ML14101A365

Relief Request for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing Program

ML14101A365
Person / Time
Site:	Columbia
Issue date:	04/02/2014
From:	Javorik A L Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-14-049
Download: ML14101A365 (44)

Text

Alex L. JavodkColm*W Generutng StadlonP.O. Box 968, PE04I I.. .r Richia, WA 99352-0968 Ph. 509-377-555April 2, 2014 10 CFR 50.55&G02-14-049 U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

Subject:

COLUMBIA GENERATING

STATION, DOCKET NO. 65047RELIEF REQUESTS FOR THE COLUMBIA GENERATING STATIONFOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM

Dear Sir or Madam,

Pursuant to 10 CFR 50.55a(aX3) and 10 CFR 50.55a(f)(5)(i),

Energy Northwest herebyrequests NRC approval of the attached relief requests for the upcoming Fourth Ten-Year Interval Pump and Valve Inservice Testing (IST) Program at Columbia Generating Station.

As required by 10 CFR 50.55a(f)(4).

the Fourth Ten-Year Interval IST Programwill comply with the requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code (2004 Edition through 2006 Addenda).

Previous IST relief requests for Columbia have been submitted with the overall programplan for the associated ten-year Interval.

However, for the upcoming fourth ten-year ISTinterval, Energy Northwest is submitting the associated relief requests separately and inadvance of the overall program plan. The IST overall program plan for the fourth ten-year interval will be submitted by separate correspondence.

Attachment I to this letter provides a comparison between the relief requests for thethird ten-year interval and the relief requests for the fourth ten-year interval.

Attachment 2 provides the relief requests for the fourth ten-year interval IST program.The Fourth Ten-Year Interval Program will be in effect from December 13, 2014 toDecember 12, 2024. Energy Northwest requests approval of the relief requests byNovember 1, 2014, to allow time for implementation before the start of the Interval.

There are no new or revised regulatory commitments contained in this submittal.

If youhave any questions or require additional information, please contact Ms. L. L. Williamsat (509) 377-8148.

RELIEF REQUESTS FOR THE COLUMBIA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAMPage 2 of 2Executed this day of -0___2014.

Respecftully, A. L. JavorkVice President, Engineering Attachments:

1. Comparison Between Relief Requests for the Third Ten-YearInterval and Relief Requests for the Fourth Ten-Year Interval2. Relief Requests for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing Programcc: NRC Region IV Administrator NRC NRR Project ManagerNRC Senior Resident Inspector/988C M. A. Jones -BPAM 399 REUEF REQUESTS FOR THE COLUMBIA GENERATING STATION FOURTH TEN-YEAR INTERVAL INSERVICE TESTING PROGRAMAttachment 1Comparison Between Relief Requests for the Third Tan-Yeor Interval and ReliefRequests for the Fourth Ten-Year IntervalA comparison between the relief requests for the third ten-year interval and the reliefrequests for the fourth ten-year interval is shown in the following table.Relief Request Number Equivalent or New Relief CommentsIn 3r Ten Year Interval Request Number In 4" TenPlan Year Interval PlanRG01 New Relief Request to useCode Case OMN-20 for.............

... .. ._Frequency GraceRP01 RP01RP03 RP02RP04 RP03RP05 RP04RP06 RPO5RP07 Deleted -ISTB-3510(bX2) revised to incorporate CodeCase OMN-6 in OMb 2006___addenda RP06 New Relief Request to useCode Case OMN-19Alternate Upper Limit for theComprehensive Pump TestRV01 RV01RV02 Deleted -ISTC-5100 revisedto incorporate Code CaseOMN-8 in OMb 2006addenda.RV03 RV02RV04 RV03RV05 RV04Details are provided in the individual relief requests provided In Attachment 2 to thisletter.

REUEF REQUESTS FOR THE COLUMBIA GENERATING STATION FOURTH TEN.YEAR INTERVAL INSERVICE TESTING PROGRAMAttachment 2Relief Requests for the Columbia Generating StationFourth Ten-Year IntervalInservice Testing Program 4ST Proam Plan Columbia Generating Station P I of 404th 10-Year Interval (Relief Requests Only)Relief Request -RGOIProposed Altwnative In Accordanr with 10 CFR 5.5*e(aX3XI)

-Hardship or Unusual Difficulty Without Compensating increase in Level of Quality and Safety -AlN Pumps and Valves contained within the Inservice Testing Program scope.Am --ab-- Code Editnd AddendaThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code.AalSM Code This request applies to the frequency specifications of the ASME OM Code. The frequencies for testsgiven in the ASME OM Code do not include a tolerance band.ISTA-3120(a)

ISTB-3400 ISTC-3510 ISTC-3540 ISTC-3630 (a)ISTC-3700 Inservice Testinm Interval.

The frequency for the inservice testing shall be in accordance with the requirements of SectionIST.F~guec of knev Tet. An inservice test shall be run oneach pump as specified in Table ISTB-3400-1.

Exercisig Test Freguencv.

Active Category A, Category B, andCategory C check valves shall be exercised nominally every 3months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC.5221, and ISTC-5222.

Power-operated relief valves shall be exercise tested once per fuel cycle.Maual .Manual valves shall be full-stroke exercised atleast once every 2 years, except where adverse conditions mayrequire the valve to be tested more frequently to ensureoperational readiness.

Any increased testing frequency shall bespecified by the Owner. The valve shall exhibit the requiredchange of obturator position.

Leakage Rate for Other Than Contaiment isolatio Valves.Fegunc. Tests shall be conducted at least once every 2years.Position Veification Testin. Valves with remote positionindicators shall be observed locally at least once every 2 years toverify that valve operation is accurately Indicated.

iST Program Plan Columbia Generating Station Page 2 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RG0I (Contd.)ISTC-5221(c)(3)

ISTC-5260 Appendix 1, 1-1320(a)

Appendix I, 1-1330Appendix I, 1-1340Appendix 1, 1-1350(a)

VAMe bWo hMovrnen.

At least one valve from each groupshall be disassembled and examined at each refueling outage;all valves In a group shall be disassembled and examined atleast once every 8 years.Explosvely Actuated Valves. (b) Concurrent with the first testand at least once every 2 years, the service life records of eachvalve shall be reviewed to verify that the service life of thecharges have not been exceeded and will not be exceededbefore the next refuel. (c) At least 20% of the charges Iexplosively actuated valves shall be fired and replaced at leastonce every 2 years.Test Freauencies.

Class I Pressure Relief Valvs, UY r TestClass I pressure relief valves shall be tested at leastonce every 5 years, starting with initial electric power generation.

No maximum limit Is specified for the number of valves to betested within each interval;

however, a minimum of 20% of thevalves from each valve group shall be tested within any 24month Interval.

Test Freouencv.

Class I Nonre1osino Pressure Relief Devices.Class 1 nonrecloslng pressure relief devices shaft be replacedevery 5 years unless historical data indicates a requirement formore frequent replacement.

Class I Pressure Relief Valves that are usedfor Thermal Relief Application.

Tests shall be performed inaccordance with 1-1320, Test Frequencies, Class 1 PressureRelief Valves.Test Freouencv.

Class 2 and 3 Pressure Relief Valves. 10-Year1t2t Interval, Classes 2 and 3 pressure relief valves, with theexception of PWR main steam safety valves, shall be testedevery 10 years, starting with initial electric power generation.

Nomaximum limit is specified for the number of valves to be testedduring any single plant operating cycle; however, a minimum of20% of the valves from each valve group shall be tested withinany 48 month interval.

Test FreOuency.

Class 2 and 3 Nonreclosing Pressure ReliefQojas. Classes 2 and 3 nonreclosing pressure relief devicesshaft be replaced every 5 years, unless historical data indicates arequirement for more frequent replacement.

Appendix I, 1-1360 1ST lO-w, te Columbia Generating Station P4th 1 .-Year Interval (Relief Requests Only)Relief Request -RGOI (Contd.)Appendix 1, 1-1370Appendix i, 1-1380Appendix 1, 1-1390Appendix 11, 11-4000Appendix 11, 114000MOV Diagnostic TestsTest Freauencv.

Class 2 and 3 Primary QConne Vacuum (a) Tests shell be performed on all Classes 2 and3 containment vacuum relief valves at each refueling outage orevery 2 years, whichever is sooner, unless historical datarequires more frequent testing.

(b) Leak tests shall be performed on all Classes 2 and 3 containment vacuum relief valves at afrequency designated by the Owner in accordance with TableISTC-3500-1.

Test Freouencv.

Classes 2 and 3 Vacuum Relief Valves. Exceotfo Primary Containment Vacuum Relief Valves. AlI Classes 2and 3 vacuum relief valves shall be tested every 2 yr, unlessperformance data suggest the need for a more appropriate testinterval.

Test Freauencv.

Classes 2 and 3 Pressure Relief Devices ThatAre Used for Thermal Relief AWotication.

Tests shall beperformed on all Classes 2 and 3 relief devices used in thermalrelief application every 10 yr, unless performance data indicatemore frequent testing is necessary.

In lieu of tests the Ownermay replace the relief devices at a frequency of every 10 yr,unless perfomrmnce data indicate more frequent replacements are necessary.

Performance Imoovemnent Activities.

(aX1) If sufficient information Is not currently available to complete the analysisrequired in 11-3000, or if this analysis is Inconclusive, then thefollowing activities shall be performed at sufficient intervals overan interim period of the next 5 years or two refueling outages,whichever Is less, to determine the cause of the failure or themaintenance patterns.

(e) Identify the interval of each activity.

Omization of Cordlio Mon na Activite.

(bX1 Xe) Identifythe Interval of each activity.

Interval extensions shall be limitedto one fuel cycle per extension.

Intervals shall not exceed themaximum intervals shown In table 11-4000-1.

All valves in agroup sampling plan must be tested or examined again, beforethe interval can be extended again, or until the maximum intervalwould be exceeded.

