ML092680060

R. E. Ginna - License Amendment Request: Administrative Revision of Inservice Test Program Technical Specification

ML092680060
Person / Time
Site:	Ginna
Issue date:	09/18/2009
From:	John Carlin Constellation Energy Nuclear Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML092680060 (10)

Text

John Carlin R.E. Ginna Nuclear Power Plant, LLC Site Vice President 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax John.Carlin@constellation.com Nuclear ConstellationGeneration Group Energy-September 18, 2009 U. S. Nuclear Commission Washington, Regulatory DC 20555 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 License Amendment Request: Administrative Revision of Inservice Test Program Technical Specification

REFERENCES:

(a) TSTF-479-A, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a, dated December 19, 2005 (b) TSTF-497-A, Revision 0, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less, dated July 12, 2006 (c) Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, Status of TSTF 343, 479, 482, 485, dated December 6, 2005 (d) Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, dated October 4, 2006 Pursuant to 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) hereby requests an amendment to the R.E. Ginna Technical Specifications that is based on incorporating Technical Specification Task Force 479-A (Reference a) and Technical Specification Task Force 497-A (Reference b). References (a) and (b) revise the Improved Standard Technical Specification administrative controls of the Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3. References (a) and (b) were subsequently approved by the Nuclear Regulatory Commission by References (c) and (d), respectively.

Specifically, the proposed change will replace, within Technical Specification 5.5.7, references to ASME Section XI of the Boiler and Pressure Vessel Code with references to the ASME Code for Operation and Maintenance of Nuclear Power Plants. In addition the proposed change also applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies

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Document Control Desk September 18, 2009 Page 2 of two years or less that were not included in the frequencies of the table listed in Technical Specification 5.5.7.a.

The technical basis and the significant hazards discussion for the proposed changes are provided in Attachment (1). A marked up page of the affected Technical Specification is provided in Attachment (2).

Approval of the proposed amendment is requested by April 1, 2010 with a 60 day implementation period.

There are no regulatory commitments contained in this letter. Should you have questions regarding this matter, please contact Thomas Harding (585) 771-5219, or thiomas.hardingirthconstellation.com.

STATE OF NEW YORK TO WIT:

COUNTY OF WAYNE 1, John Carlin, being duly sworn, state that I am Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be r " le. -

Sulýscribed and sworn befi re me, a Notary Public in and for the State of New"Y rk and County of LtM)/C ,thi- day of tc16-. ,2009.

WITNESS my Hand and Notarial Seal: -

My Commission Expires:0 ,/, Cur.*'r. /6

Document Control Desk September 18, 2009 Page 3 Attachments: (1) Evaluation of the Proposed Change (2) Marked up Technical Specification Page cc: D.V. Pickett, NRC Resident Inspector, NRC S. J. Collins, NRC P.D. Eddy, NYSDPS J.P. Spath, NYSERDA

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

R.E. Ginna Nuclear Power Plant, LLC September 18, 2009

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the R.E. Ginna Technical Specifications based on incorporating Technical Specification Task Force (TSTF) 479-A (Reference 1) and TSTF 497-A (Reference 2). Technical Specification Task Force-479-A and TSTF-497-A revise the Improved Standard Technical Specification administrative controls of the Inservice Testing (IST) Program. The proposed change will revise the applicable Technical Specification (TS) to align it with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3. Technical Specification Task Force-479-A and TSTF-497-A were subsequently approved by the Nuclear Regulatory Commission by References 3 and 4, respectively.

2.0 DETAILED DESCRIPTION The proposed change incorporates TSTF-479-A and TSTF-497-A and is comprised of two portions. The first portion replaces references to ASME Section XI of the Boiler and Pressure Vessel Code with references to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) within TS 5.5.7.

The second portion of the change applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.7.a. Specifically TS 5.5.7.b is changed to read:

"The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities."

