflow Final ML22329A2982023-01-19019 January 2023 Issuance of Amendment No. 274 Regarding Revision of Technical Specification 3.8.1 Surveillance Requirement 3.8.1.16 ML22294A0922022-12-15015 December 2022 Issuance of Amendment No. 273 Regarding Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 ML22339A1362022-12-0101 December 2022 2023 Requalification Program Inspection - H.B. Robinson Nuclear Plant ML22322A1322022-11-18018 November 2022 301, NRC Operator License Examination Report & Cover Letter Merged 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 ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 IR 05000261/20220032022-11-0303 November 2022 Integrated Inspection Report 05000261 2022003 IR 05000261/20224022022-10-19019 October 2022 Security Baseline Inspection Report 05000261/2022402 IR 05000261/20220102022-09-26026 September 2022 Design Basis Assurance Inspection (Teams) Inspection Report 05000261/2022010 IR 05000261/20223012022-09-23023 September 2022 301 Operator License Exam Approval Letter (05000261/2022301) ML22258A0302022-09-15015 September 2022 Evacuation Time Estimate Reports IR 05000261/20220052022-08-26026 August 2022 Updated Inspection Plan for the H.B Robinson Steam Electric Plant - Report 05000261/2022005-Final IR 05000261/20214042022-08-10010 August 2022 Reissue - H.B. Robinson Steam Electric Plant Security Baseline Inspection Report 05000261/2021404 2024-09-11
[Table view] 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:Safety Evaluation
MONTHYEARML24169A2712024-08-14014 August 2024 – Issuance of Amendment No. 280 to Adopt TSTF-258-A, Revision 4, Regarding Changes to Technical Specification 5.7, High Radiation Area ML24183A0972024-07-12012 July 2024 ISFSI; Catawba 1, 2 & ISFSI; McGuire 1, 2 & ISFSI; Oconee 1, 2, 3 & ISFSI; Shearon Harris 1; H. B. Robinson 2 & ISFSI; and Radioactive Package Shipping Under 10 CFR 71 (71-266 & 71-345) – Review of QA Program Changes EPID L-2024-LLQ-0002 ML24114A0152024-06-0303 June 2024 Unit 2 – Issuance of Amendment No. 279 Regarding Application of Leak-Before-Break Methodology for Auxiliary Reactor Coolant System Piping ML24009A2712024-01-24024 January 2024 Revision to Reactor Vessel Material Surveillance Capsule Withdrawal Schedule ML23226A0862023-10-12012 October 2023 Issuance of Amendment No. 277 Regarding Revision of TSs to Add High-High Steam Generator Level Function to Table 3.3.2-1 and Remove Obsolete Content from TSs 2.1.1.1 and 5.6.5.b ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 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 ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML22329A2982023-01-19019 January 2023 Issuance of Amendment No. 274 Regarding Revision of Technical Specification 3.8.1 Surveillance Requirement 3.8.1.16 ML22294A0922022-12-15015 December 2022 Issuance of Amendment No. 273 Regarding Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 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 ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 ML22193A2122022-08-0404 August 2022 Request of Alternatives to ASME Code Section XI Subsection IWE Requirements for Containment Inspections ML22159A2952022-08-0303 August 2022 Issuance of Amendment No. 271 Regarding Correction to Non-Conservative Technical Specifications Figure 3.4.3-2, Pressure/Temperature Limit Cooldown Curves ML22046A0222022-06-14014 June 2022 Issuance of Amendments to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO ML21259A0992021-11-0404 November 2021 Proposed Alternatives to American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants ML21242A2982021-09-21021 September 2021 Proposed Alternative to American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants ML21155A2132021-08-26026 August 2021 Plant 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 ML21113A0132021-05-0606 May 2021 Request for Use of a Later Edition of ASME Boiler and Pressure Vessel Code, Section XI for Repair and Replacement Activities 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 ML20300A2062020-11-0909 November 2020 Duke Fleet - Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML20258A2712020-09-21021 September 2020 Correction Letter to Amendment Nos. 301, 329, 307, 303, 178, 317, 296, 416, 418, 417, and 268 ML20083F9272020-08-12012 August 2020 Issuance of Amendments to Relocate the Unit/Facility/Plant Staff Qualification Requirements to the Duke Energy Quality Assurance Program Description ML20097F0882020-06-19019 June 2020 Relief Request RA-19-0106 Regarding Proposed Alternative to ASME Code Case N-729-4 Volumetric