The requirements of ISTA-3120, Inservice Test Interval, do not apply.GL 96-05 reguired 2erodic static and dynamic diaanostic testintrvals The MOV Program is required by condition 10 CFR50.55a(bX3)(ii).

1ST Program Plan Columbia Generating Station 4 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RG01 (Contd.)Reason forRauePursuant to 10 CFR 50.55a, 'Codes and standards,"

paragraph (aX3Xil),

relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request isthat the Code requirement presents an undue hardship without a compensating increase in thelevel of quality of safety.ASME OM Code Section IST establishes the IST frequency for all components within thescope of the Code. The frequencies (e.g., quarterly) have always been Interpreted as"nominar frequencies (generally as defined in the Table 3.2 of NUREG-1482, Revision

2) andOwners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specifications (TS) SurveilMance Requirements (SRs). The TSs typically allow for a less than or equal to 25% extension of the surveillance test interval toaccommodate plant conditions that may not be suitable for conducting the surveillance (SR3.0.2).However, regulatory issues have been raised concerning the applicability of the Technical Specification (TS) "grace perod" to ASME OM Code required IST frequencies irrespective ofallowances provided under TS Administrative Controls (i.e., TS 5.5.6, "Inservice TestingProgram,"

invokes Surveillance Requirement (SR) 3.0.2 for various OM Code frequencies).

The lack of a tolerance band on the ASME OM Code IST frequency resticts operational flexibility.

There may be a conflict where IST could be required (i.e., its frequency couldexpire),

but where it is not possible or not desired that it be performed until after a plantcondition or associated Limiting Condition for Operation (LCO) is within its applicability.

Therefore, to avoid this conflict, the IST should be performed when It can and should beperformed.

The NRC recognized this potential issue in the TS by allowing a frequency tolerance asdescribed in TS SR 3.0.2. The lack of a similar tolerance applied to the ASME OM Codetesting places an unusual hardship on the plant to adequately schedule work tasks withoutoperational flexibility.

Thus, just as with TS required surveillance

testing, some tolerance is needed to allowadjusting ASME OM Code testing intervals to suit the plant conditions and other maintenance and testing activities.

This assures operational flexibility when scheduling IST that minimizes the conflicts between the need to complete the testing and plant conditions.

Progg" fA ft4mt and Bull fr UseColumbia Generating Station proposes to use the ASME OM Code Case OMN-20 aspublished in ASME OM-2012 edition for the fourth ten year interval of IST Program.

The 2012edition of Operation and Maintenance of Nuclear Power Plants, was approved by the ASMEBoard on Nuclear Codes and Standards on December 21, 2012. Code case OMN-20 will beused for determining acceptable tolerances for pump and valve testing frequencies.

The codecase as published in ASME OM-2012 edition is repeated below.

IST Progron Plan Columbia Generating Station 5 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RGOI (Contd.)publshWed OMN.20 Cod. CaseI TEST FREQUENCY GRACEASME OM, Division 1, Section IST and al earlier editions and addenda specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2 years, etc.) or theoccurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenance, etc.).a) Components whose test frequencies are based on elapsed time periods shall be tested atthe frequencies specified In Section IST with a specified time period between tests asshown in Table 1. The specified time period between tests may be reduced or extendedas follows:1) For periods specified as fewer than 2 yr, the period may be extended by up to 25% forany given test.2) For periods specified as greater than or equal to 2 yr, the period may be extended byup to 6 mo for any given test.3) All periods specified may be reduced at the discretion of the owner (i.e., there is nominimum period requirement).

Period extension is to facilitate test scheduling and considers plant operating conditions thatmay not be suitable for performance of the required testing (e.g., performance of the testwould cause an unacceptable increase in the plant risk profile due to transient conditions orother ongoing surveillance, test, or maintenance activities).

Period extensions are notintended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified.

Period extensions may also be applied to accelerated test frequencies (e.g., pumps in alertrange) and other less than 2 yr test frequencies not specified in Table 1.Period extensions may not be applied to the test frequency requirements specified inSubsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-water Reactor Nuclear Power Plants, as Subsection ISTD contains its ownrules for period extensions.

(b) Components whose test frequencies are based on the occurrence of plant conditions orevents may not have their period between tests extended excepts as allowed by ASMEOM, Division 1, Section IST, 2009 Edition through OMa-2011 Addenda and all earliereditions and addenda.

IST Program Plan Columbia Generating Station P o4th 10-Year Interval (Relief Requests Only)Relief Request -RGO1 (Contd.)Table i Specified Test Frequencies Frequeny peci8 fte Time Period Between Tests.(or, 92 daysLrevery 3mot) ______________

___Semiannually 184 days(or every 6 months) ...d. ..Annually(or every year) 368 daysX Years X calendar yearsrWhere X is a whole number of years> 2 Allowing use of the code case OMN-20 will provide reasonable assurance of operational readiness ofpumps and valves subject to ASME OM code 2004 edition through OMb-2006 addenda testingrequirements.

Duration of Prooose AlVrMM#MFourth 10 year interval.

EmadlmThe following similar relief requests for Quad Cities Unit 1 and 2, and Three Mile Island Unit I wereapproved by the NRC.Request Number RV-01 for Quad Cities Units 1 and 2 was approved by the NRC by letter datedFebruary 14,2013 (ADAMS Accession Number ML13042A348).

Request Number VR-02 for Three Mile Island Unit 1 was approved by the NRC by letter datedAugust 15, 2013 (ADAMS Accession number ML13227A024).

1. Code Case OMN-20, Inservice Test Frequency, published in ASME OM-2012 Edition.

,ST Program Plan Columbia Generating Station Po 7 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RPOIin Accordance with 10 CFR 50.55a(aX3XI)

-Alternative Provides Acceptable Level of Quality and Safety -AW rd Lgabst fto" Code PumpPump Class Gu P & ID Dwg. No. System(s)

SW-P-1A 3 A M524, SH I Standby Service WaterSW-P-lB 3 A M524, SH 2 Standby Service WaterHPCS-P-2

.3 A M524, SH 1 Standby Service Water, HIPApoftabb Code Edition and AdkkadsThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code.AAmlicable Codle Reauir-.entM Measure pump differential

pressure, AI. Vertical line shaft centrifugal pumps preservice and inservice testing (ISTB-5210, ISTB-5220, and Table ISTB-3000-1).

Relief is required for Group A andcomprehensive and preservice tests.lftsonfor lnuestThere are no inlet pressure gauges installed in the inlet of these vertical line shaft centrifugal pumps,making it Impractical to directly measure Inlet pressure for use In determirnng differential pressure forthe pump.Proposed Alterntive ajnd Basis fbr U"Pump discharge pressure will be recorded during the testing of these pumps. Code Acceptance Criteria will be based on discharge pressure instead of differential pressure as specified In the CodeTable ISTB-5221

-1. The effect of setting the Code Acceptance Criteria on discharge pressure insteadof differential pressure as specified in the Code will have no negative impact on detecting pumpdegradation.

1. SW-P-1A, I B, and HPCS-P-2 are vertical line shaft centrifugal pumps which are immersed intheir water source. They have no suction line which can be instrumented.

2. Technical Specification SR 3.7.1.1 specifies the minimum allowable spray pond level to assureadequate NPSH and ultimate heat sink capability.

4ST 10-Yerr Plnt Columbia Generating Station P 8 of 404.th 10-Year Interval (Relief Requests Only)Relief Request -RPOI (Contd.)3. The difference between allowable minimum and overflow pond level is only 21 inches of wateror 0.8 pounds per square inch (psi). This small difference, will not be significant to the TestProgram and suction pressure will be considered constant.

Administratively, the pond level iscontrolled within a nine (9) inch band.4. Acceptable flow rate and discharge pressure will suffice as proof of adequate suctionpressure.

5. These pumps operate with a suction lift. Maximum elevation of spray pond level is 434 feet 6inches and minimum elevation of discharge piping for these pumps is 442 feet 5/8 Inches.Thus discharge pressure for these pumps will always be lower than the calculated differential pressure for the entire range of suction pressures.

Thus acceptance criteria based ondischarge pressure is conservative.

This is further illustrated below.Differential pressure is defined as discharge pressure minus suction pressure.

In the case of apump with suction lift the suction pressure is negative, thus:AP = Pd -F PJ)AP = Pd + PSThis concept is more easily understood when head is used instead of pressure.

CASE 1 CASE 2Suton Head Suction LiftSucoHedonP+Wd T Dbchargeis PdHamISTAPOIdrSa*Qfile IST Prorm Plan Columbia Gener ing Station Pap 9of404th 10-Year Interval (Relief Requests Only)Relief Request -RI (Contd.)The ASME Code uses the term differential pressure instead of total head since differential pressure is required to be measured.

However, most literature on pumps deals with hydraulic parameters in terms of head and flow. In case 1:Total Head = Discharge Head -Suction HeedBut in Case 2 (Service Water Pumps)Total Head a Discharge Head + Suction LiftWhen one converts head to pressure, the equivalent formula for diffrential pressure would be:AP(psi) = Pd(psi)+

0.431(psiift) x (ELv(ft)-

EL ~v,=(ft))

Since pump discharge pipe elevation for these pumps is always more than spray pond waterlevel, discharge pressure is always less than the calculated differential pressure.

The effect of setting the Code Acceptance Criteria on discharge pressure instead of differential pressure as specified in the Code provides a more conservative test methodology.

DMurato MI PEr92o2d AlenUlMMFourth 10 year interval.

This relief was granted for the third 10 year Interval.

NRC approval was documented in a letter datedMay 15, 2007 (ADAMS Accession Number ML071010344, TAC No. MD3536) for Relief Request No.RPOI.

ST Pro-ra Plan Columbia Generating Station P 10 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RP02Relief RuMetIn Accordance with 10 CPR 5O.5e(f)(5XIii)

-Inservice Testing Impracticality

-hemdPUMP ode Pump P&Io owg. Number System(s)

PumpClass GrowpSW-P-IA 3 A M524, SH 1 Standby Service WaterSW-P-lB 3 A M524, SH 2 Standby Service watHPCS-P-2 3 A M524, SH 1 Standby Service Water, HPCSMik"Coe EM M dagThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code.L~QULBU~r32U~

Subsection ISTB-5221(b) and ISTB-5223(b).

