ML16020A331

Cooper - Response to Fifth Ten-Year Interval Pump and Valve IST Program Relief, Requests Identified Discrepancies

ML16020A331
Person / Time
Site:	Cooper
Issue date:	01/13/2016
From:	Limpias O A Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2016004
Download: ML16020A331 (5)

Text

NNebraska Public Power DistrictAlways there when you need usNLS201 6004January 13, 2016U.S. Nuclear Regulatory Commission Attention:

Document Control DeskWashington, D.C. 20555-0001

Subject:

Response to Fifth Ten-Year Interval Pump and Valve IST Program ReliefRequests Identified Discrepancies Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Letter from Oscar A. Limpias, Nebraska Public Power District, to the U.S. NuclearRegulatory Commission, dated Marchl 19, 2015, "Fifth Ten-Year Interval Pumpand Valve Inservice Testing Program Relief Requests"

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District (NPPD) to provide a responseto discrepancies identified by the Nuclear Regulatory Commission (NRC) in the referenced letterrelated to Relief Requests RP-04, RP-05, and RP-07.The proposed relief requests contain potential errors that were identified during a review by theNRC. The attachment to this letter provides the NPPD response.

This letter does not contain any new regulatory commitments.

If you have any questions concerning this matter, please contact Jim Shaw, Licensing Manager,at (402) 825-2788.

Vice President

-Nuclearand Chief Nuclear Officer/dv

Attachment:

Response to Fifth Ten-Year Interval Pump and Valve Inservice Testing (1ST)Progr.am Relief Requests Identified Discrepancies P.O. Box 98 / Brownville, NE 68321-0098 Telephone:

(402) 825-3811

/ Fax:. (402)

NLS2016004 Page 2 of 2cc: Regional Administrator w/ attachment USNRC -Region IVCooper Project Manager wI/attachment USNRC -NRR Plant Licensing Branch IV-2Senior Resident Inspector wI/attachment USNRC -CNSNPG Distribution w/o attachment CNS Records w/ attachment NLS2016004 Attachment Page 1 of 3Response to Fifth Ten-Year Interval Pump and Valve Inservice Testing (IST) ProgramRelief Requests Identified Discrepancies Cooper Nuclear Station, Docket No. 50-298, DPR-46The Nuclear Regulatory Commission (NRC) identified potential errors regarding 1ST ReliefRequests RP-04, RP-05, and RP-07 that were submitted for the Fifth Ten-Year Interval.

Thesediscrepancies are shown in italics, with the Nebraska Public Power District (NPPD) responseshown in normal font.Relief Request RP-04The Title and Section 1 identify the Reactor Core Isolation Cooling (RCIC) Pump as the affectedcomponent.

Section 5 identifies the High Pressure Coolant Injection (HPCI) pumps. It issuspected that the reference to the HP CI pumps is an error. Please confirm that the rest of theinformation/data provided in that section applies to the RCIC pump (i.e., not HPCI).NPPD ResponseNPPD has reviewed RP-04 and has concluded the reference to the HPCI pumps is an error. Thesecond sentence of Section 5 should state "reactor core isolation cooling" rather than "highpressure coolant injection."

The rest of the information and data provided in Section 5 correctly applies to the RCIC pump.Relie~fRequest RP-05(a) The 4th paragraph of Section 5 discusses the HPCI pumps flow rate; the fifth paragraph discusses the RCIC PumP flow. However, in the last sentence of the RCIC paragraph, the flowrate is indicated to be 6000 gallons per minute (gpm) and the instrument accuracy is identified as 1.66% (same as HPCI). Please confirm the information/data provided in those sections.

(b) The 4th paragraph of Section 5 discusses the HP CI pump flow indicating controller with arange of 0 to 5000 gpm. Whereas, the last few lines of the 4th paragraph use 6000 gpm, whichwould seem to exceed the flow range.(c) The 4th paragraph of Section 5, fifth line, discusses the HP CI pump nameplate accuracy+0.25% from approximately 1000 to 5000 gpm, which does not provide the correct loopaccuracy as mentioned in the same paragraph.

