ML13197A219

Alternative Request G-001 to Adopt ASME Code Case OMN-20, Inservice Test Frequency

ML13197A219
Person / Time
Site:	Millstone
Issue date:	07/08/2013
From:	Grecheck E Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13197A219 (12)

Text

Dominion Nuclear Connecticut, Inc. i r~ o miniow 75000 Dominion Boulevard, Glen Allen, VA 23060 i Web Address: www.dom.com July 8, 2013 U.S. Nuclear Regulatory Commission Serial No.13-367 Attention: Document Control Desk NSSL/MLC RO Washington, DC 20555 Docket Nos. 50-336 50-423 License Nos. DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 ALTERNATIVE REQUEST G-001 TO ADOPT ASME CODE CASE OMN-20.

"INSERVICE TEST FREQUENCY" Pursuant to 10 CFR 50.55a(a)(3)(ii), Dominion Nuclear Connecticut, Inc. (DNC) requests NRC approval of an alternative to the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (i.e., OM Code), 2001 Edition through 2003 Addenda, for Millstone Power Station Units 2 (MPS2) and 3 (MPS3). Specifically, DNC requests approval of an alternative to adopt Code Case OMN-20, "Inservice Test [IST] Frequency," to allow the use of tolerances for ASME OM Code IST frequencies.

For MPS2 and MPS3, these alternatives are being requested for the remainder of the fourth and third 10-year IST intervals, respectively, which both began on December 2, 2008 and will end on December 1, 2018.

The bases for the proposed alternative requests are provided in Attachment 1 for MPS2 and Attachment 2 for MPS3.

If you have any questions regarding this submittal, please contact Wanda Craft at (804) 273-4687.

Sincerely, Eugene S. Grecheck Vice President - Nuclear Engineering and Development Attachments:

1. Millstone Power Station Unit 2, Alternative Request G-001 to Adopt ASME Code Case OMN-20, "Inservice Test Frequency," for Fourth 10-Year IST Interval

2. Millstone Power Station Unit 3, Alternative Request G-001 to Adopt ASME Code Case OMN-20, "Inservice Test Frequency," for Third 10-Year IST Interval Ao q -1

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Serial No.13-367 Docket Nos. 50-336, 50-423 Page 2 of 2 Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region-I 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713 J. S. Kim Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.13-367 Docket No. 50-336 ATTACHMENT I ALTERNATIVE REQUEST G-001 TO ADOPT ASME CODE CASE OMN-20, "INSERVICE TEST FREQUENCY" FOR FOURTH 10-YEAR IST INTERVAL MILLSTONE POWER STATION UNIT 2 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.13-367 Docket No. 50-336 Attachment 1, Page 1 of 4 Proposed Alternative In accordance with 10CFR50.55a(a)(3)(ii)

--Hardship or Unusual Difficulty without a Compensating Increase in Level of Quality or Safety--

ASME Code Component(s) Affected All pumps and valves contained within the Inservice Testing (IST) Program

Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (i.e., OM Code), 2001 Edition through 2003 Addenda Aoolicable Code Reauirement(s)

This request applies to the frequency specifications of the ASME OM Code paragraphs as identified below. The frequencies for tests given in the ASME OM Code do not include a tolerance band.

Code Paragraph Description "The frequency for the inservice testing shall be in accordance with the ISTA-3120(a) requirements of Section IST."

ISTB-3400 Frequency of Inservice Tests ISTC-3510 Exercising Test Frequency ISTC-3540 Manual Valves ISTC-3630(a) Frequency ISTC-3700 Position Verification Testing "At least one valve from each group shall be disassembled and examined at ISTC-5221 (c)(3) each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

Appendix 1, 1-1320 Test Frequencies, Class 1 Pressure Relief Valves Appendix 1,1-1330 Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Test Frequencies - Class 1 Pressure Relief Valves that are used for Thermal Relief Application Appendix 1,1-1350 Test Frequencies - Class 2 and 3 Pressure Relief Valves Appendix 1, 1-1360 Test Frequencies - Class 2 and 3 Nonreclosing Pressure Relief Devices Test Frequencies - Class 2 and 3 Primary Containment Vacuum Relief Appendix 1,1I-1370 Vle Valves Test Frequencies - Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Test Frequencies - Class 2 and 3 Pressure Relief Valves that are used for Thermal Relief Application Appendix IAppendi) II, 1), Performance Improvement Activities Interval 11-4000(a)(1)