These proposed changes serve to align R.E. Ginna TS with the TSTFs of References 1 and 2 and revises R.E. Ginna TS to reflect the ASME OM.

3.0 TECHNICAL EVALUATION

Title 10 CFR 50.55a was amended by Reference 6 to incorporate by reference more recent editions and addenda of the ASME Boiler and Pressure Vessel Code and the ASME OM Code for construction, inservice inspection, and inservice testing. These provisions provide updated rules for the construction of components of nuclear power plants and for the inservice inspection and inservice testing of those components.

Pursuant to 10 CFR 50.55a(f)(4), R.E. Ginna adopted, in Reference 5, the 1989 Edition of the ASME Code by implementation of the 1987 ASME/ANSI Operations and Maintenance (OM) Standards Part 1, Part 6, and Part 10 (OM-1, OM-6, and OM-10) as the code of record for the R.E. Ginna Fourth Ten Year IST program period which began on January 1, 2000. The proposed change to incorporate TSTF-479-A will serve to align the R.E. Ginna TS with the ASME code of record currently being used in the R.E.

Ginna IST Program.

Incorporation of TSTF-497-A applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in R.E. Ginna TS 5.5.7.a. This extension facilitates surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the surveillance while not resulting in a significant degradation of the reliability that results from performing the surveillance at its specified time.

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE The proposed change is considered to be administrative in that the incorporation of TSTF-479-A and TSTF-497-A incorporates the evolution of policy and guidance as to the required content and preferred format of TS over time. Incorporating TSTF-479-A and TSTF-497-A also aligns R.E. Ginna TS with the code of record currently in place with our IST Program.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Title 10 CFR 50.55a(f)(4) requires that ASME Boiler and Pressure Vessel Code Class 1, 2, and 3 components must meet the IST requirements of the ASME OM Code. Section 50.55a(f)(5)(ii) requires that, if a revised IST program for a facility conflicts with Technical Specifications for that facility, the licensee shall apply to the Nuclear Regulatory Commission for amendment of the Technical Specifications to conform the Technical Specification to the revised program. Therefore, in accordance with the requirements of 10 CFR 50.55a(f)(5)(ii), R.E. Ginna is submitting this license amendment request.

R.E. Ginna TS 5.5.7 currently references Section XI of the ASME Boiler and Pressure vessel Code, as the standard for testing frequencies and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves.

The current ASME Code of Record for R.E. Ginna fourth ten-year IST program is the 1989 Edition of the ASME Code by implementation of the 1987 ASME/ANSI Operations and Maintenance (OM) Standards Part 1, Part 6, and Part 10 (OM-I, OM-6, and OM-10). The current fourth ten-year IST program period began January 1, 2000.

The proposed change to TS 5.5.7 will replace references to Section XI of the ASME Boiler and Pressure Vessel Code with references to the ASME OM Code.

4.2 Precedent Below are several other facilities that have been granted approval for incorporating TSTF-479-A and TSTF-497-A into their TSs.

Facility Amendment#(s) Approval Date Braidwood Station, Units I & 2 153 August 28, 2008 Brunswick Steam Electric Plant, Units 1 & 2 247/275 April 23, 2008 4.3 Significant Hazards Consideration R.E. Ginna Nuclear Power Plant, LLC is requesting an amendment to R.E. Ginna Technical Specifications (TSs) that is based on incorporating Technical Specification Task Force (TSTF) 479-A and TSTF 497-A. Technical Specification Task Force-479-A and TSTF-497-A revise the Improved Standard Technical Specification administrative controls of the Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3.

The proposed change has been evaluated against the standards of 10 CFR 50.92(c) and has been determined to not involve a significant hazards consideration in the operation of the facility in accordance with the proposed amendment as indicated below:

2

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE

1. Operationof the facility in accordancewith the proposedamendment would not involve a significant increase in the probabilityor consequences of an accidentpreviously evaluated The proposed change will replace, within TS 5.5.7, references to Section XI of ASME Boiler and Pressure Vessel Code with references to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). In addition the proposed change adds words to TS 5.5.7.b which applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.7.a.