or Surface Examination Requirements EPID-L-2019-LLR-0065) ML20058E8992020-06-18018 June 2020 Issuance of Amendment No. 267 Regarding Change to Surveillance Requirement 3.8.2.1 ML20021A0132020-02-19019 February 2020 Request for Revision to Reactor Vessel Material Surveillance Capsule Withdrawal Schedule ML19205A2892019-09-24024 September 2019 Issuance of Amendment No. 266 to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML19254A6202019-09-17017 September 2019 Duke Energy Fleet (Brunswick, Catawba, Robinson, McGuire, Oconee, and Shearon Harris) - Alternative to Use Encoded Phased Array Ultrasonic Examination in Lieu of Radiography ML19158A3072019-08-15015 August 2019 Issuance of Amendment No. 265, Regarding Adoption of TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b ML19058A6322019-07-0101 July 2019 Issuance of Amendments to Revise Emergency Action Level Schemes to Incorporate Clarifications Provided by Emergency Preparedness FAQs ML19128A3262019-06-20020 June 2019 Alternative to Depth Sizing Qualification Examination of Welds ML19121A4822019-06-11011 June 2019 Staff Evaluation the 2017 Annual Report of Changes and Error Corrections Affecting the Large-Break Loss-of-Coolant Accident Analysis 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 ML18288A1392019-04-29029 April 2019 Issuance of Amendments 171, 263 Revising Technical Specifications to Support Self Performance of Core Reload Design and Safety Analyses ML19050A2972019-04-18018 April 2019 McGuire Nuclear Station, Units 1 and 2, Shearon Harris Nuclear Power Plant, Unit 1, H B. Robinson Steam Electric Plant, Unit 2 - Issuance of Amendments Regarding Removal ML18200A0422018-08-16016 August 2018 Issuance of Amendment No. 260 Regarding Request to Revise Technical Specification Reactor Coolant System Pressure and Temperature Limits to Reflect 24-Month Fuel Cycles ML18172A1722018-08-15015 August 2018 Issuance of Amendments to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application ML18115A1502018-05-25025 May 2018 Issuance of Amendment 258 Regarding Request to Revise Technical Specification Surveillance Requirement Frequencies to Support 24-Month Fuel Cycles (CAC No. MF9544; EPID L-2017-LLA-0206) ML18060A4012018-04-10010 April 2018 Redacted Issuance of Amendments Revising TSs for Methodology Reports DPC-NE-3008-P, Revision 0, and DPC-NE-3009-P, Revision 0) (CAC Nos. MF8439 and MF8440; EPID L-2016-LLA-0012) ML17331A0862017-12-26026 December 2017 Alternative to Inservice Inspection Regarding Reactor Pressure Vessel Threads ML17188A3872017-08-21021 August 2017 Issuance of Amendments Regarding Application to Consolidate Emergency Operations Facilities and Associated Emergency Plan Changes (CAC Nos. MF7650 Through MF7660) ML17102A9232017-05-18018 May 2017 Nonproprietary Issuance of Amendments Revising Technical Specifications for Methodology Reports DPC Ne 1008 P Revision 0, DPC Nf 2010 Revision 3 and DPC Ne 2011 P Revision 2 (CAC Nos. MF6648, MF6649, MF7693/MF7694) ML17055A6472017-05-0808 May 2017 Brunswick, Catawba, McGuire, Shearon Harris, and H. B. Robinson - Issuance of Amendments to Revise Technical Specifications to Adopt TSTF-522, Revision 0 (CAC Nos. MF8422, MF8423, MF8424, MF8425, MF8426, MF8427, MF8428, and MF8429) ML17066A3742017-04-26026 April 2017 Issuance of Amendments Re. Application to Revise TSs to Adopt TSTF-427, Rev. 2, Using the Consolidated Line Item Improvement Process (CAC Nos. MF8039 Through MF8049) ML17039A1532017-03-23023 March 2017 H.B. Robinson, Unit 2 - Issuance of Amendment 250 to Adopt Technical Specification Task Force (TSTF) Change Traveler TSTF-339, Revision 2, "Relocate TS Parameters to the COLR," Consistent with WCAP-14483 (CAC No. MF7615) ML16337A2642017-02-0303 February 2017 Issuance of Amendments Regarding National Fire Protection Association Standard 805 2024-08-14
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 11, 2012 Mr. William R. Gideon, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Hartsville, South Carolina 29550 SUB~IECT: H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - RELIEF REQUEST-2 FOR THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN (TAC NO. ME8259)
Dear Mr. Gideon:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16,2012 (Agencywide Documents Access and Management System Accession No. ML12086A067), as supplemented by letters dated May 10, 2012 (No. ML12138A041), June 4,2012 (No. ML12165A261) and September 20,2012 (No. ML12278A124), Carolina Power & Light Company (the licensee),
doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).
