CNL-16-180, Application to Request an Alternative to the ASME Code OMN-20 (RV-04)

Application to Request an Alternative to the ASME Code OMN-20 (RV-04)

ML17058A453
Person / Time
Site:	Sequoyah
Issue date:	02/27/2017
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-16-180
Download: ML17058A453 (5)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-180 February 27, 2017 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 328

Subject:

Application to Request an Alternative to the ASME Code OMN-20 (RV-04)

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), Tennessee Valley Authority (TVA) requests an alternative to the testing frequencies in the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, by adoption of approved Code Case OMN-20, "Inservice Test Frequency," for the current ten-year Inservice Testing (IST) interval for the Sequoyah Nuclear Plant (SQN) Units 1 and 2.

Approved ASME Code Case OMN-17 changes the testing frequency from 60 months to 72 months. Draft Regulatory Guide DG-1297, Operation and Maintenance Code Case Acceptability, ASME OM Code [proposed Revision 2 to Regulatory Guide (RG) 1.192, dated March 2016] endorses use of OMN-17. TVA intends to adopt OMN-17 for SQN upon issuance of RG 1.192, Rev. 2. It was anticipated that the 10 CFR 50.55a final rule, which endorses Revision 2 of RG 1.192, would be published in the December 2016 - January 2017 time frame and that Revision 2 of RG 1.192 would be issued in the first two months of 2017. As of the date of this submittal, changes to 10 CFR 50.55a have not completed the rulemaking process and Revision 2 of RG 1.192 has not been issued.

Code Case OMN-20 provides a six-month grace interval for pumps and valves with test frequencies greater than two years. In order to expedite the NRC review time, TVA is requesting approval to adopt OMN-20 in lieu of OMN-17, because TSTF-545-A contains an NRC approved relief request template and model safety evaluation. TVA plans to submit a license amendment request for SQN based on TSTF-545 at a later date.

U.S. Nuclear Regulatory Commission CNL-16-180 Page 2 February 27 , 2017 The inservice test for one SQN pressurizer safety relief valve is due on March 4, 2017 .

Therefore , approval of the proposed relief request is requested by March 3, 2017.

There are no new regulatory commitments associated with this submittal. If you should have any questions regarding this submittal , please contact Ed Schrull at (423) 751-3850.

J. W. Shea Vice President, Nuclear Licensing Enclosure Alternative Request RV-04 cc: (Enclosure)

NRC Regional Administrator- Region II NRC Senior Resident Inspector- Sequoyah Nuclear Plant NRC Project Manager- Sequoyah Nuclear Plant

ENCLOSURE Sequoyah Nuclear Plant (SQN), Units 1 and 2 Alternative Request RV-04 Alternative Due To Hardship Without a Compensating Increase in Quality and Safety in Accordance with 10 CFR 50.55a(z)(2)

1.0 DESCRIPTION

The request is to adopt a proposed alternative to the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code by adoption of approved Code Case OMN-20, "Inservice Test Frequency."

2.0 ASSESSMENT Technical Evaluation of the Proposed Alternative to the OM Code Section IST of Division 1 of the OM Code, which is incorporated by reference in 10 CFR 50.55a(a), specifies component test frequencies based either on elapsed time periods (e.g., quarterly, two years) or on the occurrence of a plant condition or event (e.g., cold shutdown, refueling outage).

ASME Code Case OMN-20, "Inservice Test Frequency," has been approved for use by the ASME OM committee as an alternative to the test frequencies for pumps and valves specified in ASME OM Division 1, Section IST 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of ASME OM Code.

Code Case OMN-20 is not referenced in the latest revision of Regulatory Guide 1.192 (August 2014) as an acceptable OM Code Case to comply with 10 CFR 50.55a(f) requirements as allowed by 10 CFR 50.55a(b)(6). The proposed alternative is to use Code Case OMN-20 to extend or reduce the IST frequency requirements for the fourth ten-year IST interval or until OMN-20 is incorporated into the next revision of Regulatory Guide 1.192.

ASME Code Components Affected The Code Case applies to pumps and valves specified in ASME OM Division 1, Section IST 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code. Frequency extensions may also be applied to accelerated test frequencies (e.g., pumps in alert range) as specified in OMN-20.

For pumps and valves with test periods of two years of less, the test frequency allowed by OMN-20 and the current Technical Specification Inservice Testing (IST) Program [as modified by TS Surveillance Requirement (SR) 3.0.2 and Enforcement Guidance Memorandum (EGM) 2012-001] are the same. For pumps and valves with test frequencies greater than two years, OMN-20 allows the test frequency to be extended by six months. The current TS IST Program does not allow extension of test frequencies that are greater than two years.