(d) The 5th paragraph of Section S discusses the RClC pump flow range as 0 to 500 gpm.Whereas, the last few lines of the 5th paragraph use 6000 gpm.(e) The 5th paragraph of Section 5, RCIC pump flow indicating controller (FIC-91) nameplate accuracy and flow square rooter (SQRT-99) nameplate accuracy as stated in the request do notprovide the correct loop accuracy as mentioned in the same paragraph.

NLS2016004 Attachment Page 2 of 3Co Please confirm the above. Additionally, suggest that NPPD verify all the flows andaccuracies in the 4th and Sth paragraphs of RP-05, because they do not match specifically withprevious fourth 10O-year 1ST interval pro gram.NPPD ResponseNPPD has reviewed RP-05 and has concluded the following:

(a) The calibration tolerance of+l10 gpm for the RCIC pump flow loop is +/-_2% of full scale(+0.02 x 500 gpm = +10 gpm) rather than approximately

+/-1.66% of full scale (+/-0.0166 x 6000gpm = +/-100 gpm). The calibration tolerance is equivalent to the +_2% full scale accuracyrequirements of the code.(b) The range of 0 to 5000 gpm is correct for the HPCI flow indicating controller.

The flow loopis calibrated to within +100 gpm or +2% of full scale (+/-+0.02 x 5000 gpm = +/-100 gpm).(c) The HPCI flow square rooter has a nameplate accuracy of++/-0.5%

(not +/-0.25%) fromapproximately 1000 to 5000 gpm. Therefore, the loop accuracy for flow indication isapproximately 0.6 1% [sqrt(0.25 2 + 0.252 + 0.52)] from 1000 to 5000 gpm as stated in thesubmitted fifth ten-year interval relief request.(d) The correct flow range for RCIC is 0 to 500 gpm. The reference to 6000 gpm was incorrectly referenced as discussed under the response to (a), above.(e) The original intent was to submit the identical relief request for the fifth ten-year interval aswas submitted for the fourth ten-year interval.

Based on this, the RCIC flow indicating controller had a nameplate accuracy of++/-0.25%

rather than +2% and the RCIC flow square rooterhad a nameplate accuracy of +0.5%, rather than +0.25%, from 100 to 500 gpm. This wouldresult in the listed loop accuracies of +2.03% [sqrt(0.252

+ 0.252+ 22)] from 0 to 100 gpm and+0.61% [sqrt(0.252

+ 0.252+ 0.52)] from 100 to 500 gpm.(f) The NRC identified discrepancies listed for RP-05 were a result of NPPD inadvertently submitting a version of RP-05 that did not match the final version that was submitted for thefourth ten-year

interval, as intended.

Therefore, all discrepancies are considered to be due to anadministrative error. These identified discrepancies were documented in the Cooper NuclearStation (CNS) corrective action program.In addition, following a more detailed review of the currently installed instrumentation for RCIC,NPPD identified that a design change completed during the fourth ten-year interval installed ahighly accurate RCIC flow indicating controller with a built-in square rooter that results in theRCIC flow loop equipment accuracy meeting the American Society of Mechanical Engineers Operation and Maintenance Code requirements.

The installation was completed in November of2012. Therefore, the RCIC pump flow rate loop instrumentation may be withdrawn fromRP-05. Since IST personnel were not involved in the review of this design change, a condition report was documented in the CNS corrective action program to address this administrative issue.

NLS201 6004Attachment Page 3 of 3Relief Request RP-O07Relief Re quest RP-O07, Core Spray Pump B Vibration Alert Limits was requested as a proposedalternative that provides an acceptable level of quality and safety per 10 CFR 50.55a(z)

(1). TheNRC's position is that it is more appropriate to request relief per 10 CFR 50.55a(z)

(2) as anundue hardship without a compensating increase in level of quality and safety.NPPD ResponseNPPD concurs with revising the basis of the relief request as an undue hardship without acompensating increase in level of quality and safety per 10 CFR 50.55a(z)(2).