The resistance of the system shall be varied until theflow rate equals the reference point. The differential pressure shall then be determined and comparedto the reference value. Alternatively, the flow rate shall be varied until the differential pressure equalsthe reference point and the flow rate determined and compared to the reference flow rate value.Relief is required for Group A and comprehensive tests.The establishment of specific reference values is impractical for these vertical line shaft centrifugal pumps.Burde Caused by Compliance

1. Service Water systems are designed such that the total pump flow cannot be adjusted to onefinite value for the purpose of testing without adversely affecting the system flow balance andTechnical Specification operability requirements.

Thus, these pumps must be tested in amanner that the Service Water loop remains properly flow balanced during and after thetesting and each supplied load remains fully operable to maintain the required level of plantsafety.

1ST Prga Pla Columbia Generating Station Page 11 of 404th 10O-Year Interval (Relief Request.

Onl)Relief Request -RP02 (Contd.)2. The Service Water system loops are not designed with a fUl flow test line with a single throttlevalve. Thus the flow cannot be throttled to a fixed reference value. Total pump flow rate canonly be measured using the total system flow indication installed on the common returnheader. Although there are valves in the common return line that are used for throttling totalsystem flow during pre-service

testing, use of these valves is impractical for regular testdue to the potential effect on the flow balance for the safety related loads. Each main loop ofservice water supplies 17-18 safety related loads, all piped in parallel with each other. TheHPCS-P-2 pump loop supplies four loads, each in parallel.

Each pump is independent fromthe others (i.e., no loads are common between the pumps). Each load is throttled to acalculation and surveillance required flow range which must be satisfied for the loads to beoperable.

All loads are aligned in parallel, and all receive service water flow when theassociated service water pump is running, regardless of whether the served component itselfis in service.

During power operation, alt loops (subsystems) of service water are required tobe operable per Technical Specifications.

A loop of service water cannot be taken out ofservice for testing without entering an Action Statement for a Limiting Condition for Operation (LCO) per Technical Specification 3.7.1.3. Each loop of Service Water is flow balanced annually to ensure that all loads are adequately supplied.

A flow range Is specified for each loed. Once property flow balanced, very little flowadjustment can be made for any one particular load without adversely impacft the operability of the remaining loads (increasing flow for one load reduces flow for all the others).

Each timethe system is flow balanced, proper individual component flows are produced, but this in turndoes not necessarily result in one specific value for total flow. Because each load has anacceptable flow range, overall system full flow (the sum of the individual loads) also has arange. Total system flow can conceivably be in the ranges of approximately 9,200 -10,200 gallons per minute (gpm) for SW-P-1A and SW-P-lB pumps and approximately 961 -1,203 gpm for HPCS-P-2 pump. Consequently, the requirement to quarterly adjust servicewater loop flow to one specific flow value for the performance of inservice testing conflicts withsystem design and component operability requirements (i.e., flow balance) as required byTechnical Specification.

PPEd2MAteratve and §l1i for UseAs discussed above, it is impractical to return to a specific value of flow rate or discharge pressure fortesting of these pumps. As stated in NUREG-1482, Rev 2 Section 5.2, some system designs do notallow for testing at a single reference point or a set of reference points. In such cases, it may benecessary to plot pump curves to use as the basis for variable reference points. Code Case OMN-16,"Use of a Pump Curves for Testing,*

is included in draft Revision I of Regulatory Guide(RG) 1.192,"Operations and Maintenance Code Case Acceptability, ASME OM Code.* Flow rate anddischarge pressure are measured during inservice testing and compared to an established reference curve. Discharge pressure instead of differential pressure is used to determine pump operational readiness as described in Relief Request RP01. The following elements ae used in developing andimplementing the reference pump curves. These elements follow the guidance of Code Case OMN-16.

IST Pr@W=m Plan Columbia Generating Station P of 404th 10-Year I (Relief Requests Only)Relief Request -RP02 (Contd.)1. SW-P-1A and SW-P-1B were replaced with new pumps in 2005 and HPCS-P-2 was replacedin 2008. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs. discharge pressure) was established for all three pumps using thepreservice test data.2. Pump curves are based on five or more test points beyond the flat porlton of the curve(between 6000 gpm and 10200 gpm for SW-P-1A and 18 pumps and between 650 and 1200gpm for HPCS-P-2 pump). The pumps are being tested near full design flow rate.3. Temporary test gauges (1 0.5% full scale accuracy) were installed to take discharge pressuretest data in addition to plant installed gauges, and Transient Data Acquisition System (TDAS).TDAS data averages 100 readings with a reading taken each second. All Instruments usedeither met or exceeded the Code required accuracy for Group A and comprehensive pumptest.4. The reference pump curves are based on flow rate vs. discharge pressure.

Acceptance criteria curves are based on differential pressure limits given In Table ISTB-5121-1 forapplicable test type. Setting the Code Acceptance Criteria on discharge pressure usingdifferential limits is slightly more conservative for these pump installations with suction lift(Relief Request RP01). See the attached sample SW-P-1A pump Acceptance Criteria sheetfor Group A test. Area 1-2-5-6 is the acceptable range for pump performance.

Area 3-4-5-6defines the Alert Range, and the area outside 1-2-3-4 defines the required Action Range.5. Similar reference curves are used for comrnehenslve pump tests using the applicable acceptance criteria and instrument accuracy and range requirements.

6. Only a small portion of the established reference curve is being used to bind the flow ratevariance due to flow balancing of various system loads. See the attached sample SW-P-1Apump Acceptance Criteria sheet for Group A test.7. A single reference value shall be assigned for each vibration measurement location.

Theselected reference value shall be at the minimum data over the narrow range of pump curvesbeing used as required by Code Case OMN-16.8. When the repair, replacement, or routine servicing of a pump may have affected a reference curve, a new reference curve shall be determined, or the existing reference curve reconfirmed, in accordance with pare. 16-3310 of Code Case OMN-16.9. If It is necessary or desirable, for some reason other than that stated In para. 16-3310 of CodeCase OMN-16, to extend the current pump curve or establish an additional reference curve,the new curve(s) must be determined in accordance with para. 16-3320 of Code Case OMN-16.

iST Program Plan Columbia Genertng Station Page 13 of°404th 10-Year Interval (Relief Requests Only)Relief Request -RP02 (Contd.)Qualbtlafed ImwThe desin of the Gq ba Gener hatiorSevioe Water syMem and the-Tehia Specifcation requirements e i impractical to a:just system flow to a fixed, referenoe value for inservice testingwithout ad "Vsel WVln the system flow and Technical Specification operability requiremen(s The propioN altemate testing using a referenoe pump curve for each pump providesadequate qsurance and accura"Qn mront pump coration to, assessi pump operational readiness dntl shall, adequately detedt- 0 degradation.

Altbmate ktstn will have nO adverseimpact on plant and public safety.Duraton of MgIS Atlftm te Fourth 10 year interval.

1~,iSimilar rneie as granted for the third 10 year interval.

NRC )pproval was docmoented in a letterdated May (ADAMS AcceSsion Nuber ML 071019343, TAC No. 4!D3540) for ReliefRequest No, 0P03. I'4i4-'.

4ST P0.=, fnt Columbia Generating Station P 14 of 404th 10-Year I (Relief Requests Only)Relief Request -R@ (Contd.)SAMPLE DATA SHEET -GrouD A TestSW-P-1A ACCEPTANCE CRITERIASW4 JA ACCEPTANCE Q ITERIA240235230225LIUI2202152102052O0t95190185180 4"9.3309A30 9,530 9,6309,730 9.830 9.930 10,030 10,130 10,230FLOW -GPMALERT RANGE st Area Inside 3-4-54ACTION RANGE a Area Outside 1-2-3-4 4ST Program Plan Columbia Generating Station Pag. 15 of 404th 10-Year Interval(RleRq etOny(Relief Request*

Only)Relief Request -RPo3R"le R*sT"In Acodnce elwith 10 FRu 5Use.Saf(X.I)

-inservice Tesng impracticality

-A6WI Code Compbrwnta

,&MbtlPump Code Class Pump Group MSysem(s)

____ ___ ___ ___ ___ ___ Number ____ ___ ____ ___LPCS-P-1 2 B M52 Low Pressure Core SprayRHR-P-2A 2 A M521, SH IRHR-P-2B 2 A M521, SH 2 Residual Heat RemovalRHR-P-2C 2 A M521, SH 3HPCS-P-1 2 B M520 High Pressure Core SprayRCIC-P-1 2 B M519 Reactor Core Isolation ColngF = ZIP" 7716ý17 71 -wrl Ilk'. 7-IT"71",

UT-77771The 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code.A1mimb C2111RCIC-P-1 (Centrfuos B=o~Grou B Tet: Subsection ISTB-5122(a).

ISTB-5122(b) and ISTB-5122(c).

The pump shall beoperated at a speed adjusted to the reference point (11%) for variable speed drives. The differential pressure or flow rate shall be determined and compared to its reference value. System resistance may be varied as necessary to achieve the reference pointCom-rsir Test: Subsecton ISTB-123(a) and ISTB-5123Mb).

The pump shall be operated at aspeed adjusted to the reference point (t1 %) for variable speed drives. The resistance of the systemshall be varied until the flow rate equals the reference point. The differential pressure shall then bedetermined and compared to its reference value. Altematively, the flow rate shall be varied until thedifferential pressure equals the reference point and the flow rate determined and compared to thereference flow rate value.Other Pures (Vertl line Shaft Cenfugal Pures):Grou2 B Test for LPCS.P-1 and HPCS-P-1:

Subsection ISTB-5222(b) and ISTB-6222(c).