Appendixb1, Optimization of Condition Monitoring Activities Interval 11-4000(b)(1 )(e)

Serial No.13-367 Docket No. 50-336 Attachment 1, Page 2 of 4 Reason for Reauest Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), an alternative is being requested from the frequency specifications of the ASME OM Code for Millstone Power Station Unit 2 (MPS2). The basis of the alternative request is that the Code frequency specifications present an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section IST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have historically been interpreted as "nominal" frequencies (generally as defined in the Table 3.2 of NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 1) and owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specifications (TSs) Surveillance Requirements (SRs). The TSs typically allow for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (MPS2 TS 4.0.2).

However, Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements (SRs) 3.0.2 and 3.0.3 to Administrative Controls Program Tests, states that SR 3.0.2 and 3.0.3 cannot be applied to TS 5.5, Programs and Manuals, for tests that are not associated with a TS SR. MPS2 TS 4.0.2 is equivalent to SR 3.0.2 contained in NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants.

The lack of a tolerance band on the ASME OM Code IST frequency restricts operational flexibility. There may be a conflict where a surveillance test could be required (i.e., its frequency could expire), but where it is not possible or not desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation (LCO) is within its applicability.

The NRC recognized this potential issue in the TSs by allowing a frequency tolerance as described in MPS2 TS 4.0.2. The lack of a similar tolerance applied to OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility. Thus, just as with TS-required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling surveillance tests and minimizes conflict between the need to complete the surveillance and plant conditions.

Prooosed Alternative and Basis for Use Code Case OMN-20 is included in the ASME OM Code, 2009 Edition, and is proposed for use as an alternative in determining acceptable tolerances for pump and valve test frequencies of the ASME OM Code. This code case was approved by the ASME OM Code Standards Committee in February 2012.

The requirements of Code Case OMN-20 are described below.

ASME OM, Division 1, Section IST and earlier editions and addenda of ASME OM Code specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2

Serial No.13-367 Docket No. 50-336 Attachment 1, Page 3 of 4 years) or on the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenance) as discussed below.

a) Components whose test frequencies are based on elapsed time periods shall be tested at the frequencies specified in Section IST with a specified time period between tests as shown in the table below. The specified time period between tests may be reduced or extended as follows:

1) For periods specified as less than 2 years, the period may be extended by up to 25% for any given test.

2) For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test.

3) All periods specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement).

Period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g., performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used as a routine action for mere operational convenience.

Period extensions may also be applied to accelerated test frequencies (e.g., pumps in Alert Range) and other less than two year test frequencies not specified in the table below.

Period extensions may not be applied to the test frequency requirements specified in Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers)in Light-Water ReactorNuclear Power Plants, as Subsection ISTD contains its own rules for period extensions.

Frequency Specified Time Period Between Tests,::

Quarterly (or every 3 months) 92 days Semiannually (or every 6 months) 184 days Annually (or every year) 366 days x Years x calendar years where 'x' is a whole number of years ->2 b) Components whose test frequencies are based on the occurrence of plant conditions or events may not have their period between tests extended except as allowed by ASME OM, Division: 1, Section IST, 2009 Edition through OMa-2011 Addenda and earlier editions and addenda.

Serial No.13-367 Docket No. 50-336 Attachment 1, Page 4 of 4 Duration of Proposed Alternative This proposed alternative will be utilized for the remainder of the MPS2 fourth 10-year IST interval, which began on December 2, 2008 and will end on December 1, 2018.

Precedents The proposed alternative request for MPS2 is similar to the following approved or pending alternative/relief requests shown below:

1) Alternative Request RV-01 was approved by the NRC for Quad Cities Units 1 and 2 on February 14, 2013 (ADAMS Accession No. ML13042A348).