The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of the safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety.
The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1, the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21,2012, and ends on February 18, 2022.
As discussed with the licensee on July 9,2012, the NRC staff is concerned with the amount of information provided in the submittal that required revision after review by and questions from the NRC staff, and your request for multiple concurrent reviews with a short review timeframe.
The uncharacteristic inattention to detail observed in the submittal resulted in the need to focus limited resources to address mostly administrative issues. Additional attention to ensure a high quality submittal would allow for a more efficient use of review resources, and better ability of the NRC staff to accommodate requests for a shortened review timeframe.
- w. Gideon - 2 The details of the NRC staff review are included in the enclosed SE. Section 50.55a(f) of 10 CFR, "Inservice Testing Requirements," requires in part, that the 1ST of certain ASME OM Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements.
Therefore, the licensee's proposed alternative for 1ST-RR-2 is authorized for the fifth 10-year 1ST interval at HBRSEP, which started on July 21, 2012, and ends on February 18, 2022.
Sincerely, e F. Quic ocho, Acting Chief lant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
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- "" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON THE FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM PLAN RELIEF REQUEST-2 CAROLINA POWER & LIGHT COMPANY H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. 50-261
1.0 INTRODUCTION
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 16, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12086A067), as supplemented by letters dated May 10, 2012 (No. ML12138A041), June 4,2012 (No.
ML12165A261) and September 20,2012 (No. ML12278A124), Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted Relief Request (RR)-2 for the Inservice Testing (1ST) Program Plan for the fifth 10-year interval for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).
The licensee proposed to use alternative flow instrumentation as required for the 1ST of the pumps listed in Table 3-1 of this safety evaluation (SE). These alternatives will be used in lieu of current pump testing methods and acceptance criteria described in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for HBRSEP. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i), the licensee requested to use proposed alternatives on the basis that the alternatives provide an acceptable level of quality and safety.
The fourth 10-year interval in HBRSEP began on February 19, 2002, and was scheduled to end on February 18, 2012. As allowed by ASME Section XI, IWA-2430(d) 1, the licensee extended the fourth 10-year interval through July 20,2012, to complete refueling outage-27, which was postponed to January 18, 2012. The duration of the proposed alternative is for the fifth 10-year 1ST interval that started on July 21, 2012, and ends on February 18, 2022.
2.0 REGULATORY EVALUATION
Section 50.55a(f) of 10 CFR, "Inservice Testing ReqUirements," requires in part, that the 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii) of 10 CFR 50.55a.
In proposing alternatives, a licensee must demonstrate that the proposed alternatives provide an acceptable level of quality and safety. Paragraph 50.55a(a)(3) of 10 CFR states, in part, that alternatives to the requirements of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of
-2 quality and safety or if (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The licensee requested authorization in IST-RR-2 of an alternative to the requirements of the ASME OM Code pursuant to 10 CFR 50.55a(a)(3)(i). The NRC staff has previously authorized IST-RR-2 for the third 1ST 1O-year interval on July 15, 1994 (ADAMS Legacy Library No. 9407250145) and for the fourth 1ST 10-year interval on June 27,2002 (ADAMS Accession No. ML031780245) for HBRSEP.
3.0 TECHNICAL EVALUATION
The NRC staff has evaluated the information provided by the licensee in support of IST-RR-2 for relief from, and alternative to, the ASME OM Code requirements and the bases for disposition are documented below.