Thedifferential pressure or flow rate shall be determined and compared to Its reference value. Systemresistance may be varied as necessary to achieve the reference point.Groug A Test for RHR-P 2A. 26 AND 2C and Comorehensive Test for all g=ons exceot RCIC-P-1:

Subsection ISTB-5221b and ISTB-5223(b).

The resistance of the system shall be varied until theflow rate equals the reference point. The differential pressure shall then be determined and comparedto its reference value. Alternatively, the flow rate shall be varied until the differential pressure equalsthe reference point and the flow rate determined and compared to the reference flow rate value.

1ST Program Pftn Columbia Generating Station Pop 16 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RPO3 (Contd.)The establishment of specific reference values Is impractical for these pumps.Burden Causd by rdRUReference values are defined as one or more fixed sets of values of quantities as measured orobserved when the equipment is known to be operating acceptably.

All subsequent test results are tobe compared to these reference values. Based on operating experience, flow rate (Independent variable during Inservice testing) for these pumps cannot be readily duplicated with the existing flowcontrol systems.

Flow control for these systems can only be accomplished through the operation ofrelatively large motor operated globe valves as throttling valves. Because these valves are notequipped with position indicators which reflect percent open, the operator must repeatedly jog themotor operator to try to make even minor adjustments in flow rate. These efforts, to exactly duplicate the reference value, would require excessive valve manipulation which could ultimately result Indamage to valves or motor operators.

B=2Wse Alternativnd BAMsI"& for UseAs discussed above, it is impractical to return to a specific value of flow rate, or differential pressurefor testing of these pumps. As stated in NUREG-1482, Rev 2 Section 5.2, some system designs donot allow for testing at a single reference point or a set of reference points. In such cases, it may benecessary to plot pump curves to use as the basis for variable reference points. Code Case OMN-16,"Use of a Pump Curves for Testing,"

is included in draft Revision 1 of RG 1.192,"Opeeations andMaintenance Code Case Acceptability, ASME OM Code."Since the independent reference variable (flow rate) for these pumps Is impractical to adjust to a fixedreference value and requires excessive valve manipulation, the maximum variance shall be limited tot2% of the reference value. Thus, flow rate shall be adjusted to be within + 2% of the reference flowrate and the corresponding differential pressure shall be measured and compared to the reference differential pressure value determined from the pump reference curve established for this narrowrange of flow rate. Slope of the pump reference curve Is not flat even over this narrow range of flowrate. Assuming the flow rate to be fixed over this narrow range can result in additional error incalculating the deviation between the measured and reference differential pressure and at times thisdeviation can be non-conservative.

Since the dependent variable (differential pressure) can beassumed to vary linearly with flow rate in this narrow range, establishing multiple reference points inthis narrow range is similar to establishing a reference pump curve representing multiple reference points. This assumption of linearity between differential pressure and flow rate is supported by themanufacturer pump curves in the stable design flow rate region.

h 10-Yearn PI n Columbia Generating Station Page 17of 404th 10-Year Interval (Relief Requests Only)Relief Request -RP03 (Contd.)The following elements are used in developing and Implementing the reference pump curves. Theseelements follow the guidance of Code Case OMN-16.1. RHR-P-2B was replaced with a new pump in 2013. A preservice test as required by theASME OM Code was performed and a reference pump curve (flow rate vs. differential pressure) was established for this pump using the preservice test data. A similar reference pump curve (flow rate vs differential pressure) has been established for RHR-P-2A and RHR-P-2C pumps from data taken on these pumps when they were known to be operating acceptably.

These pump curves represent pump performance almost identical tomanufacturers test data.2. For RCIC-P-1, a variable speed drive pump, flow rate is set within +/-2% of the reference flowrate and the reference curve is based on speed with acceptance criteria based on differentel pressure.

This Is done because of the imnprcticaty of sotlng speed to a specific reference value to achieve the desired flow rate and pump discharge pressure.

See the attachedsample RCIC-P-1 pump Acceptance Criteria sheet for Group B test. Additionally, evaluation ofthe manufacturer pump data, preoperational and special test data used to establish the pumpreference curve indicates Insignificant change in differential pressure with small variation inflow rate.3. HPCS-P-1 was replaced with a new pump in 2007. A preservice test as required by the ASMEOM Code was performed and a reference pump curve (flow rate vs. differential pressure) wasestablished for this pump using the preservice test data.4. For LPCS-P-1 pump, the reference pump curve is based on the manufacturer pump curve thatwas validated during preoperational testing using 5 or more test points beyond the flat portionof the curve.5. Residual Heat Removal (RHR), High Pressure Core Spray (HPCS) and Reactor Core Isolation Cooling (RCIC) pump curves are based on five or more test points beyond the flat portion ofthe curve. These ECCS pumps have minimum flow rate requirements specified in Technical Specifications and are being tested near these flow rates.6. Temporary test gauges (:t 0.5% full scale accuracy) were installed to take suction anddischarge pressure test data in addition to plant installed gauges and Transient DataAcquisition System (TDAS). TDAS date averages 100 readings with a reading taken eachsecond. All instruments used either met or exceeded the Code required accuracy forapplicable Group A, Group B and comprehensive pump test.7. Review of the pump hydraulic data trend plots Indicates close correlation with the established pump reference curves, thus further validating the accuracy and adequacy of the pump curvesto assess pumps operational readiness.

8. Acceptance criteria curves are based on differential pressure limits given in applicable TableISTB-5121-1 or Table ISTB-5221-1.

See the attached sample RHR-P-2A pump Acceptance Criteria sheet for Group A test. Area 1-2-5-6 is the acceptable range for pump performance.

Area 3-4-5-6 defines the Aled Range and the area outside 1-2-3-4 defines the required Action IST Program Plan Columbia Generating Station Pa 18 of 40O4th 10-Year Interval (Relief Requests Only)Relief Request -RP03 (Contd.)Range. A similar sample RCIC-P-1 pump Acceptance Criteria sheet for Group 8 test is alsoattached.

9. Similar reference curves will be used for m rhen.ve p ui n10. Only-44 Sn* pk~toq of the established wreferewie 4urve is bi"n tsed to accommodate flowrate wgria+ce.

ea u sample pump c ptce Criteria shetp.11. Asr eeeievalueý,

be Ossigned fbr e8ch votwaon measurement Ioctln. Thrife, value SAWIW+t rnim dgta o4e the naw angd of pomp owvesbeing se as required by Code e112. Wheaý jhe repa.re~acement,

'or rmitine'seryVIn of a pumrp' mayi havO affected a reference curv4, is nw referenpe cMrv sWaW be d=etprmird, C*4h xistin reference curve reconflrrned, in accqrdace witp .16-330 of Code CsO .-is,13. If it carY or dcir", for sofie reason othe than that staitac n para. 16-3310 o CodeCase ýt extendý the current pu*N curve or estWblsh an addlUDws reference curve,the CW ¶n~t be, determined In Occoidlanco with para. 1643320 of Code Case OMN-16.Due to impQ adjusting indeoendqt vu hailA rates, and speedfo ailkrveRI pump) to a irferefor alue rvr tet ihe.system modifications, alt~ernate testing tovary thee vae~~e ovor a 40ry,. narroW range (tup to +/- %% eetec values) ind using pumpreference ciwves r Us,. narrow 1 is proposed.

Alternate testineis-ng a rePerence PUm P curvefor each puiip pbvid a. ~ ..pote a o*Ufoe ard accursqy In H + condition to assesspump operational readiness and wip adequef4~tect pump degaain elq~ttesting will haveno adverse impact on plant and publt htife 1.Fourth 10 year interval.'

Pemgogden Similar relief was granted for the third 10 year W:ter1. NRC approval was docufiVlPte4 In letterdated March 23, 2007 (ADAMS Accession Nurn:e$MLOTO600I 11, TAO No. MVDb6353740rellef Request No. RPO4.

4ST Progrval Columbia Generating Station P 19 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RP03 (Contd.)SAMPLE DATA SHEET. GroQ A TestRHR-P-2A ACCEPTANCE CRITERIA£z13113012912812712612512412312212112011911811711611511411311211111010910t1071061051041031021011009998979695"- -------..-....... ----------- -------.", I ..... " 2.. .-. .-...i -i. .... i .... i-.. I .. ... .. .*W M.. .. ... .1 * ..i.749C7500 7510 7520 7530 7540 7550 7560 7570 7580 7590 7600 7610 7620 7630 7640 7650INDICATED FLOW -GPMALERT RANO -- Area IsW 3-4--6 ACTION RANGE: Arem Outside 1-2-3-4 4th 0Ye Planter Columbia Generating Station4th 10-Vewteml (Relief Requests Only)Relief Request -RP03 (Contd.)AM E DATA SHEET -GM B TestRCIC-P-1 ACCEPTANCE CRITERIAIIU51335-au1211325IMIMUnim12"IM1117511NOl1is1120I1ls11011075106100 4"S4410134430 44S0 4470 44W 4510 4S30PUMP/TUFSNE SPEED (RPM)ACTION RANGE a Area Outside 1-2-3-44SSO 470 4590 IST Pmr am Plan Columbia Generating Station Pag 21 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RP04Proponed Afterna9In Accordance with 10 CFR SO.5g(aX3XI)

Alternative Provides Acceptable Level of Quality and Safety,AMC Code 92=200ne Pump Code Class Pump Group Nu mStsRHR-P-2A2 AM52, Number _RHR-P-2A 2 A M521, SH IRHR-P-2B 2 A M521, SH 2 Residual Heat RemovalRHR-P-2C 2 A M521, SH 3HPCS-P-1 2 I M20 High Pressure Core Spry=-, -I 1771 7,'Xvý 71 4 '-! 77, = i -F.77 ý 7 77,The 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code./lmlAlWW"Code R elomISTB-351j0bW1L.

Ranae. The full- scale range of each analog instrument shall be not greater thanthree times the reference value.Reason for ReouesInstalled test gauges used to measure the pump discharge

pressure, which is used to determine differential

pressure, do not meet the Code range requirements.

