ML100541618
| ML100541618 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/05/2010 |
| From: | Keenan J Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N10-0032 | |
| Download: ML100541618 (7) | |
Text
PSEG P.O. Box 236, Hancocks Bridge, NJ 08038-0236 i
0 PSEG Nuclear LLC FEB 0 5 2010 LR-N10-0032 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Nuclear Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
Request for Relief from ASME OM Code Test Intervals for Pressure Relief Valves In accordance with 10 CFR 50.55a, "Codes and Standards," PSEG Nuclear LLC (PSEG), hereby requests NRC approval of proposed Relief Request V-05 to extend the test intervals for certain Class 2 pressure relief valves on a one-time basis until restart after refueling outage R16, which is currently scheduled to begin in October 2010.
PSEG requests approval of the proposed request by April 28, 2010 to permit continued plant operation until R16. The Code of Record for the current third interval is American Society of Mechanical Engineers (ASME) / American National Standards Institute, "Code for Operation and Maintenance of Nuclear Power Plants" (ASME OM Code), 2001 Edition through 2003 Addenda.
The proposed relief request is provided in the attachment to this letter.
There are no commitments contained in this letter.
Aoq-7
Document Control Desk Page 2 LR-N 10-0032 FEB 05 WO If you have any questions or require additional information, please contact Mrs. Erin West at 856-339-5411.
Sincerely,
<Jeitlre IKeenan Manager-Licensing PSEG Nuclear, LLC
Attachment:
- 1.
Relief Request V-05 cc:
S. Collins, Administrator, Region I,.,NRC R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector Hope Creek P. Mulligan, Manager IV; NJBNE T. Devik - Hope Creek Commitment Tracking Coordinator L. Marabella - Corporate Commitment Tracking Coordinator
ATTACHMENT I Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354 Request for Relief from ASME OM Code Test Intervals for Pressure Relief Valves I V-05 I Low Pressure Coolant Injection (LPCI) System Relief Valve Test Interval--
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Hope Creek Generating Station Inservice Test Program 10 CFR 50.55a Request V-05 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii)
Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety
- 1. ASME Code Component(s) Affected Hope Creek Generating Station (HCGS) Low Pressure Coolant Injection (LPCI) System Relief Valves in Table 1 below.
Table 1 Component No.
Description Code Class 1 BCPSV-F025B LPCI Loop B Header Relief Valve 2
1 BCPSV-F025D LPCI Loop D Header Relief Valve 2
2. Applicable Code Edition and Addenda
For the current third 10-year inservice testing (IST) interval, American Society of Mechanical Engineers (ASME) / American National Standards Institute, "Code for Operation and Maintenance of Nuclear Power Plants" (ASME OM Code), 2001 Edition through 2003 Addenda. The third interval began on December 2 1s', 2006 and will end on December 2 0 th 2016.
3. Applicable Code Requirement
ASME OM Code, 2001 Edition through 2003 Addenda, ISTC-5240, "Safety and Relief Valves,"
requires safety and relief valves to meet the inservice test requirements of Mandatory Appendix I, "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants." Section 1-1350(a) requires Class 2 and 3 pressure relief valves, with the exception of pressurized water reactor main steam safety valves, to be tested every 10 years, with a minimum of 20% of the valves from each valve group tested within any 48-month interval. This 20% shall consist of valves that have not been tested during the current 10-year test interval, if they exist. Section 4.3.5 of NUREG-1482, Rev. 1 states in determining the minimum acceptable sample size, fractions of valve numbers resulting from calculating the numbers of valves to be tested are to be rounded to the next higher whole number. Additionally, 1-1390 requires Class 2 and 3 thermal relief valves to be tested every 10 years.
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Hope Creek Unit 1 Inservice Test Program 10 CFR 50.55a Request V-05
4. Reason for Request
During a review of the HCGS Relief Valve section of the IST program in July-2009, PSEG identified discrepancies in the scheduling of periodic relief valve testing. In January 2010, PSEG discovered that two of the previously identified relief valves were improperly categorized as being able to be tested while the station is online. As a result, the 10 year applicable ASME OM Code requirements for testing will be exceeded after April 28, 2010, six months short of R16. PSEG documented the scheduling discrepancies in the corrective action program and performed a review to confirm the extent of condition for relief valve testing issues for Hope Creek Generating Station.