The proposed change is administrative, does not affect any accident initiators, does not affect the ability to successfully respond to previously evaluated accidents and does not affect radiological assumptions used in the evaluations. Thus, operation of the facility in accordance with the proposed change will not involve an increase in the probability or the consequences of an accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated.

The proposed change will replace, within TS 5.5.7 references to Section XI of ASME Boiler and Pressure Vessel Code with references to the ASME OM Code. In addition the proposed change also adds words to TS 5.5.7.b which applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.7.a.

The proposed change does not involve a modification to the physical configuration of the plant (i.e., no new equipment will be installed) or involve a change in the methods governing normal plant operation. The proposed change will not impose any new or different requirements or introduce a new accident initiator, accident precursor, or malfunction mechanism. Additionally there is no change in the types or increase in the amounts of any effluent that may be released offsite and there is no increase in individual or cumulative occupational exposure.

Therefore the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Operationof the facility in accordancewith the proposedamendment would not involve a significant reduction in a margin of safety.

The proposed change will replace, within TS 5.5.7 references to Section XI of ASME Boiler and Pressure Vessel Code with references to the ASME OM Code. In addition the proposed change also adds words to TS 5.5.7.b which applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.7.a.

The proposed change does not involve a modification to the physical configuration of the operating units or change the methods governing normal plant operation. The proposed change incorporates revisions to the ASME Code that results in a net improvement in the measures for testing pumps and valves. The safety functions of the applicable pumps and valves will be maintained.

3

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on theabove, R.E. Ginna concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The R.E. Ginna review has determined that the proposed amendment would change an inspection requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. TSTF-479-A, Revision 0, dated December 19, 2005, Changes to Reflect Revision of 10 CFR 50.55a

2. TSTF-497-A, Revision 0, dated July 12, 2006, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less

3. Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, dated December 6, 2005, Status of TSTF 343, 479, 482, 485

4. Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, dated October 4, 2006

5. Letter from M. Gamberoni (NRC) to R. Mecredy (Ginna), dated June 13, 2000, Requests for Relief from the ASME Boiler and Pressure Vessel Code Section XI Requirements for the Ginna Nuclear Power Plant Fourth 10-Year Interval of the Pump and Valve Inservice Testing Program (TAC NO MA7265 )

6. Federal Register, Volume 64, Number 183, dated September 22, 1999, 10 CFR Part 50 - Industry Codes and Standards; Amended Requirements 4

ATTACHMENT (2)

MARKED UP TECHNICAL SPECIFICATION PAGE R.E. Ginna Nuclear Power Plant, LLC September 18, 2009

Programs and Manuals 5.5 5.5.6 Pre-Stressed Concrete Containment Tendon Surveillance Program This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity.

The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Regulatory Guide 1.35, Revision 2.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Tendon Surveillance Program inspection frequencies.

5.5.7 Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components including applicable supports. The program shall include the following: a bleto

a. Testing frequencies specified in Section Xl of the ASME Beiler--aid Procsure Vossol Code and applicable Addenda as follows:

code for Operation 1-and Maintenance ASME Seiler-d-eure-Veseel Code and Required Frequencies for of Nuclear Power applicable Addenda terminology for inservice performing inservice testing testing activities activities Plants (ASME OM Code) Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually At least once per 366 days Biennially or every 2 years At least once per 731 days

b. The provisions of SR 3.0.2 are applicable to the above required Frequenciefor performing inservice testing activities; and to other normal and accelerated c. The provisions of SR 3.0.3 are applicable to inservice testing Frequencies activities; and specified as 2 years or less in the d. Nothing in the ASME 0,iletr-annd-POressue, Vessel Code shall be Inservice Testing construed to supersede the requirements of any Technical program Specification.

R.E. Ginna Nuclear Power Plant 5.5-4 Amendment 406