ML100470471
| ML100470471 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/18/2010 |
| From: | Robert Pascarelli Plant Licensing Branch III |
| To: | Jensen J Indiana Michigan Power Co |
| beltz T, NRR/DORL/LPL3-1, 301-415-3049 | |
| References | |
| AEP-NRC-2010-19, TAC ME3318 | |
| Download: ML100470471 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2010 Mr. Joseph N. Jensen Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNIT 2 (CNP-2) - EVALUATION OF RELIEF REQUEST (REL-004) (TAC NO. ME3318)
Dear Mr. Jensen:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated February 5, 2010, Indiana Michigan Power Company (the licensee) submitted a request for relief for approval of an alternative to a requirement in the American Society of Mechanical Engineers (ASME), Code for the Operation and Maintenance of Nuclear Power Plants (OM Code), for the Donald C. Cook Nuclear Plant, Unit 2 (CNP-2). Specifically, the proposed alternative would be applied to two main steam safety valves (MSSVs) on a one-time basis for the period of April 2010 through October 2010.
The NRC staff has reviewed the proposed relief request and concludes that the alternative in REL-004 is acceptable. The NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes the REL-004 for CNP-2 MSSVs 2-SV-2B-1 and 2-SV-3-1 on a one-time basis for the period of April through October 2010.
If you have any questions, please contact Terry Beltz of my staff at (301) 415-3049.
Sincerely, Robert J. Pascarelli, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-316
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 RELIEF REQUEST REL-004 REGARDING PROPOSED ALTERNATIVE FOR INSERVICE TESTING OF MAIN STEAM SAFETY VALVES 2-SV-2B-1 AND 2-SV-3-1 INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-316
1.0 INTRODUCTION
By letter dated February 5, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100491089), Indiana Michigan Power Company (the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) authorize the use of Alternative REL-004 for the Donald C. Cook Nuclear Power Plant, Unit 2 (CNP-2). The licensee requested authorization to use an alternative test interval than that required by the American Society of Mechanical Engineers (ASME), Code for the Operation and Maintenance ofNuclear Power Plants (OM Code). The licensee requested authorization to extend the test interval for CNP-2 Main Steam Safety Valves (MSSVs) 2-SV-2B-1 and 2-SV-3-1 beyond five years on a one-time basis from April until the October 2010 refueling outage.
Specifically, pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a(a)(3)(i)
(10 CFR 50.55a(a)(3)(i)), the licensee stated that the proposed alternative provides an acceptable level of quality and safety.
2.0 REGULATORY REQUIREMENTS Title 10 of the Code of Federal Regulations, 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 NRC is authorized under 10 CFR 50.50.55a to approve alternatives to ASME OM Code requirements upon making necessary findings.
The NRC findings with respect to authorizing alternatives to the ASME OM Code are given below.
Enclosure
- 2
3.0 TECHNICAL EVALUATION
3.1 Alternative REL-004 The applicable ASME OM Code edition and addenda for CNP is the 2001 Edition through the 2003 Addenda.
ASME OM Code Mandatory Appendix I, Paragraph 1-1320(a), "5-Year Test Interval," 2001 Edition through the 2003 Addenda, requires that Class 1 pressure relief valves be tested at least once every five years. ASME Code Interpretation 01-18, "ASME OM Code-1995 with OMa ASME Code-1996 Addenda, Appendix 1," dated June 26,2003, clarifies that the 5-year test interval starts when the valve is tested.
ASME OM Code Mandatory Appendix I, Paragraph 1-1350, "Test Frequency, Class 2 and 3 Pressure Relief Valves," 2001 Edition through the 2003 Addenda, requires that MSSVs be tested at a 5-year interval in accordance with Paragraph 1-1320(a).
The licensee is requesting authorization in Alternative REL-004 to extend the test interval for CNP-2 MSSVs 2-SV-2B-1 and 2-SV-3-1 beyond five years on a one-time basis until the October 2010 refueling outage.
The 5-year test interval for MSSVs 2-SV-2B-1 and 2-SV-3-1 will expire before the refueling outage scheduled for October 2010. The licensee initially considered the start of the 5-year test interval to begin once the MSSV was installed. The storage time was not included in the 5-year interval.
