ML100331816

Safety Evaluation of Relief Request V-06 for the Third 10-Year Interval of the Inservice Testing Program for Hope Creek Generating Station

ML100331816
Person / Time
Site:	Hope Creek
Issue date:	03/10/2010
From:	Chernoff H Plant Licensing Branch 1
To:	Joyce T Public Service Enterprise Group
Ennis R, NRR/DORL, 415-1420
References
TAC ME2158
Download: ML100331816 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 10, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear P.O. Box 236, N09 Hancocks Bridge, NJ 08038

SUBJECT:

SAFETY EVALUATION OF RELIEF REQUEST V-06 FOR THE THIRD 10-YEAR INTERVAL OF THE INSERVICE TESTING PROGRAM FOR HOPE CREEK GENERATING STATION (TAC NO. ME2158)

Dear Mr. Joyce:

By letter dated September 1, 2009, as supplemented by letter dated January 26, 2010, PSEG Nuclear LLC submitted relief request V-06 which proposed an alternative to certain inservice testing (1ST) requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for Hope Creek Generating Station (HCGS). The relief request applies to the third 1O-year 1ST interval which began on December 21, 2006, and will end on December 20, 2016. The subject relief request involves an extension to the test interval for a pressure relief valve in the safety auxiliaries cooling system.

The U.S. Nuclear Regulatory Commission staff has completed its review of the subject relief request as documented in the enclosed Safety Evaluation (SE). Our SE concludes that:

(1) compliance with the specified 1ST requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety; and (2) the proposed alternative provides reasonable assurance of the operational readiness of the subject relief valve.

Therefore, pursuant to Section 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations, the proposed alternative is authorized for HCGS.

The proposed alternative is authorized until restart after refueling outage R16, which is currently scheduled to begin in October 2010.

T. Joyce -2 If you have any questions concerning this matter, please contact the HCGS Project Manager, Mr. Richard Ennis, at (301) 415-1420.

Sincerely, /

1~/;f{A~

t;~ld K. Chernoff, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket 1\10. 50-354

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST V-06 FOR THE THIRD 10-YEAR INTERVAL OF THE INSERVICE TESTING PROGRAM PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1.0 INTRODUCTION

By letter dated September 1, 2009, as supplemented by letter dated January 26, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML092520040 and ML100330316, respectively), PSEG Nuclear LLC (PSEG or the licensee) submitted relief request V-06 which proposed an alternative to certain inservice testing (1ST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for Hope Creek Generating Station (HCGS).

As discussed in the licensee's letter dated September 1, 2009, during a review of the HCGS 1ST program, PSEG identified discrepancies in the scheduling of periodic relief valve testing. The schedule for testing some relief valves incorrectly applied a 25% extension to the applicable test interval, As a result, 3 relief valves (1EGPSV-2519, 1GBPSV-9522B, and 1GBPSV-9523B) were not tested during refueling outage R15 in spring 2009. To meet the 1O-year test interval requirement in the OM Code, these valves would be required to be tested no later than May 5, 2010. The licensee stated that testing the valves before refueling outage R16 (fall 2010) would constitute a hardship due to the inaccessibility of the valves during normal plant operation. As such, PSEG requested that the 1O-year test interval be extended until restart from refueling outage R16, which is currently scheduled to begin in October 2010. The licensee's proposed alternative was submitted pursuant to Section 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

As discussed in the supplement dated January 26, 2010, two of the subject relief valves (1GBPSV-9522B and 1GBPSV-9523B) were replaced during a maintenance outage in January 2010. As such, relief request V-06 only pertains to relief valve 1EGPSV-2519.

Enclosure

-2

2.0 REGULATORY EVALUATION

Section 50.55a of 10 CFR, requires that 1ST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) 1ST program intervals in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Nuclear Regulatory Commission (NRC or the Commission) pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month 1ST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv),

inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval.

Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.

In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. Section 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants."