3.1 IST-RR-2 3.1.1 ASME Code Requirements The applicable ASME OM Code edition and addenda for HBRSEP is the 2004 Edition through the 2006 Addenda.
Table ISTB-351 0-1, "Required Instrument Accuracy,>> requires that flow rate instrumentation used for Group A, Group B, comprehensive, and preservice tests have an accuracy of plus or minus 2 percent.
3.1.2 Component for which Relief is Requested The licensee requested to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the following pumps:
Table 3-1: Components for which Relief is Requested Pump Description Category Type CCW-PMP-A CCW (Component Cooling Water) Pump A Group A Horizontal Centrifugal CCW-PMP-B CCW Pump B Group A Horizontal Centrifugal CCW-PMP-C CCWPumpC Group A Horizontal Centrifugal SI-PMP-A Safety Injection (SI) Pump A Group B Horizontal Centrifugal SI-PMP-B SI Pump B Group B Horizontal Centrifugal SI-PMP-C SI PumpC Group B Horizontal Centrifugal SW-PMP-A SW (Service Water) Pump A Group A Vertical Line Shaft SW-PMP-B SW Pump B Group A Vertical Line Shaft 3.1.3 Licensee's Basis for Relief Request The original plant design of HBRSEP Unit 2 occurred prior to the issuance of 1ST requirements, and the plant design did not include flow rate measurement instrumentation that met subsequent ASME OM Code requirements. Since that time, flow instrumentation that meets
- 3 ASME OM Code requirements has been installed. However, the pumps listed in Table 3-1 have flow instrumentation that may be difficult to replace with certified instruments within the allotted Technical Specification (TS) limiting condition for operation (LCO).
In order to calibrate the flow instruments, a reference standard must be utilized and a calibration certificate obtained. HBRSEP is not equipped to perform this type of calibration and the instruments are sent to a certified vendor. The vendor is no longer capable of calibrating these instruments without the use of a test facility, which must be reserved in advance prior to use.
The time it takes to complete the calibration process varies from 2 to 6 weeks. The TS LCO time period would not be sufficient to facilitate diagnostics, instrument transport, repairs, calibration, reinstallation, and certification upon discovery that a calibrated instrument is found to be deficient. Also, for the SW and CCW pumps, this turnaround time could force the licensee to use noncalibrated flow instruments in consecutive quarterly tests.
The licensee is attempting to replace the ultrasonic flow meters with permanent indicators that require less user interface. However, two flow instrument installations are not functioning properly and will require additional modifications. One permanent flow meter used to support the CCW pump 1ST is working properly, however, the licensee feels it would be prudent to monitor this flow meter installation to ensure that long term performance continues to be accurate and repeatable. If the new flow meter produces erratic results, an ultrasonic flow meter could be used in accordance with HBRSEP procedures to obtain accurate flow measurements in order to assess pump operational readiness.
3.1.4 Licensee's Proposed Alternative Examination In the unlikely event that a flow rate measurement device for the pumps listed in Table 3-1 failed to operate properly and a calibrated flow rate instrument, composed of a meter and a set of transducers that have been previously paired during off-site calibration, is not available for replacement, an uncalibrated ultrasonic flow measurement device, composed of a meter and a set of transducers that have not been previously paired during off-site calibration, can be installed in accordance with specific instructions to ensure proper operation and provide accurate measurement of flow rate. Generally, spare instruments are maintained and certified, but may not be available, or rendered inoperable. When calibrated flow instruments are not available, backup uncalibrated flow measurement instruments can be installed and verified in accordance with a detailed procedure in order to provide a high level of assurance relative to the proper operation of the flow rate device. Based on past experience, unsatisfactory pump performance can be determined through the use of noncalibrated ultrasonic flow rate instruments when the instruments are properly installed and verified in accordance with site specific procedures. An acceptable level of quality and safety is maintained and the use of this alternative would be prudent in the unlikely event of this emergent condition.
The licensee has used noncalibrated flow measurement instruments on occasion during the HBRSEP fourth 10-year 1ST program interval. For SW pump A, they were used two times between July 2009 and January 2010; for SW pump B, they were used five times bewteen July 2009 and January 2010; for SI pump C, they were used once.