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ENCLOSURE

Applicable Code Edition and Addenda

ASME Code Case OMN-20 applies to ASME OM Division 1, Section IST 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code.

The SQN Units 1 and 2, Code Edition and Addenda that are applicable to the program interval are ASME OM Code 2004 Edition through 2006 Addenda. The SQN Units 1 and 2 current interval ends June 30, 2026.

Applicable Code Requirement

This request is made in accordance with 10 CFR 50.55a(z)(2), and proposes an alternative to the requirements of 10 CFR 50.55a(f), which requires pumps and valves to meet the test requirements set forth in specific documents incorporated by reference in 10 CFR 50.55a(a).

ASME Code Case OMN-20 applies to Division 1, Section IST of the ASME OM Code and associated addenda incorporated by reference in 10 CFR 50.55a(a).

Reason for Request

The IST Program controls specified in Section 5.5.6 of TS provide: a) a table specifying certain IST frequencies; b) an allowance to apply SR 3.0.2 to inservice tests required by the OM Code and with frequencies of two years or less; c) an allowance to apply SR 3.0.3 to inservice tests required by the OM Code; and d) a statement that, "Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS." In Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirement 3.0.2 and 3.0.3 to Administrative Controls Program Tests," and EGM 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests," the NRC stated that items b, c, and d of the TS IST Program were inappropriately added to the TS and may not be applied (although the EGM allows licensees to continue to apply those paragraphs pending a generic resolution of the issue).

In RIS 2012-10 and EGM 2012-001, the NRC stated that the current TS allowance to apply SR 3.0.2 and SR 3.0.3 to the IST Program would no longer be permitted. In response, OMN-20, which provides allowances similar to SR 3.0.2, was approved and is proposed to be used as an alternative to the test periods specified in the OM code. The proposed alternative substitutes an approved Code Case for the existing TS requirements that the NRC has determined are not legally acceptable as a TS allowance. This proposed alternative provides an equivalent level of safety as the existing TS allowance, while maintaining consistency with 10 CFR 50.55a and the ASME OM Code.

Proposed Alternative and Basis for Use The proposed alternative is OMN-20, "Inservice Test Frequency," which addresses testing periods for pumps and valves specified in ASME OM Division 1, Section IST 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of ASME OM Code.

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ENCLOSURE This request is being made in accordance with 10 CFR 50.55a(z)(2), in that the existing requirements are considered a hardship without a compensating increase in quality and safety for the following reasons:

1) For IST testing periods up to and including two years, Code Case OMN-20 provides an allowance to extend the IST testing periods by up to 25%. The period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g., performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified. The test period extension and the statements regarding the appropriate use of the period extension are equivalent to the existing TS SR 3.0.2 allowance and the statements regarding its use in the SR 3.0.2 Bases. Use of the SR 3.0.2 period extension has been a practice in the nuclear industry for many decades and elimination of this allowance would place a hardship on SQN when there is no evidence that the period extensions affect component reliability.

2) For IST testing periods of greater than two years, OMN-20 allows an extension of up to six months. The ASME OM Committee determined that such an extension is appropriate.

The six-month extension will have a minimal impact on component reliability considering that the most probable result of performing any inservice test is satisfactory verification of the test acceptance criteria. As such, pumps and valves will continue to be adequately assessed for operational readiness when tested in accordance with the requirements specified in 10 CFR 50.55a(f) with the frequency extensions allowed by Code Case OMN-20.

3) As stated in EGM 2012-001, if an Inservice Test is not performed within its frequency, SR 3.0.3 will not be applied. The effect of a missed Inservice Test on the Operability of TS equipment will be assessed under the licensee's Operability Determination Program.

Duration of Proposed Alternative The proposed alternative is requested for the current ten-year IST interval or until Code Case OMN-20 is incorporated into a future revision of Regulatory Guide 1.192, referenced by a future revision of 10 CFR 50.55a, whichever occurs first.

Precedents The NRC approved the use of OMN-20 for North Anna on March 27, 2014 (NRC ADAMS Accession Number ML14084A407).

The NRC approved the use of OMN-20 for Duane Arnold on June 9, 2014 (NRC ADAMS Accession Number ML14144A002).

The NRC approved the use of OMN-20 for Point Beach, Seabrook, St. Lucie, and Turkey Point on December 15, 2016 (NRC ADAMS Accession Number ML16330A118).

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