NNebraska Public Power DistrictAlways there when you need usNLS201 6004January 13, 2016U.S. Nuclear Regulatory Commission Attention:

Document Control DeskWashington, D.C. 20555-0001

Subject:

Response to Fifth Ten-Year Interval Pump and Valve IST Program ReliefRequests Identified Discrepancies Cooper Nuclear Station, Docket No. 50-298, DPR-46

Reference:

Letter from Oscar A. Limpias, Nebraska Public Power District, to the U.S. NuclearRegulatory Commission, dated Marchl 19, 2015, "Fifth Ten-Year Interval Pumpand Valve Inservice Testing Program Relief Requests"

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District (NPPD) to provide a responseto discrepancies identified by the Nuclear Regulatory Commission (NRC) in the referenced letterrelated to Relief Requests RP-04, RP-05, and RP-07.The proposed relief requests contain potential errors that were identified during a review by theNRC. The attachment to this letter provides the NPPD response.

This letter does not contain any new regulatory commitments.

If you have any questions concerning this matter, please contact Jim Shaw, Licensing Manager,at (402) 825-2788.

Vice President

-Nuclearand Chief Nuclear Officer/dv

Attachment:

Response to Fifth Ten-Year Interval Pump and Valve Inservice Testing (1ST)Progr.am Relief Requests Identified Discrepancies P.O. Box 98 / Brownville, NE 68321-0098 Telephone:

(402) 825-3811

/ Fax:. (402)

NLS2016004 Page 2 of 2cc: Regional Administrator w/ attachment USNRC -Region IVCooper Project Manager wI/attachment USNRC -NRR Plant Licensing Branch IV-2Senior Resident Inspector wI/attachment USNRC -CNSNPG Distribution w/o attachment CNS Records w/ attachment NLS2016004 Attachment Page 1 of 3Response to Fifth Ten-Year Interval Pump and Valve Inservice Testing (IST) ProgramRelief Requests Identified Discrepancies Cooper Nuclear Station, Docket No. 50-298, DPR-46The Nuclear Regulatory Commission (NRC) identified potential errors regarding 1ST ReliefRequests RP-04, RP-05, and RP-07 that were submitted for the Fifth Ten-Year Interval.

Thesediscrepancies are shown in italics, with the Nebraska Public Power District (NPPD) responseshown in normal font.Relief Request RP-04The Title and Section 1 identify the Reactor Core Isolation Cooling (RCIC) Pump as the affectedcomponent.

Section 5 identifies the High Pressure Coolant Injection (HPCI) pumps. It issuspected that the reference to the HP CI pumps is an error. Please confirm that the rest of theinformation/data provided in that section applies to the RCIC pump (i.e., not HPCI).NPPD ResponseNPPD has reviewed RP-04 and has concluded the reference to the HPCI pumps is an error. Thesecond sentence of Section 5 should state "reactor core isolation cooling" rather than "highpressure coolant injection."

The rest of the information and data provided in Section 5 correctly applies to the RCIC pump.Relie~fRequest RP-05(a) The 4th paragraph of Section 5 discusses the HPCI pumps flow rate; the fifth paragraph discusses the RCIC PumP flow. However, in the last sentence of the RCIC paragraph, the flowrate is indicated to be 6000 gallons per minute (gpm) and the instrument accuracy is identified as 1.66% (same as HPCI). Please confirm the information/data provided in those sections.

(b) The 4th paragraph of Section 5 discusses the HP CI pump flow indicating controller with arange of 0 to 5000 gpm. Whereas, the last few lines of the 4th paragraph use 6000 gpm, whichwould seem to exceed the flow range.(c) The 4th paragraph of Section 5, fifth line, discusses the HP CI pump nameplate accuracy+0.25% from approximately 1000 to 5000 gpm, which does not provide the correct loopaccuracy as mentioned in the same paragraph.