In accordance with 10 CFR 50.55a(a)(3)(ii), PSEG requests relief from the applicable ASME OM Code requirements for 1 BCPSV-F025 B and D and for the LPCI system relief valve sample group until restart from the HCGS refueling outage R16, which is currently scheduled to begin in October 2010. The 10-year test intervals would be extended by approximately 6 months. NUREG-1482, Rev.
1, Section 2.5, "Relief Requests and Proposed Alternatives," states that nuclear power plant licensees may also propose alternatives to ASME Code requirements, if compliance with the specified requirements would result in hardship or unusual difficulty withouta compensating increase in the level of quality and safety. The NRC staff hasinterpreted "hardship" to meanma high degree of difficulty or an adverse impact on plant operation, as illustrated by examples, including:.
- having to enter multiple TS limiting conditions for operation
" inaccessibility,
" replacing equipment or in-line components 1BCPSV-F025 "B" and "D" provide overpressure protection for the LPCI "B" and "D" injection lines respectively.
Removal and testing of the valves is performed when the unit is in a refueling outage because the discharge of these relief valves is connected to the torus and cannot be isolated from containment. Removal of these valves would result in a breach of containment.
Testing 1BCPSV-F025 "B" and "D" before refueling outage R16 would constitute a hardship, due to the inability to isolate the valve discharge piping from the containment during normal plant operation.
In addition, testing 1BCPSV-F025 "B" and "D" before refueling outage R16 can only be accomplished with unusual difficulty. Specifically, the unusual difficulty consists in performing a plant shutdown.
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Hope Creek Unit 1 Inservice Test Program 10 CFR 50.55a Request V-05
5. Proposed Alternative and Basis for Use
PSEG proposes to extend the 10-year test interval for the LPCI system relief valve sample group, listed in Table 2 below for 1 BCPSV-F025 "B" and "D", by approximately 6 months.
Table 2 Valve No.
Description Safety Setpoint Last Class (psig)
Tested 1BCPSV-LPCI Loop 2
Crosby 410 5/01/00 F025B B Header JMB-Relief Valve WR lx1 1BCPSV-LPCI Loop 2
Crosby 410 4/28/00 F025D
'D Header JMB-Relief Valve WR lx1 Aý review of the test history was performed to understand the history of these valves. The LPCI valve group consists of five valves manufactured by Crosby Valve Company. The test history search consisted of reviewing the test data for the valves withinýtiis group over parts ofthe 2 nd anhd 3 rd IST test interval.
The review of the test history of the five LPCI system relief valves showed that all of the valves within this grouping, with the exception 'of the 1BCPSV-F025C, were successfully as-found, lift set, surveillance tested during the IST 2 nd and 3rd Test Interval with no signs of external leakage.:
The history of testing on 1BCPSV-F025C was reviewed back to the 2nd IST Test Interval. The test on 04/20/03 was higher (17.7 psi) than the setpoint tolerance of +3%. A minor adjustment was made and the valve was successfully as-left tested.
Based on the review of plant specific experience described above, PSEG has concluded that the proposed alternative provides reasonable assurance of operational readiness for the LPCI system relief valve group. Therefore, in accordance with 10 CFR 50.55a(a)(3)(ii), this interval inspection extension until HCGS R16 is requested on the basis that compliance with the specified requirements would result in hardship or unusual difficult without a compensating increase in the level of quality and safety.
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Hope Creek Unit 1 Inservice Test Program 10 CFR 50.55a Request V-05
6. Duration of Proposed Alternative
This proposed alternative is requested until the restart after R16, currently scheduled to begin in October 2010. The duration of this extension is approximately 6 months.
7. Precedents
In Reference 1, the NRC authorized a one-time extension of the 48-month test interval to 52 months for seven relief valve sample groups for Donald C. Cook Nuclear Plant Unit 2.
In Reference 2, the NRC authorized a one-time extension of the 10-year test interval for a Class 2 relief valve by approximately 7 months for Point Beach Nuclear Plant, Unit 1.
In Reference 3, the NRC authorized a one-time extension for Class 2 and 3 pressure relief valves by approximately 7 months for Salem Unit 2.
- 8. References
- 1. NRC Safety Evaluation dated October 29, 2001 (TACONo. MB2979),
Donald C. Cook Nuclear Plant, Unit 2, Docket No. 50-3:16.
- 2. NRC Safety Evaluation. datedApril 1, 2004CI(TAC No. MC2046),
Point Beach Nuclear Plant, Unit 1, Docket No. 50-266.
- 3. NRC Safety Evaluation dated March 5, 2009 (TAC No. ME0784),
Salem Generating Station, Unit 2, Docket No, 50-311.
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