2) Exelon Letter TMI-12-168, Submittal of Relief Requests Associated with the Fifth Inservice Testing Interval, November 7, 2012 (ADAMS Accession No. ML12313A344).

3) Virginia Electric and Power Company, Surry Units 1 and 2, Inservice Testing Program for Pumps and Valves, Fifth Ten Year Interval Update and Associated Relief Requests, May 1, 2013 (ADAMS Accession No. ML13128A104).

4) South Carolina Electric and Gas Company, Virgil C. Summer Unit 1, Request Relief from ASME Code Requirements in VCSNS 4th Ten Year Inservice Inspection Interval, RR-4-01 (G) IST Pump and Valve Surveillance Requirements.... May 16, 2013 (ADAMS Accession No. ML13140A008).

References

1) ASME OM Code, 2001 Edition, Addenda through 2003.

2) Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests.

3) NUREG-1482, Revision 1, Guidelines for Inservice Testing at Nuclear Power Plants.

4) NUREG-1432, Revision 4.0, Standard Technical Specifications, Combustion Engineering Plants.

'Serial No.13-367 Docket No. 50-423 ATTACHMENT 2 ALTERNATIVE REQUEST G-001 TO ADOPT ASME CODE CASE OMN-20.

"INSERVICE TEST FREQUENCY" FOR THIRD 10-YEAR IST INTERVAL MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.13-367 Docket No. 50-423 Attachment 2, Page 1 of 4 Proposed Alternative In accordance with IOCFR50.55a(a)(3)(ii)

--Hardship or Unusual Difficulty without a Compensating Increase in Level of Quality or Safety--

ASME Code ComDonent(s) Affected All pumps and valves contained within the Inservice Testing (IST) Program ADolicable Code Edition and Addenda American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (i.e., OM Code), 2001 Edition through 2003 Addenda Applicable Code Reauirement(s)

This request applies to the frequency specifications of the ASME OM Code. The frequencies for tests given in the ASME OM Code do not include a tolerance band.

Code Paragraph Description ISTA-3120(a) "The frequency for the inservice testing shall be in accordance with the requirements of Section IST."

ISTB-3400 Frequency of Inservice Tests ISTC-3510 Exercising Test Frequency ISTC-3540 Manual Valves ISTC-3630(a) Frequency ISTC-3700 Position Verification Testing ISTC-5221 (c)(3) "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

Appendix 1,1-1320 Test Frequencies, Class 1 Pressure Relief Valves Appendix 1,1-1330 Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Appendix 1,1-1340 Test Frequencies - Class 1 Pressure Relief Valves that are used for Thermal Relief Application Appendix 1,1-1350 Test Frequencies - Class 2 and 3 Pressure Relief Valves Appendix 1,1-1360 Test Frequencies - Class 2 and 3 Nonreclosing Pressure Relief Devices Appendix 1, 1-1370 Test Frequencies - Class 2 and 3 Primary Containment Vacuum Relief Valves Appendix 1,1-1380 Test Frequencies - Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Appendix 1,1-1390 Test Frequencies - Class 2 and 3 Pressure Relief Valves that are used for Thermal Relief Application Appendix Appendix II, 11, Performance Improvement Activities Interval 11-4000(a)(1)

Appendix II, Appendix11,e Optimization of Condition Monitoring Activities Interval 11-4000(b)(1 )(e)II

Serial No.13-367 Docket No. 50-423 Attachment 2, Page 2 of 4 Reason for Reauest Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), an alternative is being requested from the frequency specifications of the ASME OM Code for Millstone Power Station Unit 3 (MPS3). The basis of the alternative request is that the Code frequency specifications present an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section IST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have historically been interpreted as "nominal" frequencies (generally as defined in the Table 3.2 of NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 1) and owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specifications (TSs) Surveillance Requirements (SRs). The TSs typically allow for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (MPS3 TS 4.0.2).

However, Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests, states that SR 3.0.2 and 3.0.3 cannot be applied to TS 5.5, Programs and Manuals, for tests that are not associated with a TS SR. MPS3 TS 4.0.2 is equivalent to SR 3.0.2 contained in NUREG-1431, Standard Technical Specifications, Westinghouse Plants.

The lack of a tolerance band on the ASME OM Code IST frequency restricts operational flexibility. There may be a conflict where a surveillance test could be required (i.e., its frequency could expire), but where it is not possible or not desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation (LCO) is within its applicability.

The NRC recognized this potential issue in the TSs by allowing a frequency tolerance as described in MPS3 TS 4.0.2. The lack of a similar tolerance applied to OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility. Thus, just as with TS-required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling surveillance tests and minimizes conflict between the need to complete the surveillance and plant conditions.

Proposed Alternative and Basis for Use Code Case OMN-20 is included in the ASME OM Code, 2009 Edition, and is proposed for use as an alternative in determining acceptable tolerances for pump and valve test frequencies of the ASME OM Code. This code case was approved by the ASME OM Code Standards Committee in February 2012.

The requirements of Code Case OMN-20 are described below.

ASME OM, Division 1, Section IST and earlier editions and addenda of ASME OM Code specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2

Serial No.13-367 Docket No. 50-423 Attachment 2, Page 3 of 4 years) or on the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenance) as discussed below.

a) Components whose test frequencies are based on elapsed time periods shall be tested at the frequencies specified in Section IST with a specified time period between tests as shown in the table below. The specified time period between tests may be reduced or extended as follows:

1) For periods specified as less than 2 years, the period may be extended by up to 25% for any given test.

2) For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test.

3) All periods specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement).

Period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g., performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used as a routine action for mere operational convenience.

Period extensions may also be applied to accelerated test frequencies (e.g., pumps in Alert Range) and other less than two year test frequencies not specified in the table below.

Period extensions may not be applied to the test frequency requirements specified in Subsection ISTD, Preserviceand Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-waterReactorNuclear Power Plants, as Subsection ISTD contains its own rules for period extensions.

Frequency Specified Time Period Between Tests Quarterly (or every 3 months) 92 days Semiannually (or every 6 months) 184 days Annually (or every year) 366 days x Years x calendar years where 'x is a whole number of years >2 b) Components whose test frequencies are based on the occurrence of plant conditions or events may not have their period between tests extended except as allowed by ASME OM Division: 1 Section IST 2009 Edition through OMa-2011 Addenda and earlier editions and addenda of ASME OM Code.

Serial No.13-367 Docket No. 50-423 Attachment 2, Page 4 of 4 Duration of Prooosed Alternative This proposed alternative will be utilized for the remainder of the MPS3 third 10-year IST interval, which began on December 2, 2008 and will end on December 1, 2018.

Precedents The proposed alternative request for MPS3 is similar to the following approved or pending alternative/relief requests shown below:

1) Alternative Request RV-01 was approved by the NRC for Quad Cities Units 1 and 2 on February 14, 2013 (ADAMS Accession No. ML13042A348).

2) Exelon Letter TMI-1 2-168, Submittal of Relief Requests Associated with the Fifth Inservice Testing Interval, November 7, 2012 (ADAMS Accession No. ML12313A344).

3) Virginia Electric and Power Company, Surry Units 1 and 2, Inservice Testing Program for Pumps and Valves, Fifth Ten Year Interval Update and Associated Relief Requests, May 1, 2013 (ADAMS Accession No. ML13128A104).

4) South Carolina Electric and Gas Company, Virgil C. Summer Unit 1, Request Relief from ASME Code Requirements in VCSNS 4 th Ten Year Inservice Inspection Interval, RR-4-01 (G) IST Pump and Valve Surveillance Requirements..., May 16, 2013 (ADAMS Accession No. ML13140A008).

References

1) ASME OM Code, 2001 Edition, Addenda through 2003.

2) Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests.

3) NUREG-1482, Revision 1, Guidelines for Inservice Testing at Nuclear Power Plants.

4) NUREG-1431, Revision 4.0, Standard Technical Specifications, Westinghouse Plants.