ML090580295
| ML090580295 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/10/2009 |
| From: | Mark Kowal Plant Licensing Branch 1 |
| To: | John Carlin Ginna |
| Pickett D | |
| References | |
| TAC ME0652 | |
| Download: ML090580295 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 r13rch In, xrn Mr. John T. Carlin Vice President RE. Ginna Nuclear Power Plant RE. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519
SUBJECT:
FOURTH INTERVAL INSERVICE TESTING PROGRAM RELIEF REQUEST NO. VR RE. GINNA NUCLEAR POWER PLANT (TAC NO. ME0652)
Dear Mr. Carlin:
By letter dated February 16, 2009, RE. Ginna Nuclear Power Plant, LLC (the licensee),
submitted Relief Request No. VR-14 for the RE. Ginna Nuclear Power Plant. The licensee requested Nuclear Regulatory Commission (NRC) approval of an alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, to extend the test interval so that inservice testing of safety injection accumulator relief valves 830A and 830B could be performed during the RE. Ginna fall 2009 refueling outage.
Based on the NRC staff's review and evaluation of the information provided by the licensee, the staff concludes that extending the test interval for relief valves 830A and 830B for up to 6 months beyond the ASME Code interval is an acceptable alternative. The alternative is authorized pursuant to Title 10 of the Code of Federal Regulations 50.55a(a)(3)(i) on the basis that the alternative provides an acceptable level of quality and safety. The duration of the alternative is from April 3, 2009, until one of the valves is tested during the fall 2009 refueling outage.
Our safety evaluation is enclosed. Please contact Douglas Pickett at 301-415-1364 if you have any questions.
Sincerely, Mark G. Kowal, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
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- -+cSAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST NO. VR-14 ALTERNATIVE TEST INTERVAL FOR RELIEF VALVES 830A AND 830B RE. GINNA NUCLEAR POWER PLANT, LLC RE. GINNA NUCLEAR PLANT DOCKET NO. 50-244
1.0 INTRODUCTION
By letter dated February 16, 2009 (Agencywide Documents Access and Management System Accession No. ML090540063), RE. Ginna Nuclear Power Plant, LLC (the licensee), submitted Relief Request No. VR-14 for the RE. Ginna Nuclear Power Plant. The licensee requested authorization to use an alternative to an inservice test provision in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in accordance with Title 10 of the Code of Federal Requletions (10 CFR), Part 50, Section 55a(a)(3)(i) on the basis that the proposed alternative provides an acceptable level of quality and safety. The alternative, which was proposed for safety injection accumulator relief valves 830A and 830B, requests approval to extend the test interval for 6 months on a one-time basis.
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Requtetions, Part 50, Section 50.55a(f), "Inservice testing requirements," requires, in part, that ASME Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) and (a)(3)(ii) of 10 CFR 50.55a.
In proposing alternatives, a licensee must demonstrate that the proposed alternative provides an acceptable level of quality and safety or that compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The Nuclear Regulatory Commission (NRC) is authorized under 10 CFR 50.55a to approve alternatives to ASME OM Code requirements upon making necessary findings. NRC guidance contained in NUREG-1482 Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants," provides alternatives to ASME OM Code requirements which are acceptable. The licensee proposed an alternative in Request No. VR-14 in accordance with 10 CFR 50.55a(a)(3)(i), due to an alternative that provides an acceptable level of quality and safety.
The NRC's findings with respect to authorizing alternatives to the ASME OM Code are given below.
Enclosure
- 2
3.0 TECHNICAL EVALUATION
3.1 Request No. VR-14 3.1.1 ASME OM Code Requirement ASME OM Code, Appendix I, Paragraph 1-1360(a), 1998 Edition, states that a minimum of 20%
of the valves from each group shall be tested within any 48-month interval.
3.1.2 Proposed Alternative Testing The R.E. Ginna facility has two pressure relief valves (830A and 830B) associated with the safety injection accumulators that make up Relief Device Group 8A. Since there are only two valves in the Relief Device Group, the Code requires that at least one of them be tested during each 48-month period. Both of these valves were last tested during the spring 2005 refueling outage. Therefore, the Code requires that at least one of these valves be tested prior to the end of the current 48-month interval which expires on April 3, 2009.