Residual Heat Removal (RHR) andHigh Pressure Core Spray (HPCS) Pumps discharge pressure instruments (RHR-PT-37A, RHR-PT-378, RHR-PT-37C, and HPCS-PT-4),

exceed or may exceed (dependent upon measuredparameters),

the Code allowable range limit of three times the reference value. Relief is required forGroup A, Group B inservice test and preservice test only. Temporary test gauges meeting the Coderequirements shall be used for the comprehensive test.Proposed Aftwmaidus and Basis for UseDuring Group A or Group B pump inservice

testing, pump discharge pressure which Is used todetermine differential pressure shall be measured by respective Transient Date Acquisition Data(TDAS) points listed below for each pump. TDAS data averages 100 readings with a reading takeneach second.1. ISTB-3510(a) and ISTB-3510(bX1) specify both accuracy and range requirements for eachinstrument used in measuring pump performance parameters.

The purpose of instrument requirements is to ensure that pump test measurements are sufficiently accurate andrepeatable to permit evaluation of pump condition and detection of degradation.

Instrument accuracy limits the inaccuracy associated with the measured test data. Thus, higherinstrument accuracy lowers the uncertainty associated with the measured data. The purposeof the Code range requirement is to ensure reading accuracy and repeatability of test data.

iST Program Plan Columba Generat Statn Page 22 of 404th 10-Y intear v(Relief Requests Only)Relief Request -RP04 (Contd.)2. Since the TDAS data is being obtained to an accuracy of t1% of full scale, it consistently yields measurements more accurate than would be provided by itrument meeting the Codeinstrument accuracy requirement of f 2% of full scale and range requirement of three timesthe reference value. Equivalent Code accuracy being obtained by TDAS measurements iscalculated in the table below.*Rof. Instrument Test Instrument Range Value Loop Equivalent CodePump Parameter I.D. (PSIG) (PSIG) Accuracy AccuracyRHR-P-2A Discharge RHR-PT-:37A 0-6. 0 136

• 1%, [6/(3x136))xlOO Pressure TDAS PT 155 t 6 psig =1.47%RHR-P-2B Discharge RHR-PT-378 0-600 148

• 1%, [6/(3x148)jx1OO Pressure TOAS PT 076 -8 Pslg =1.36%RHR-P-2C Discharge RHR-PT-37C 0-400 143 t 1%, j6/(3x143)1x100 Pressure TOAS PT 091 16 EN =1.40%HPCS-P-1 Discharge HPCS-PT-4 0-1500 465 + 1%, [15/(3x465)jx1OO

.... ___Pressure TDAS PT 107 .... *15psig =1.08%*The above table reflects latest reference values as specified in the implementing procedures.

This table winnot be updated to reflect small changes in future reference values.Thus, the range and accuracy of TDAS instruments being used to measure pump discharge pressure result in data measurements of higher accuracy than that required by the Code andthus will provide reasonable assurance of pump operational readiness.

It should also be notedthat the TDAS system averages many readings, therefore giving a significantly more accuratereading than would be obtained by using the averaging technique as allowed by ISTB-3510(d) on visual observation of a fluctuating test gauge.3. The range of the pressure transmitters (PTs) used for these applications were selected tobound the expected pump discharge pressure range during all normal and emergency operating conditions (the maximum expected discharge pressure for the RHR and HPCSpumps is approximately 450 psig and 1400 psig respectively).

However, during inservice testing the pumps are tested at full flow, resulting in lower discharge pressures than theelevated discharge pressure that can occur during some operating conditions.

For this reasonthe pump reference value Is significantly below the maximum expected operational discharge pressure.

A reduction of the range of the PTs to three times the reference value would, Inthese cases, no longer bound the expected discharge pressure range for these pumps, andtherefore is not practicable.

If a PT were to fail, a like replacement would have to be used dueto the above identified reasons of replacing a PT with one not suited for all pump flowconditions.

However, this is not a concern because the existing instrumentation providespump discharge pressure indication of higher accuracy and better resolution than that requiredby the Code for evaluating pump condition and detecting degradation.

1ST Prowam Plmn Columbia Generating Station P 23 of 404th 10-Year Interval (Relief RequestS Only)Relief Request -RP04 (Contd.)4. NUREG-1482, Revision 2 Section 5.5.1 states that when the range of a permanently installed analog instrument is greater than three times the reference value, but the accuracy of theinstrument is more conservative than that required by the Code, the [NRC] staff may grantrelief when the combination of the range and accuracy yields a reading that is at leastequivalent to that achieved using instruments that meet the Code requirements (i.e. up to

• 6percent for Group A and B tests, and +/- 1.5 percent for pressure and differential pressureInstruments for Preservice and Comprehensive tests).TDAS data will consistently provide acceptable accuracy to ensure that the pumps are performing atthe flow and pressure conditions to fulfill their design function.

TOAS data Is sufficiently accurate forevaluating pump condition and in detecting

-pump degradation.

The effect of granting this reliefrequest will have no adverse impact on plant and public safety. Test quality will be enhanced byobtaining slightly better, more repeatal data.2ur0tio Of Astwnathm Fourth 10 year interval.

This relief was granted for the third 10 year interval.

NRC approval was documented in a letter datedMarch 23, 2007 (ADAMS Accession Number ML 070600111, TAC No. MD3538) for Relief RequestNo. RPO5.

IST Proim Pla Columbia Generatinig Station Pag 24 of 404th 10-Year Intrval (ORele Requests Only)Relief Request -RPOSIn Accordanc.

with 10 CFR S0.55SaX3XIi)

-Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety --- 2=Pump Code Class Pump Group P&ID Dwg. No. System(s)

SLC-P-IA 2 B M522 Stk LUquidSLC-P-1B 2 B M522 ControlAnliabe gf &W ndM AddedThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM CodeApplicalbe Code Roguiryameat Subsection ISTB-3550.

When Measuring flow rate, a rate or quantity meter shall be installed in thepump test circuit.

If a meter does not Indicate the flow rate directly, the record shall include themethod used to reduce the date.Subsection ISTB-5300(a).

(1) For the Group A test and the comprehensive test, after pumpconditions are as stable as the system permits, each pump shall be run at least 2 min. At the end ofthis time at least one measurement or determination of each of the quantities required by Table ISTB-3000-1 shall be made and recorded.

(2) For the Group B test, after the pump conditions are stable, atleast one measurement or determination of the quantity required by Table ISTB-3000-1 shall be madeand recorded.

Relief is required for Group B and comprehensive and preservice tests.Reason for RaueatlA rate or quantity meter is not installed in the test circuit.

To have one installed would be costly andtime consuming with few compensating benefits.

As a result of a rate or quantity meter not being installed in the test circuit, it Is impractical to directlymeasure the flow rate for the Standby Liquid Control pumps. Therefore, the requirement for allowinga 2 minute "hold" time for Pump tests is an unnecessary burden which would provide no additional assurance of determining pump operational readiness.

IST Prograr Plan' Columbia Generating Station P 25 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RPOI (Contd.)-UWSUNUREG-1482, Revision 2 Section 5.5.2 states, "requiring licensees to install a flow meter to measurethe flow rate and to guarantee the test tank size, such that the pump flow rate will stabilize in2 minutes before recording the data would be a burden because of the design and installation changes to be made to the existing system. Therefore, compliance with the Code requirements wouldbe a hardshe~.

Pump flow rate will be determined by measuring the volume of fluid pumped and dividingcorresponding pump run time. The volume of fluid pumped will be determined by the difference influid level in the test tank at the beginning and end of the pump run (test tank fluid level corresponds to volume of fluid in the tank). The pump flow rate calculation methodology meets the accuracyrequirements of OM Code, Table ISTB-3510-1.

The pump flow rate calculation Is identified on therecord of test and ensures that the method for the flow rate calculation yields an acceptable means forthe detection and monitoring of potential degradation of the Standby Liquid Control Pumps andtherefore, satisfies the intent of the OM Code Subsection ISTB.In this type of testing, the requirement to maintain a 2 minute hold time after stabilization of thesystem is unnecessary and provides no additional increase of the ability of determining pumpcondition.

The test tank fluid volume is approximately 236 gallons.

The measured flow rate Is approximately 43gpm. The accuracy of the level reading Is +/- 1/8 inch. The accuracy of volume or level change is t1/4inch (1/8 inch at initial level and 1/8 inch at final level). The pump is required to be run for a minimumtime to ensure that an 18 inch change of test tank level has occurred.

This is to ensure that the Coderequired accuracy for flow rate measurement of t2 percent is satisfied.

A 2% error over 18 inchescorresponds to 0.36 inches that is greater than 0.25 inches. The test methodology used to calculate pump flow rate will provide results consistent with Code requirements.

This will provide adequateassurance of acceptable pump performance.

Calculation methods are specified in the surveillance procedures for the Standby Liquid ControlPumps, and meet the quality assurance requirements for the Columbia Generating Station.Duration Of Pro9ose A~MMtiFourth 10 year interval.

Similar relief was granted for the third 10 year interval.

NRC approval was documented in a letterdated May 15, 2007 (ADAMS Accession Number ML071010344, TAC No. M03548) for ReliefRequest No. RP06.