The subject relief request applies to the third 10-year 1ST interval at HCGS which began on December 21,2006, and will end on December 20,2016. The Code of Record for the third interval was developed in accordance with the 2001 Edition through 2003 Addenda of the ASME OM Code.

3.0 TECHNICAL EVALUATION

3.1 The Licensee's Alternative ASME OM Code, 2001 Edition through 2003 Addenda, Mandatory Appendix I, "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants," Section 1-1350, requires that Class 2 and 3 pressure relief valves, with the exception of pressurized water reactor main steam safety valves, be tested every 10 years.

The licensee's letter dated September 1,2009, stated that relief valve 1EGPSV-2519, a Code Class 3 valve, provides overpressure protection for the safety auxiliary cooling system (SACS) return side accumulator and relieves to the atmosphere. To meet the 1O-year test interval requirement in the OM Code, the subject valve would be required to be tested no later than May 5, 2010. PSEG requested that the 1O-yeartest interval be extended until restart from refueling outage R16, which is currently scheduled to begin in October 2010.

-3 The licensee's letter dated September 1, 2009, provided the following reason for the proposed alternative:

Removal and testing of 1EGPSV-2519 is performed when the unit is in a refueling outage because it is inaccessible as it cannot be isolated and removed with the station online. The accumulator is part of the Turbine Auxiliary Cooling System (TACS) and 1EGPSV-2519 can only be removed when TACS is not in service, which is during a refueling outage.

The accumulator is designed to protect the safety related SACS piping from being overpressurized due to a pressure transient resulting from a pipe break in the TACS loop. The TACS system is not safety related, but it is designed to provide cooling water to the turbine auxiliary equipment during normal plant operation and normal plant shutdown. The TACS system water supply originates and terminates from the safety related SACS system. Loss of TACS would result in a trip of the main turbine and a scram of the reactor.

3.2 NRC Staff Evaluation NUREG-1482, Revision 1, dated January 2005 (ADAMS Accession No. ML050550290) gives licensees guidelines and recommendations for developing and implementing programs for the 1ST of pumps and valves at commercial nuclear power plants. Section 3.1.3 of NUREG-1482 provides NRC recommendations regarding scheduling of inservice tests. This section states that licensees must perform each applicable test within the specified time interval, with a maximum allowed extension not to exceed 25% of the test interval. As discussed in the NUREG, this recommendation applies to test intervals with a maximum duration of 2 years based on the Standard Technical Specifications. For an 1ST interval of 2 years, a 25%

extension results in an extension of 6 months. The licensee's proposed alternative would extend the 1O-year test interval for relief valve 1EGPSV-2519 by less than 6 months (i.e., approximately 5% of the 1O-year interval).

The licensee's letter dated September 1, 2009, stated that there are two SACS system relief valves in the applicable test sample group (1 EGPSV-2519 and 1EGPSV-2266). Both valves were successfully as-found lift setpoint surveillance tested during the 2nd 1ST interval with no signs of external leakage. Based on these test results and the relatively short timeframe associated with the proposed extension of the 1O-year test interval, the NRC staff finds that the proposed alternative provides reasonable assurance of the operational readiness of the subject relief valve. The NRC staff further finds that compliance with the OM Code 1O-year test interval requirement for relief valve 1EGPSV-2519 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety since the plant would need to be shutdown in advance of the upcoming refueling outage in order to test the valve.

4.0 CONCLUSION

Based on the above evaluation, the NRC staff concludes that: (1) compliance with the specified 1ST requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety; and (2) the proposed alternative provides reasonable assurance

-4 of the operational readiness of the subject relief valve. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the proposed alternative is authorized for HCGS. The proposed alternative is authorized until restart after refueling outage R16, which is currently scheduled to begin in October 2010.

Principal Contributors: S. Tingen R. Ennis Date: March 10, 2010

1. Joyce -2 If you have any questions concerning this matter, please contact the HCGS Project Manager, Mr. Richard Ennis, at (301) 415-1420.

Sincerely, Ira!

Harold K. Chernoff, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

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