Table 3-2 shows the approximate Acceptable Range margin currently available and the flow reference value for each pump.
-4 Table 3-2 Approximate Acceptable Pump Range Margin, gallons Reference Flow, gpm per minute (gpm)
CCW-PMP-A 2400 5300 CCW-PMP-B 2400 5250 jCW-PMP-C 1200 5440 I-PMP-A 45 335 SI-PMP-B 55 340 SI-PMP-C 60 320 SW-PMP-A 450 7260 SW-PMP-B 650 6880 This alternative is not intended to be used repeatedly as a testing convenience. The licensee will make efforts to obtain an acceptable calibrated flow instrument for use during the next pump test. Documentation of the flow measurements taken will be available for an onsite NRC review.
3.1.5 NRC Staff's Evaluation The licensee has proposed an alternative in lieu of the requirements found in the 2004 Edition through 2006 Addenda of the ASME OM Code, Table ISTB-3510-1. Specifically, the licensee proposed to use, on a temporary basis when required, noncalibrated ultrasonic flow measuring instruments with an intrinsic accuracy of plus or minus 3 percent, during 1ST for the pumps listed in Table 3-1.
Table ISTB-3510-1 of the OM Code requires that flow rate instruments have an accuracy of plus or minus 2 percent for Group A, Group B, and comprehensive tests.
The licensee currently uses externally mounted ultrasonic flow meters to measure flow rate during 1ST for the pumps listed in Table 3-1. If one of these flow meters is out of calibration, the licensee must send it to a vendor for calibration, and the process can take 2 to 6 weeks to complete, which is longer than the TS LCO. The NRC staff previously authorized this alternative for the HBRSEP Unit 2 third 1ST 10-year interval on July 15, 1994, and fourth 1ST 10-year interval on June 26, 2003.
The licensee stated that in the fourth 10-year 1ST interval, noncalibrated flow instrumentation has been used two times between July 2009 and January 2010 for SW pump A. five times between July 2009 and January 2010 for SW pump B, and once for SI pump C. During this time, it became evident to the licensee that the permanent meter for SW pumps A and B was erratic. To eliminate this issue, the licensee purchased and calibrated two new ultrasonic flow meters, and the vendor was brought in to help install and test the new devices. Also, SW pump B was being tested at an increased frequency (every 45 days) during this interim period.
In Table 3-2, the licensee provided the Acceptable Range flow rate margin for each pump, based on the most recent pump test results. This data shows that the flow rate margin is sufficient so that the use of a noncalibrated instrument would not mask pump degradation that would require a pump to enter the Alert Range or Required Action Range.
- 5 The licensee is also attempting to replace the calibrated ultrasonic flow meters with permanent indicators that require less user interface. The licensee will not use noncalibrated flow measurement instruments as a testing convenience. If usage of noncalibrated instruments is required, the licensee will make an effort to obtain a calibrated flow measurement instrument for subsequent tests.
The licensee's alternative request was based on applying the rule of 10 CFR 50.55a(a)(3)(i),
"The proposed alternatives would provide an acceptable level of quality and safety." However, the alternative method described in IST-RR2 is more in line with 10 CFR 50.55a(a)(3)(ii),
"Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety." Therefore, the NRC finds that the proposed alternative provides reasonable assurance that the pumps listed in Table 3-1 are operationally ready.
4.0 CONCLUSION
The NRC staff finds that the proposed alternative, described in alternative request IST-RR-2, provides reasonable assurance that the pumps listed in Table 3-1 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(a)(3)(ii), and is in compliance with the ASME OM Code's requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests remain applicable.
Therefore, the NRC authorizes the alternative, described in IST-RR-2, for the HBRSEP, 10-year 1ST interval, which began on July 21,2012, and is currently scheduled to end on July 20, 2022.
Principle Contributor: Robert Wolfgang Date of issuance: December 11, 2012
ML12314A288
- Via Memo OFFICE 2/PM LPL2-2/LA DE/EPTB/BC* DE/EICB/BC* LPL2-2/BC NAME ABillochCol6n BClayton AMcMurtray ..IThorp ABiliochCol6n DATE 11/08112 11/14112 11/15/12 11/29/12 12/11/12