(d) The 5th paragraph of Section S discusses the RClC pump flow range as 0 to 500 gpm.Whereas, the last few lines of the 5th paragraph use 6000 gpm.(e) The 5th paragraph of Section 5, RCIC pump flow indicating controller (FIC-91) nameplate accuracy and flow square rooter (SQRT-99) nameplate accuracy as stated in the request do notprovide the correct loop accuracy as mentioned in the same paragraph.

NLS2016004 Attachment Page 2 of 3Co Please confirm the above. Additionally, suggest that NPPD verify all the flows andaccuracies in the 4th and Sth paragraphs of RP-05, because they do not match specifically withprevious fourth 10O-year 1ST interval pro gram.NPPD ResponseNPPD has reviewed RP-05 and has concluded the following:

(a) The calibration tolerance of+l10 gpm for the RCIC pump flow loop is +/-_2% of full scale(+0.02 x 500 gpm = +10 gpm) rather than approximately

+/-1.66% of full scale (+/-0.0166 x 6000gpm = +/-100 gpm). The calibration tolerance is equivalent to the +_2% full scale accuracyrequirements of the code.(b) The range of 0 to 5000 gpm is correct for the HPCI flow indicating controller.

The flow loopis calibrated to within +100 gpm or +2% of full scale (+/-+0.02 x 5000 gpm = +/-100 gpm).(c) The HPCI flow square rooter has a nameplate accuracy of++/-0.5%

(not +/-0.25%) fromapproximately 1000 to 5000 gpm. Therefore, the loop accuracy for flow indication isapproximately 0.6 1% [sqrt(0.25 2 + 0.252 + 0.52)] from 1000 to 5000 gpm as stated in thesubmitted fifth ten-year interval relief request.(d) The correct flow range for RCIC is 0 to 500 gpm. The reference to 6000 gpm was incorrectly referenced as discussed under the response to (a), above.(e) The original intent was to submit the identical relief request for the fifth ten-year interval aswas submitted for the fourth ten-year interval.

Based on this, the RCIC flow indicating controller had a nameplate accuracy of++/-0.25%

rather than +2% and the RCIC flow square rooterhad a nameplate accuracy of +0.5%, rather than +0.25%, from 100 to 500 gpm. This wouldresult in the listed loop accuracies of +2.03% [sqrt(0.252

+ 0.252+ 22)] from 0 to 100 gpm and+0.61% [sqrt(0.252

+ 0.252+ 0.52)] from 100 to 500 gpm.(f) The NRC identified discrepancies listed for RP-05 were a result of NPPD inadvertently submitting a version of RP-05 that did not match the final version that was submitted for thefourth ten-year

interval, as intended.

Therefore, all discrepancies are considered to be due to anadministrative error. These identified discrepancies were documented in the Cooper NuclearStation (CNS) corrective action program.In addition, following a more detailed review of the currently installed instrumentation for RCIC,NPPD identified that a design change completed during the fourth ten-year interval installed ahighly accurate RCIC flow indicating controller with a built-in square rooter that results in theRCIC flow loop equipment accuracy meeting the American Society of Mechanical Engineers Operation and Maintenance Code requirements.

The installation was completed in November of2012. Therefore, the RCIC pump flow rate loop instrumentation may be withdrawn fromRP-05. Since IST personnel were not involved in the review of this design change, a condition report was documented in the CNS corrective action program to address this administrative issue.

NLS201 6004Attachment Page 3 of 3Relief Request RP-O07Relief Re quest RP-O07, Core Spray Pump B Vibration Alert Limits was requested as a proposedalternative that provides an acceptable level of quality and safety per 10 CFR 50.55a(z)

(1). TheNRC's position is that it is more appropriate to request relief per 10 CFR 50.55a(z)

(2) as anundue hardship without a compensating increase in level of quality and safety.NPPD ResponseNPPD concurs with revising the basis of the relief request as an undue hardship without acompensating increase in level of quality and safety per 10 CFR 50.55a(z)(2).