During a recent internal assessment, the licensee determined that testing of safety injection accumulator relief valves 830A and 830B was inadvertently omitted from the spring 2008 refueling outage work scope. As a result, the valves were not tested. These valves can only be removed and tested during a refueling outage when the accumulators are depressurized.
Therefore, in order to remain in compliance with the Code, the licensee proposed to extend the test interval for relief valves 830A and 830B up to 6 months beyond April 3, 2009, on a one-time basis so that testing could be performed during the fall 2009 refueling outage. The duration of the proposed alternative would be from April 3, 2009, until one of the valves is tested during the fall 2009 refueling outage.
3.1.3 Basis for the Alternative The proposed alternative is to extend the test frequency for no more than 6 months in order to permit testing to be performed during the fall 2009 refueling outage.
The licensee notes that the overall reliability of the safety injection accumulator relief valves has been good. With one exception, the previous 4 inservice tests (set pressure and seat tightness) for the subject valves, dating back to 1993 have been acceptable and were found within all Code and owner established acceptance criteria. The single exception was due to a problem with a valve's internais which caused the valve to initially stick and then lift above its allowable high end set point pressure. The valve was subsequently rebuilt and successfully tested.
The licensee has included testing of these valves in the forced outage scope as an interim compensatory measure. Therefore, if the plant unexpectedly shuts down between now and the fall 2009 refueling outage and plant conditions are supportive, at least one of the relief valves will be tested.
3.1.4 NRC Staff's Evaluation of Proposed Alternative The NRC staff notes that the requested interval extension will be for no more than 6 months.
The staff further notes that, had the test interval been 24 months instead of 48 months, the R.E.
~ 3 Ginna Nuclear Power Plant Technical Specifications (TSs) would have permitted a 6-month interval extension without requiring NRC review and approval.
Ginna TS Surveillance Requirement (SR) 3.0.2 states that each SR is considered met if the surveillance is performed within 1.25 times the interval specified in the TS Frequency. Ginna TS 5.5.7, "lnservice Testing Program," item b asserts that the provisions of SR 3.0.2 are applicable for test frequencies up to 24 months. Ginna TS 3.0.2 and 5.5.7 are consistent with NUREG-1431, Standard Technical Specifications for Westinghouse Plants. Therefore, had the test interval for the safety injection accumulator relief valves been 24 months, the Ginna TS would have permitted a 25 percent (i.e., 6-month) extension of the test interval. As stated in the Ginna TS Bases, the 25-percent extension is not intended to be used repeatedly or merely as an operational convenience to extend the surveillance interval.
As discussed above, the NRC staff finds that the requested 6-month extension is equivalent to the TS allowed extension for ASME OM test intervals that are 24 months in duration. The staff finds that the one-time, s-rnonth extension cannot be used repeatedly or merely as an operational convenience to extend the interval beyond 48 months. The staff further finds that extending the test interval an additional 6 months beyond the Code allowed 48 months should not adversely affect the operational readiness of the two relief valves. Therefore, based upon the above discussion along with the previous test history of these valves that demonstrate reasonable valve operability, the staff finds the licensee's proposal acceptable.
3.1.5 Conclusion Based on the NRC staff's review and evaluation of the information provided by the licensee, the staff concludes that extending the test interval for safety injection accumulator relief valves 830A and 830B for up to 6 months beyond the Code interval is an acceptable alternative. The alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(I) on the basis that the alternative provides an acceptable level of quality and safety. The duration of the alternative is from April 3, 2009, until one of the valves is tested during the fall 2009 refueling outage.
Principal Contributor: Stephen G. Tingen Date: ~'Brch 10, zi>>
ML090580295 OFFICE LPLI-1/PM LPLI-1/LA CPTB/BC OGC LPLI-1/BC NAME DPickett SLittie via email JMcHaie as signed on MSmith MKowal DATE 3/06/09 03 I 06 I 09 02 119/09 03 I 091 09 03 110 I 09