4ST 1-ar Int Columbia Generating Station Pop 26 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RP06In Accordance with 10 CFR 50.55(a(X3XI)

-Alternative Provides Acceptable Level of Quality and Safety -ASME Code CMM AffgteDeg BasisPump Code Class Pump Group Accident Flow Test Flow Rate (GPM)rate (GPM)FPC-P-1A 3 A *575 595 to 605FPC-P-1B 3 A *575 595 t0 605HPCS-P-1 2 B 6M 0 p 65.0 to 6690HPCS-P-2 3 A *1022 1030 to 1 180LPCS-P- .2 B 5625@I22p 6435 to 6830RCIC-P-1 2 a 600 610 to 628RHR-P-2A 2 A 7034 0 0 psid 7493 to 7550RHR-P-2B 2 A 70 a 0 e!!5 7493 to 7550RR-P-2C 2 A 7034 0 0 psid 7493 to 7650SLC-P-IA 2 B 41.2 GE 41.49SLC-P-1B 2 8 41.2 GE 41.49SW-P-1A 3 A *8928 9350 to 10270SW-P-IB 3 A 8880 9350 to 10270*These values are design flow rates rather than design basis accident flow rates./m-m Code it 7 7The 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code.Aplnabte Code Roim mIST 123WI. Comprehensive Test Procedure refers to Table ISTB-5121-1 "Centrifugal Pump TestAcceptance Cdteia" that requires "Required Action Range" High limit of 3% above the established reference value for the measured hydraulic value of differential pressure or flow rate for theComprehensive Test.S-,L, Comprehensive Test Procedure refers to Table ISTB-5221-1 Vertical Line ShaftCentrifugal Pump Test Acceptance Criteria that requires "Required Action Range" High limit of 3%above the established reference value for the measured hydraulic value of differential pressure or flowrate for the Comprehensive Test.

lST Program Plan Columbia Gonerating Station P 27 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RPW (Contd.)I, Comprehensive Test Procedure refers to Table ISTB-5321-2 Reciprocating PositiveDisplacement Pump Test Acceptance Criteria that requires "Required Action Range" High limit of 3%above the established reference value for the measured hydraulic value of discharge pressure or flowrate for the Comprehensive Test.For some comprehensive pump tests, Energy Northwest had difficulty in Irmpementing the highrequired action range limit of 1.03% above the established hydreul parameter reference value due tonormal data scatter.

Energy Northwest had to develop contingency plans in the pump operability surveillance procedures In the event the pump enters the action high range and is declared Inoperable and applicable Technical Specification LCO entered for reasons other than a pump degradation issue.Based on the sinilar difficulties experienced by other Owners, ASME OM Code Case OMN-19 wasdeveloped and has been published in the ASME OM-2012 edition.

The white paper for this codecase, Standards Committee Ballot 09-810, record 09457, discussed the impact of instrument inaccuracies, human factors involved with setting and measuring test parameters, readability ofgauges and other riscellaneous factors on the ability to meet the 1.03% acceptance criteria.

Industryoperating experience is also discussed in the white paper.Code Case OMN-19 has not been approved for use in RG 1.192, "Operations and Maintenance CodeCase Acceptability, ASME OM Code."Columbia Generating Station proposes to use the ASME OM Code Case OMN-19 as published inASME OM-2012 edition for the fourth ten year interval of IST Program.

The 2012 edition of Operation and Maintenance of Nuclear Power Plants, was approved by the ASME Board on Nuclear Codes andStandards on December 21, 2012. ASME OMN-19 code case allows the use of a multiplier of 1.06times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test's upper"Acceptable Range" critera and "Required Action Range, High" criteria referenced in the applicable ISTB test acceptance criteria tables ISTB-5121-1, ISTB-5221-1, and ISTB-5321-2.

As stated In the Standards Committee Ballot white paper, this issue was also discussed at theASMEJNRC special meeting on June 4h, 2007. The NRC questioned the basis for the upper requiredaction limits. The inaccuracies that are the basis for the change as discussed In the white paper aresummarized below.1. Instrument Inaccuracies of measured hydraulic value.2. Instrument inaccuracies of set value and its effect on measured value.3. Instrument Inaccuracies and allowed tolerance for speed.4. Human factors involved with setting and measuring flow, D/P, and speed.5. Readability of Gauges based on the smallest gauge Increment.

6. Miscellaneous Factors.

iST Prorm Ple Columbia Generating Station P 28 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RP06 (Contd.)The above discussed inaccuracies associated with obtaining the comprehensive pump test hydraulic data may easily cause the measured value to exceed the existing code allowed upper required actionlimit of 3%. The new upper limit of 6% as approved in the code case OMN-19 will eliminate declaring the pump inoperable and entering unplanned Technical Specification LCO.The mandatory Appendix V pump periodic verification test program has been published in ASME OM-2012 edition.

This mandatory appendix contains requirements to augment the rules of subsection ISTB for inservice testing of pumps. It also states that the Owner is not required to perform a pumpperiodic verification test if the design basis accident flow rate In the Owner's safety analysis Isbounded by the comprehensive pump test or Group A test. As specified in the pump table above, thequarterly Group A or B and biennial comprehensive tests bound the verification of pump design basisflow rate and associated differential pressure or discharge pressure for positive displacement pumps.Using the upper limit of 1.06 times the reference value in lieu of the 1.03 multiplier for thecomprehensive pump test's upper "Acceptable Range' criteria and *Required Action Range, High"criteria referenced in the applicable ISTB test acceptance criteria tables will provide adequateindication of pump performance and continue to provide an acceptable level of quality and safety.Each pump performance Is also monitored by subsection IST1 required quarterly applicable Group Aor Group B test that verifies operational readiness of the pump. The quarterly Group A or B pump testand biennial comprehensive pump test bounds the verification of pump design basis flow rate andassociated dtfferential or discharge pressure as applicable.

DurMon gm PMogM AlenFourth 10 year interval.

None1. Code Case OMN-19, Alternative Upper Limit for the Comprehensive Pump Test. Published InASME OM-2012 Edition.2. Division 1, Mandatory Appendix V Pump Periodic Verification Test Program.

Published InASME OM-2012 Edition.3. White Paper for ISTB Code Change, December

/ 2007, [Standards Committee Ballot 09-610,Record 09-657) Change C, A relaxation of the high required action range for theComprehensive Pump Test Hydraulic Parameters (1.03 to 1.06) iST 9w f" Columbia Generating Station Page 29 of 404th 0-Yar nteval(Relief Requests Only)Relief Request -RVOIReiRe- RequestIn Aecodance with 10 CFR S.Wens)(SI)

-Inservice Testing Impractalty

-ASME Cde aMMA9WM ffutAffected Class Cat. Function System(s)

CVB-V-IAB, 2 AC To break vacuum on the drywell to suppression CVB-V-ICD, chamber downcomers and to limit steam leakageCVB-V-1EF, from the downcomer to the wetwel gas space.CVB-V-IGH, Primary Containment CVB V.JLM, Cooling and PurgeCVB-V-INP, CVB-V-IQR, CVB-V-IST hNNOW Code 9d" and MMAThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM CodeAgglicabile Code Reguirement OM Subsection ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves.imorlticality of omuisnceThese check valves cannot be tested individually therefore, assigning a limiting leakage rate for eachvalve or valve combination Is not practical.

Burdn Cause kv ComoUManca Subsection ISTC-3630 requires Category A valves, other than containment isolation valves, to beindividually leak tested at least once every two years. Each vacuum relief valve assembly consists oftwo independent testable check valves In series with no instrument located between them to allowtesting of each of the two check valves. Therefore, leak testing in accordance with the Code isimpractical.

Modifications to allow individual testing of these valves would require a major systemredesign and be burdensome.

pudui AM n for UseThese valves will be leak tested in accordance with Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR 3.6.1.1.3, and SR 3.6.1.1.4 during refueling outages.

4ST Program Pint Columbia Generating Station P 30 404th 10-Year Interval (Relief Requests Only)Relief Request -RVOI (Contd.)Technical Specifications SR 3.6.1.1.2 drywell-to-suppression chamber bypass leakage test monitorsthe combined leakage of three types of pathways:

(1) the drywell floor and downcomers, (2) pipingexternally connected to both the drywell and suppression chamber air space, and (3) the suppression chamber-to-drywell vacuum breakers.

The test frequency is 120 months and 48 months following onetest failure and 24 months if two consecutive tests fail until two consecutive tests are less than orequal to the bypass leakage limit.Technical Specifications SR 3.6.1.1.3 establishes a leak rate test frequency of 24 months for eachsuppression chamber-to-drywell vacuum breaker pathway, except when the leakage test ofSR 3.6.1.1.2 has been performed (Note to SR 3.6.1.1.3).

Thus, each suppression chamber-to-drywall vacuum breaker pathway will have a leak test frequency of 24 months by either SR 3.6.1.1.2 orSR 3.6.1.1.3.

Technical Specifications SR 3.6.1.1.4 establishes a leakage test frequency of 24 months to determine the suppression chamber-to-drywell vacuum breaker total bypass leakage, except when the bypassleakage test of SR 3.6.1.1.2 has been performed (Note to SR 3.6.1.1.4).

Thus, the determination ofsuppression chamber-to-drywell vacuum breaker total leakage will have a leak test frequency of24 months by either SR 3.6.1.1.2 or SR 3.6.1.1.4.

These valves are also verified-closed by position indicators, exercised, and tested in the opendirection using a torque wrench per Technical Specification SR 3.6.1.7.1, SR 3.6.1.7.2, andSR 3.6.1.7.3.

In accordance with a separate commitment, the valves are visually inspected eachrefmling outage.aualftfstf InMatThe leakage criteria and cormective actions specified in the Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR 3.6.1.1.3, and SR 3.6.1.1.4 combined with visual examination of valveseats every refuel outage provides adequate assurance of the relief valve assembly's ability to remainleak tight and to prevent a suppression pool bypass. Thus, proposed alternatlve provides adequateassurance of material quality and public safety.Duration m ft ggm Alte veFourth 10 year interval.

This relief was granted for the third 10 year interval.

NRC approval was documented in a letter datedMay 15, 2007 (ADAMS Accession Number ML 071010344, TAC No. MD3549) for Relief Request No.RVO1.Letter dated February 9, 2007, Carl F. Lyon (NRC) to J. V. Parish (Energy Northwest),

"Columbia Generating Station -Issuance of Amendment RE: Suppression Chamber-to-Drywell VacuumBreakers and Drywell-to-Suppression Chamber Bypass Leakage Test (TAC No. MD1225)".

