ML14084A407
| ML14084A407 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/27/2014 |
| From: | Robert Pascarelli Plant Licensing Branch II |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| Pascarelli R, NRR/DORL/LPLII-1 | |
| References | |
| TAC MF2506, TAC MF2507 | |
| Download: ML14084A407 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 March 27, 2014
SUBJECT:
NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, FOURTH 10-YEAR INTERVAL INSERVICE TESTING (1ST) PROGRAM REQUIREMENTS-ALTERNATIVE REQUEST G-1 (TAC NOS. MF2506 AND MF 2507)
Dear Mr. Heacock:
By letter dated July 17, 2013, Virginia Electric and Power Company, the licensee, submitted alternative request G-1 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives 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 the 1ST programs at North Anna Power Station, Units 1 and 2, for the fourth 1 0-year 1ST program intervals. Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in G-1 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.
The NRC staff determined that alternative request G-1 provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable. Therefore, the NRC staff authorizes alternative request G-1 at North Anna Power Station, Units 1 and 2, for the remainder of the fourth 1 0-year 1ST program intervals which are scheduled to end on December 14, 2020.
If you have any questions concerning this matter. please contact Dr. Sreenivas at (301) 415-2597.
Docket Nos.: 50-338 and 50-339
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv Sincerely, Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOURTH 10-YEAR INTERVAL INSERVICE TESTING (1ST)
RELIEF REQUEST G-1 NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 VIRGINA ELECTRIC AND POWER COMPANY DOCKET NOS. 50-338 AND 50-339
1.0 INTRODUCTION
By letter dated July 17, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13204A117}, Virginia Electric and Power Company, the licensee, submitted alternative request G-1 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives 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 the 1ST programs at North Anna Power Station, Units 1 and 2, for the fourth 1 0-year 1ST program intervals.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in G-1 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.
2.0 REGULATORY EVALUATION
10 CFR 50.55a(f), "lnservice Testing Requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda.
1 0 CFR 50.55a(a)(3}, states, in part, that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The North Anna Power Station, Units 1 and 2, fourth ten-year 1ST intervals both began on December 15, 2010, and are currently scheduled to end on December 14, 2020 (ADAMS Accession No. ML093350600). Both 1ST programs comply with the ASME OM Code, 2004 Edition, no addenda.
Enclosure Based on the above, and subject to the NRC's findings with respect to authorizing the proposed alternatives to the ASME OM Code given below, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternatives requested by the licensee.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Alternative Request G-1 This request applies to the test frequency specifications of the ASME OM Code. The frequencies for tests given in the ASME OM Code include the following, but do not include a tolerance band:
i Code Paragraph Description l
i ISTA-3120(a)
'The frequency for the inservice testing shall be in accordance with the requirements ()f ~ection J§"f_~".
-~-~---~*.
ISTB-3400 Frequency of lnservi_~e Tests M---*
ISTC-3510 Exercising Test Frequency t-*
IISTC-3540 Manual Valves I ISTC-3630(a) -
Frequency
--~---*- **--*
~ ISTC-3700 Position Verification Testing I
"At least one valve from each group shall be disassembled and examined at IISTC-5221 (c)(3) each refueling outage; all valves in a group shall be disassembled and examined at least ()nee every 8 ye~E~:"
Appendix I. 1-1320 Test Frequencie!~Ciass 1 Pressure Relief Valves_
lApp~~dix I, 1-1330 Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices r Appendix I, 1-1340 Test Frequencies-Class 1 Pressure Relief Valves that are used for
~-
Thermal Relief Applicati9_r:'.
1 Appendix_l.:_l-1350 Test Frequencies- ~lass 2 and 3 Pressure Relief Valv~~
! Appendix I, 1-1360 Test Frequencies-Class 2 and 3 N_~~reclosing Pressure Relief De~ices i
Test Frequencies - Class 2 and 3 Primary Containment Vacuum Relief Appendix 1, 1-1370 Valves
-~** ***--
Appendix I. 1-1380 Test Frequencies-Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Appendix I, 1-1390 Test Frequencies-Class 2 and 3 Pressure Relief Valves that are used for Thermal Relief Ap~lication Appendix II, Performance Improvement Activities Interval
-J ll-4000(a)( 1)
Appendix II, Optimization of Condition Monitoring Activities Interval
- ll-4000(b)(1)(e)
L
Reason for Request
ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG-1482, Revision 1 [2]) and owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specification (TS) Surveillance Requirements (SRs). The TSs typically allow for a less than or equal to 25 percent extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance. (Reference North Anna Power Station, Units 1 and, 2 TS 3.0.2.) However, regulatory issues have been raised concerning the applicability of the TS grace period to ASME OM Code-required 1ST frequencies.
The lack of a tolerance band on the ASME OM Code 1ST frequencies restricts operational flexibility. There may be a conflict where 1ST could be required (i.e., the 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 is within its applicability.
The NRC recognized this potential issue in the TSs by allowing a frequency tolerance as described in North Anna Power Station, Units 1 and 2, TS 3.0.2. The lack of a similar tolerance applied to the ASME 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 ASME OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling ISTs that minimize the conflicts between the need to complete the testing and plant conditions.