The licensee's justification for extending the test interval for MSSVs 2-SV-2B-1 and 2-SV-3-1 for up to approximately 7 months beyond 5 years is that the MSSVs were disassembled and inspected prior to the start of the current test interval in accordance with ASME Code Case OMN-17, "Alternative Rules for Testing ASME Class 'I Pressure Relief/Safety Valves."
3.2 NRC Evaluation of Proposed Alternative ASME OM Code Mandatory Appendix I does not require that safety valves be disassembled and inspected prior to the start of the 5-year test interval. The ASME developed Code Case OMN-17 and plans to publish OMN-17 in the upcoming edition/addenda of the ASME 01\\11 Code. Code Case OMN-17 allows extension of the test interval for Class 1 safety valves from 5 years to 6 years plus a 6-month grace period. The code case imposes a special maintenance requirement to disassemble and inspect each safety valve to verify that parts are free from defects resulting from time-related degradation or maintenance-induced wear prior to the start of the extended test interval. Similar to the special maintenance requirement in Code Case OMN-17, the licensee stated that MSSVs 2-SV-2B-1 and 2-SV-3-1 were disassembled to perform inspection and maintenance activities prior to the start of the current test interval. Wear and contact surfaces were cleaned and lubricated as required. New pre-oxidized discs were installed and each MSSV was reassembled and tested prior to being placed in storage.
The NRC staff finds that extending the 5-year test interval for MSSVs 2-SV-2B-1 and 2-SV-3-1 for up to approximately seven months beyond five years is acceptable on a one time-basis until the refueling outage in October 2010. This is consistent with the maintenance and test provisions in ASME Code Case OMN-17. Extending the test interval for up to approximately seven months beyond five years until the October 2010 refueling outage should not adversely affect the
- 3 operational readiness of the MSSVs because the MSSVs were disassembled and inspected prior to the extended test interval. This additional maintenance is beyond what is required by ASME OM Code Mandatory Appendix I when testing safety valves on a 5-year interval and justifies extension of the test interval for up to seven months beyond five years while providing an acceptable level of quality and safety.
4.0 CONCLUSION
As set forth above, the NRC staff determined that the Alternative REL-004 is acceptable for CNP-2 MSSVs 2-SV-2B-1 and 2-SV-3-1. Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME Code's requirements. Therefore, the NRC staff authorizes the alternative in REL-004 for Cf\\lP-2 MSSVs 2-SV-2B-1 and 2-SV-3-1 on a one-time basis for the period of April 2010 tnrouqh October 2010.
Principal Contributor: Stephen G. Tingen, NRR Date: February 18, 2010
February 18, 2010 Mr. Joseph N. Jensen Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNIT 2 (CNP-2) - EVALUATION OF RELIEF REQUEST (REL-004) (TAC NO. ME3318)
Dear Mr. Jensen:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated February 5,2010, Indiana Michigan Power Company (the licensee) submitted a request for relief for approval of an alternative to a requirement in the American Society of Mechanical Engineers (ASME), Code for the Operation and Maintenance of Nuclear Power Plants (OM Code), for the Donald C. Cook Nuclear Plant,Unit 2 (CNP-2). Specifically, the proposed alternative would be applied to two main steam safety valves (MSSVs) on a one-time basis for the period of April 2010 through October 2010.
The NRC staff has reviewed the proposed relief request and concludes that the alternative in REL-004 is acceptable. The NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes the REL-004 for CNP-2 MSSVs 2-SV-2B-1 and 2-SV-3-1 on a one-time basis for the period of April through October 2010.
If you have any questions, please contact Terry Beltz of my staff at (301) 415-3049.
Sincerely, IRAJ Robert J. Pascarelli, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-316
Enclosure:
Safety Evaluation cc w/encl: Distribution via ListServ Distribution:
PUBLIC RidsNrrDorlLpl3-1 Resource LPL3-1 R/F RidsNrrDciCptb Resource RidsNrrLABTully Resource RidsNrrPMDCCook Resource STingen, NRR/CPTB ADAMS Accession Number: ML100470471
(*) No substantial chances to SE input memo dated 02/17/10 OFFICE LPL3-1/PM LPL3-1/LA NRR/CPTB/BC (*)
LPL3-1/BC NAME TBeitz BTuily AMcMurtray RPascarelli DATE 02/18/10 02/18/10 02/17/10 02/18/10 OFFICIAL RECORD COPY