1ST Man Columbia Generating Station P 31 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RV02Proposed AhltftIn Accordance with 10 CFR 50.S5(s)X3Xl)

-Alternative Provides Acceptable Level of Quality and Safety -am ode ominMe AffAffected Valves Class C.t. Function nssxsL)PSR-V-X73-1 2 APSR-V-X80-1 2 APSR-V-X83-1 2 APSR-V-X77A1 I APSR-V-X82-1 2 A Containment Isolation Post Accident SamplingPSR-V-X84-1 2 APSR-V-X77A3 1 APSR-V-X82-7 2 APSR-V-X88-1 2 AV77-M7=77,

ýMT-rv =7 tThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM CodeQM Subsecton SoertdOg erateMd YAMas SIM TestingReason for ReouastSubsection ISTC-5151(c) requires the stroke time of all solenoid-operated valves to be measured toat least the nearest second. These nine PSR solenoid valves are the inboard Containment Isolation Valve for nine different penetrations and are operated from a single keylock control switch. It isimpractical to measure the individual valve stroke times. To do so would require repetitive cycling ofthe control switch causing unnecessary wear on the valves and control switch with little compensating benefit.

4ST lO-rw Int Columbia Generating Station P4th 10-Year I l (Relief Requests Only)Relief Request -RVO2 (Contd.)ProMo" Abktwna End BA" &Lr UnAll of these solenoid valves stroke in less than 2 seconds and are considered Fast-Acting valves.Their safety function Is to close to provide containment isolation.

The stoke time of the slowest valvewill be measured by terminating the stroke time measurement when the last of the nine indicating lights becomes illuminated.

If the stroke time of the slowest valve is in the acceptance range (lessthan or equal to 2 seconds),

then the stroke times of all valves will be considered acceptable.

However, if the stroke time of the slowest valve exceeds the acceptance criteria (2 seconds),

all 9valves will be declared inoperable and corrective actions in accordance with Subsection ISTC-5153 taken. After corrective

actions, the required reference values shall be established in accordance withISTC-3300.

Also any abnormality or erratic action shall be recorded and an evaluation shall be maderegarding need for corrective action as required by ISTC-5151(d).

2uAWLftv/know The proposed alternate testing will verify that the valves respond in a timely manner and provideinformation for monitoring signs of material degradation.

This provides adequate assurance ofmaterial quality and public safety.bmm=777 mFourth 10 year interval.

Similar relief was granted for the third 10 year Interval.

NRC approval was documented In a letterdated March 23, 2007 (ADAMS Accession Number ML 070600111, TAC No. MD3550) for ReliefRequest No. RV03.

1ST Program Plan Colu a Generating Station Page 33 of 404th 10-Year Interval (Relief RG quese t Only)Relief Request -RV03Proosed Alternativ in Accordance with 10 CFR SO.-55aX3XI)

-Alternative Provides Acceptable Level of Quality and Safety -aSm Code 99MRonnt MfeANAffected Valves Glsss Cat. Functi System(s)

MS-RV-IA, B, C, D I CMS-RV-24A B, C, D 1 C Overpressure Protecton Main SteamMS-RV-3A, B, C 1 CMS-RV-30 1 C nd Auto... .... ...... ...O v e rp r s s u rf e P ro t e c t io n a n d A tMS-RV-4A, 8, C, D 1 C D "'pr~mtne System to lower reectorpressure sufficient to allow tnWiatIon of Low--Presaur Coolant Incti (RHR, LPCI mode)MS-RV-5B, C I CmCme -tdWe Md &"doThe 2004 Edition and the 2005 and 2006 Addenda of the ASME OM CodeAollicb" COde a irm eMandatorW A&Mendix I. PaffiraM 1-3310: Sequence of Periodic Testing of Class 1 Main SteamPressure Relief Valves with Auxiliary Actuating Devices.Mandatory AQ2endlx I. ParaoroMh 1-3310, states that tests before maintenance or set-pressure adjustment, or both, shall be performed for 1-3310(a),

(b), and (c) in sequence.

The remaining shallbe performed after maintenance or set-pressure adjustments:

(a) visual examination; (b) seat tightness determination, if practicable; (c) set-pressure determination; (d) determination of electrical characteristics and pressure integrity of solenoid valve(s);

(e) determination of pressure Integrity and stroke capability of air actuator; (f) determination of operation and electrical characteristics of position indicators; (g) determination of operation and electrical characteristics of bellows alarm switch;(h) determination of actuating pressure of auxiliary actuating device sensing element, whereapplicable, and electrical continuity; and(i) determination of compliance with the Owner's seat tightness criteria.

'ST Pgi' p"' Columbia Generating Station P 3 of 404th 10-Year Interval (Relief Requests Only)Relief Request -RV03 (Contld.)

Reasew fbr RgaoutRelief is requested from requirements for sequence of periodic testing of Class 1 Main Steampressure relief valves with auxiliary actuating devices.1. Remote set pressure verification devices (SPVDs) have been permanently Instaled on alleighteen Main Steam Relief Valves (MSRVs) to alow set pressure testing at low poweroperation, typically during shutdown for refueling outage and on startup if necessary.

TheseSPVDs incorporate a nitrogen powered metal bellows assembly that adds a quantified liftingforce on the valve stem until the MSRV's popping pressure is reached.

During normal poweroperation, these SPVDs remain deenergized and do not interfere with normal safety or reliefvalve functions.

Removal and replacement of the MSRVs is normally performed only for valvemaintenance and not for the purpose of As-Found set pressure determination.

MSRVs areremoved and replaced for maintenance purposes (e.g., seat leakage, refurbishment) nominally each refueling outage. The valves which are required to be As-Found set pressure tested, aspart of the Code required periodic

testing, do not necessarily correspond to those required tobe replaced for maintenance.

Actxuts and solenoids are separated from the valve andremain in place when MSRVs are removed and replaced for maintenance.

As found visual examinations cannot be performed per the Code required sequence while thedrywell is inerted.

Visual examinations are performed after reactor shutdown but prior to valvemaintenance or set-pressure adjustments.

If due to a reactor scram, MSRV periodic set pressure testing could not be performed at powerduring shutdown for refueling outage, it will be required to be performed during powerascension from refueling outage or by removing the valves and sending them to the vendor foras-found set pressure testing.

This would require Paragraphs 1-3310(a),

(d), (e), (f), and (h)tests to be performed during outage prior to Paragraphs 1-3310(b),

(c) and (0) tests. Paragraph 1-3310(g) is not applicable to these valve designs.2. "Valves" and "accessories" (actuators, solenoids, etc.) have different maintenance and testcycles due to the methods used for maintenance and testing at Columbia Generating Stationas discussed in item 1, and should be considered separately for the purposes of meeting therequired test frequency and testing requirements.

Valve testing (i.e., visual examination, seattightness, set pressure determination and compliance with Owner's seat tightness

criteria, inaccordance with Paragraphs 1-3310(a),

(b), (c) and (i)) are independent of and can beseparate from testing of "accessories" (i.e., solenoids,

actuator, position Indicators andpressure sensing element, in accordance with Paragraphs 1-3310(d),

(e), (f), and (h)).Paragraph 1-3310 states that tests before maintenance or set-pressure adjustment, or both,shall be performed for 1-3310(a),

(b), and (c) in sequence.

The remaining shall be performed after maintenance or set pressure adjustments.

Valve maintenance or set pressureadjustment does not affect "accessories" testing;

likewise, maintenance on "accessories" doesnot affect valve set pressure or seat leakage.

Therefore, the MSRVs and the "accessories" may be tracked separately for the purpose of satisfying the Paragraph 1-1320 test frequency requirements.

4ST lO-Yea Int Columbia Generating Station P of44th 10-Yer Interval (Relief Requests Only)Relief Request -RV03 (Contd.)3. Paragraph 1-3310(f) requires determination of operation and electrical charactgrscs ofposition Indicators, and Paragraph 1-3310(h) requires determination of actuating pressure ofauxiliary actuating device sensing element and electrical continuity.

These tests are requiredto be performed at the same frequency as the valve set pressure and auxiliary actuating device testing.The position indicators are all calibrated and functional tested during outages; the sensingelements (pressure switches) are all checked and calibrated at least once per 24 months.Although the existing bats do not have a one-to-one cor retion to the valve or actuator tests,these calibrations and functional tests meet all testing requirements of this Subsection, and farexceed the required test frequency and testing requirements.

Praie ft M nd Basis ftw URI1. WValves-and -accessories" (actuators, solenoids, etc.) shall be tested separately and meetParagraph 1-1320 test frequency requirements.

Since the valve and actuator test andmaintenance cycles are different, the plant positions of the actuators

selected, or due, forperiodic testing may not match the plant positions of the MSRVs selected, or due, for As-Found set pressure testing.MSRV periodic set pressure testing will normally be performed at power during shutdown forrefueling outage. As-found visual examination will be performed after set-pressure testing,which is out of the specified Code required sequence.

If MSRV periodic set pressure testing could not be performed at power during shutdown forrefueling outage due to reactor scram it will be required to be performed during powerascension from refueling outage or by removing the valves and sending them to the vendor foras-found set pressure testing.

This will require Paragraphs 1-3310(a),

(d) and (a) tests to beperformed during outage prior to Paragraphs 1-3310(b),

(c) and (I) tests.The actuators and solenoids will be tested at the end of the outage after other maintenance iscomplete, and the tests will be credited as satisfying the Code periodic test requirements provided that no actuator or solenoid maintenance (other than actuator assembly re-installation on a replaced valve) is performed that would affect their As-Found status prior totesting or that could affect the valve's future set pressure determination.

2. All MSRV position indicators will continue to be tested in accordance with existing surveillance procedures for monthly channel checks, and for channel calibration and channel functional testing at least once per 24 months during shutdowns.

These tests will be credited forsatisfying the requirements of Paragraph 1-3310(f).

3. All auxiliary actuating device sensing elements (pressure switches) will continue to be testedand calibrated on a 24 month frequency.

These tests will be credited for satisfying therequirements of paragraph 1-3310(h).