Proposed Alternative The licensee proposes to adopt ASME OM Code Case OMN-20, /nservice Test Frequency, which was published in conjunction with ASME OM Code, 2012 Edition. The purpose of this code case is to prescribe a methodology for determining acceptable tolerances for pump and valve test frequencies. The text of Code Case OMN-20 is shown below. This proposed alternative will be utilized for the remainder of the North Anna Power Station, Units 1 and 2, fourth 1 0-year 1ST intervals, which both began on December 15, 2010, and are currently scheduled to end on December 14, 2020. This alternative will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the 1ST Program scope.
Code Case OMN lnservice Test Frequency 1
Test Frequency Grace ASME OM, Division 1, Section 1ST and all earlier editions and addenda specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2 yr, etc.) or the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenance, etc.).
(a) Components whose test frequencies are based on elapsed time periods shall be tested at the frequencies specified in Section 1ST with a specified time period between tests as shown in Table
- 1. The specified time period between tests may be reduced or extended as follows:
- 1) For periods specified as fewer 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 repeatedly merely as an operational convenience to extend test intervals beyond those specified.
Period extensions may also be applied to accelerated test frequencies (e.g., pumps in alert range) and other fewer than 2-year test frequencies not specified in Table 1.
Period extensions may not be applied to the test frequency requirements specified in Subsection ISTD, Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-water Reactor Nuclear Power Plants, as Subsection ISTD contains its own rules for period extensions.
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 1ST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda.
Table 1 Specified Test Frequencies Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 mo)
Semiannually 184 days (or every 6 mo)
Annually 366 days (or every year) x years x calendar years where xis a whole number of years~ 2 3.2
NRC Staff Evaluation
Historically, licensees have applied and the NRC staff has accepted the standard TS definitions for 1ST intervals (including allowable interval extensions) to ASME OM Code required testing.
(Reference NUREG-1482 Revision 2, Section 3.1.3). Recently, the NRC staff reconsidered the allowance of using TS testing intervals and interval extensions for 1ST not associated with TS SRs.
As noted in Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests," the NRC determined that programmatic test frequencies can't be extended in accordance with the TS SR 3.0.2. This includes all 1ST described in the ASME OM Code not specifically required by the TS SRs.
Following this development, the NRC staff sponsored and co-authored an ASME OM Code inquiry and Code Case to modify the ASME OM Code to include TS-Iike test interval definitions and interval extension criteria. The resultant ASME Code Case OMN-20, as shown above, was approved by the ASME Operation and Maintenance Standards Committee on February 15, 2012, with the NRC representative voting in the affirmative. ASME Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code, 2012 Edition. The licensee proposes to adopt Code Case OMN-20.
Requiring the licensee to meet the ASME OM Code requirements, without an allowance for defined frequency and frequency extensions for 1ST of pumps and valves, results in a hardship without a compensating increase in the level of quality and safety. Based on the prior acceptance by the NRC staff of the similar TS test interval definitions and interval extension criteria, the NRC staff finds that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. Allowing usage of ASME Code Case OMN-20 provides reasonable assurance of operational readiness of pumps and valves subject to the ASME OM Code 1ST.
4.0 CONCLUSION
As set forth above, the NRC staff determines that for alternative request G-1, the proposed alternative provides reasonable assurance that the affected components are operationally ready.
Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable. Therefore, the NRC staff authorizes alternative request G-1 at North Anna Power Station, Units 1 and 2, for the remainder of the fourth 1 0-year 1ST program intervals which are scheduled to end on December 14, 2020.
Principle Contributor: John Billerbeck, NRR.
Date: March 27, 2014
Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 March 27, 2014
SUBJECT:
NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, FOURTH 10-YEAR INTERVAL INSERVICE TESTING (1ST) PROGRAM REQUIREMENTS-ALTERNATIVE REQUEST G-1 (TAC NOS. MF2506 AND MF 2507)
Dear Mr. Heacock:
By letter dated July 17, 2013, Virginia Electric and Power Company, the licensee, submitted alternative request G-1 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives 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 the 1ST programs at North Anna Power Station, Units 1 and 2, for the fourth 1 0-year 1ST program intervals. Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in G-1 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.
The NRC staff determined that alternative request G-1 provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 1 0 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable. Therefore, the NRC staff authorizes alternative request G-1 at North Anna Power Station, Units 1 and 2, for the remainder of the fourth 1 0-year 1ST program intervals which are scheduled to end on December 14, 2020.
If you have any questions concerning this matter, please contact Dr. Sreenivas at (301) 415-2597.
Sincerely, Ira/
Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-338 and 50-339
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION:
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DATE 3/22/14 3/27/14 3/13/14 OFFICIAL RECORD COPY RidsRgn2MaiiCenter Resource RidsNrrLASFigueroa Resource JBillerbeck, NRR db
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':JY ema1 ate arc 3,2014 NRR/LPL2-1/BC RPascarelli 3/27/14