1SW Progran Plan Columbia Generating Station P 36 of 404tho10-Year Inv= (Relief Requests Only)Relief Request -RV03 (Contd.)QualtSfty Imp a tDue to different maintenance and test cycles of valves and accessories and also due to methods usedfor testing and maintenance, It Is impractical to meet the Code required testing requirements withoutsubjecting the valves to unnecessary challenges and increased risk of seat degradation.

Therequirement for testing actuators and accessories in a specific sequence does not enhance system orcomponent operability, or in any way Improve nuclear safety. The proposed alternate testingadequately evaluates the operational readiness of these valves commensuramt with their safetyfunction.

This will help reduce the number of challenges and failures of safety relief valves and stillprovide timely informauon regarding operability and degradation.

This will provide adequateassurance of material quality and public safety.DQurio of PromaamdA Fourth 10 year interval.

Similar relief was granted for the third 10 year interval.

NRC approval was documented in a letterdated March 23, 2007 (ADAMS Accession Number ML 070600111, TAC No. MD3551) for ReliefRequest No. RVO4.

4ST Pro-Ym Plan Columbia Generating Station Pop 34th 10-Year Interval (Relief Requests Only)Relief Request -RV04Proposed Aktunatlv In Accordance with 10 CFR 50.SSe(aX3X))

-Alternative Provides Acceptable Level of Quality and Safety -Affected Valves I ) [lss [ SysIsmsPI-EFC-X(3?E, PI-EFC,-X37F ISystem(s):

Process Instrumentatin for varioussystem conincted to RPVPI-EFC-X38A, PI-EFC-X38B, PI-EFC-X38C, PI-EFC-X38D, 1 CPI-EFC-X38E, PI-EFC-X38F PI-EFC-X39A, PI-EFC-X396, CPI-EFC-X390, PI-EFC-X39E PI-EFC-X40C, PI-EFC-X40D I CPI-EFC-X40E, PI-EFC-X40F 2 CPI-EFC-X41C, PI-EFC-X41D 1 CPI-EFC-X41E, PI-EFC-X41F 2 CPI-EFC-X42A, PI-EFC-X42B 1 CPI-EFC-X44AA, PI EFC X44AB,PI-EFC-X44AC, PI-EFC-X44AD, PI-EFC-X44AE, PI-EFC-X44AF, CPI-EFC-X44AG, PI-EFC-X44AH, PI-EFC-X44AJ, PI-EFC-X44AK, PI-EFC-X44AL, PI-EFC-X44AM PI-EFC-X44BA, PI-EFC-X44BB, PI-EFC-X448C, PI-EFC-X44BD, PI-EFC-X448E, PI-EFC-X448F, 1 CPI-EFC-X44BG, PI-EFC-X44BH, PI-EFC-X44BJ, PI-EFC-X448K, PI-EFC-X44BL, PI-EFC-X44BM PI-EFC-X61A, PI-EFC-X61B 1 CPI-EFC-X62C, PI-EFC-X62D I CPI-EFC-X69A, PI-EFC-X698, 1 CPI-EFC-X69E PI-EFC-X70A, PI-EFC-X708, PI-EFC-X70C, PI-EFC-X70D, 1 CPI-EFC-X70E, PI-EFC-X7OF PI-EFC-X71A, PI-EFC-X71B, PI-EFC-X71C, PI-EFC-X71D, I CPI-EFC-X71E, PI-EFC-X7IF PI-EFC-X72A 1 CFunction:

Close:Excess flow check valves are provided ineach Instrument process line that ispart of the reactor coolant pressureboundary.

Desgn and installation of theexcess flow check valves at ColumbiaGenerating Station conform to Regulatory Guide 1.11.The reactor instrument line excess flowcheck valves dose to limit the flow in therespective instrument lnes In the event ofan instrument line break downstream ofthe EFCVs outside containment.

PI-EFCX73A ICI.

IS PlrWw n Columbia Generating Station Pg38of 404th 10-Year Interva (Relief Requ,,-ts Only)Relief Request -RV04 (Contd.)Affected Valves Class Cat. System(s)

/ FunctionPI-EFC-X74A, PI-EFC-X748, 1 C System(s):

Process Instrumentation for vaiousPI-EFC-X74E, PI-EFC-X74F systems connected to RPVPI-EFC-X75A, PI-EFC-X758, PI-EFC-X75C, PI-EFC-X750, I c Function:

Excess flow check valves are provided inPI-EFC-X75E, PI-EFC-X75F each inrument process line that ispart of the reactor coolant presurePI.EFC.X788, PI-EFC-X78C, C boundary.

Design and installaon of thePI-EFC-X78F excess flow check valves at ColumbiaPI-EFC-X79A, PI-EFC-X798 I C Generating Station conform to Regulatory PI-EFC-X106 I C Gukde 1.11.PI-EFC-Xl07 I C Clo: The reacto instrumren nm excess flowPI-EFC-X108 I C check valves close to limit the flow in the--...respective instument lines In the event ofPI-EFC-X109 I C an instrument line break downsteam ofPI-EFC-X110 I C the EFCVs outside containment PI-EFC-X1 11 1 CPI-EFC-X1 12 1 CPIEFC-X1,3 I CPI-EFC-X113 1 CPI-EFC-X115 1 C __________________

WS~tIiflaaJna~aim The 2004 Edition and the 2005 and 2006 Addenda of the ASME OM Code&Malbe Codem uMAmmnOM Subsection ISTC-3522=c1, Cateoorv C Chock Valves. If exercising is not practicable duringoperation at power and cold shutdowns, It shall be performed during refueling outages.OM useton IS -700, Valve Poito VA .Valves with remote position indicators shall beobserved locally at least once every 2 years to verify that valve operation is accurately indicated.

Where practicable, this local observation should be supplemented by other indications such as use offlow meters or other suitable instrumentation to verify obturator position.

These observations neednot be concurrent.

Where local observation Is not possible, other indications shall be used forverification of valve operation.

Reason for Reouest and Basis for UASME OM Code Subsection ISTC requires testing of active or passive valves that are required toperform a specific function In shutting down a reactor to the cold shutdown condition, in maintaining the cold shutdown condition, or in mitigating the consequences of an accident.

The EFCVs are notrequired to perform a specific function for shutting down or maintaining the reactor in a cold shutdown 4ST PrO-rea int Columbia Generating Station P of 404th 10-Year Interval (Relief Requtet.

Only)Relief Request -RY04 (Contd.)condition.

Additionaly, the reactor instrument lines are assumed to maintain integrity for all accidents except for the Instrument Line 8reak Accident (ILBA) as described In Final Safety Analysis Report(FSAR) Subsection 15.6.2. The reactor instrument lines at Columbia Generating Station have a flow-restricting orifice upstream of the EFCV to limit reactor coolant leakage in the event of an instrument line rupture.

Isolation of the instrument line by the EFCV is not credited for mitigating the ILBA. Thus,a failure of an EFCV is bounded by the Coluria Generating Station safety analysis.

These EFCVsdose to imk the flow of reactor coolant to the secondary containment in the event of an instrument line break and as such are included in the IST program at the Owner's discretion and are tested inaccordance with the amended Technical Specification SR 3.6.1.3.8.

The GE (General Electric)

Licensing Topical Report NEDO-32977.A dated November 1998(Reference 2), and associated NRC safety evaluation, dated March 14, 2000, prves the basis forthis relief. The report provides Justification for relaxation of the testing frequency as described in theamended Technical Specification SR 3.6.1.3.8.

The report demonstrates the high degree of EFCVreliability and the low consequences of an EFCV failure.

Excess flow check valves have beenextremely reliable throughout the industry.

Based on 15 years of testing (up to year 2000) with onlyone (1) failure, the Columbia Generating Station revised Best Estimate Failure Rate Is 7.9E-8 perhour; less than the industry average of 1.01E-7 per hour. There have been no failures since year2000. Technical Specification amendment request for SR 3.6.1.3.8 was reviewed by the NRC staff insafety evaluation (SE) dated February 20, 2001 (Reference 3).Failure of an EFCV, though not expected as a result of the amended Technical Specification change,is bounded by the Columbia Generating Station safety analysis.

Based on the GE Topical report andthe analysis contained in the FSAR, the proposed alternative to the required exercise frequency andvalve Indication verification frequency for EFCVs provide an acceptable level of quality and safety. InReference 3, the NRC staff concluded that the increase in risk associated with the relaxation of EFCVtesting is sufficiently low and acceptable.

Energy Northwest requests relief pursuant to 10 CFR 50.55a(a)(3)(i) to test reactor instrument lineexcess flow check valves in accordance with the amended Technical Specification SR 3.6.1.3.8.

ThisSR requires verification every 24 months that a representative sample of reactor instrument lineEFCVs actuate to the isolation position on an actual or simulated Instrument line break signal. Therepresentative sample consists of an approximately equal number of EFCVs such that each EFCV istested at least once every 10 years (nominal).

Valve position indication verification of therepresentative sample will also be performed during valve testing.

Any EFCV failure will be evaluated per the Columbia Generating Station Corrective Action Program.I = i A ,- 77-- -F175.7 -Fourth 10 year interval.

ST Program Pn Columbia Generating Station P of 404th 10-Veer interval (Relief Requests Only)Relief Request -RV04 (Contd.)This relief was granted for the third 10 year interval.

NRC approval was documented In a letter datedMarch 23, 2007 (ADAMS Accession Number ML 070600111, TAC No. MD3552) for Relief RequestNo. RVO5.1. FSAR 15.6.22. Letter BWROG-00069, dated June 14, 2000, from W.G. Warren, (BWR Owners Group) toOffice of Nuclear Reactor Regulation, "Transunttal of Approved GE Licensing Topical ReportNEDO-32977-A, Excess Flow Check Valve Testing Relaxation",

dated November 19983 Letter dated February 20, 2001, Jack Cushing (NRC) to JV Parish (EN), 'Columbia Generating station -Issuance of Amendment RE: Technical Specifications Surveillance Requirement 3.6.1.3.8 (TAC NO. MB0421 )"