ML14113A346

Relief from the Requirements of the ASME Code

ML14113A346
Person / Time
Site:	Surry
Issue date:	04/25/2014
From:	Robert Pascarelli Plant Licensing Branch II
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Barillas M
References
TAC MF1813, TAC MF1814
Download: ML14113A346 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 25, 2014 Mr. David A Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Blvd.

Glenn Allen, VA 23060

SUBJECT:

SURRY POWER STATION, UNITS 1 AND 2- RELIEF FROM THE REQUIREMENTS OF THE ASME CODE (TAC NOS. MF1813 AND MF1814)

Dear Mr. Heacock:

By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), Virginia Electric and Power Company (Dominion), the licensee, submitted Relief Request P-2 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative is associated with inservice testing (1ST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through 2006 Addenda for the fifth 10-year interval 1ST program at Surry Power Station (Surry) Units 1 and 2.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(f)(6)(i),

the licensee requested relief and proposed to use alternative requirements for ASME OM Code Group A tests for the residual heat removal (RHR) pumps in Surry, Units 1 and 2, 1ST program on the basis that the code requirement is impractical. The licensee proposed alternatives to the requirements of ISTB-3400, "Frequency of lnservice Tests" and ISTB Table of 3400-1, "lnservice Test Frequency" for Surry, Units 1 and 2.

The NRC staff reviewed Relief Request P-2 and concludes, as set forth in the enclosed safety evaluation, that Dominion adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(f)(6)(i) and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff grants Relief Request P-2, for the Surry, Units 1 and 2, fifth 10-year 1ST intervals which are scheduled to begin on May 10, 2014, and end on May 9, 2024.

D. Heacock If you have any questions, please contact the Project Manager, Martha Barillas at 301-415-2760 or via e-mail at martha.barillas@nrc.gov.

Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos: 50-280 and 50-281

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 NO. P-2 REGARDING RESIDUAL HEAT REMOVAL PUMPS VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-280 AND 50-281

1.0 INTRODUCTION

By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), Virginia Electric and Power Company (Dominion), the licensee, submitted Relief Request P-2 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative is associated with inservice testing (1ST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through 2006 Addenda for the fifth 10-year interval 1ST program at Surry Power Station (Surry) Units 1 and 2.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(f)(6)(i),

the licensee requested relief and proposed to use alternative requirements for ASME OM Code Group A tests for the Residual Heat Removal (RHR) pumps in Surry, Units 1 and 2, 1ST program on the basis that the code requirement is impractical. The licensee proposed alternatives to the requirements of ISTB-3400, "Frequency of lnservice Tests" and ISTB Table of 3400-1, "lnservice Test Frequency."

2.0 REGULATORY EVALUATION

10 CFR Section 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 except where alternatives have been authorized by the NRC pursuant to paragraphs (a)(3)(i) or (a)(3)(ii).

10 CFR 50.55a(a)(3) states, in part, that alternatives to the requirements of paragraph (f) may be used, when authorized by the NRC, if the applicant demonstrates that: (i) the proposed alternatives would provide 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.

Enclosure

10 CFR 50.55a(f)(5)(iii), states, in part, that if licensees determine that conformance with certain code requirements is impractical, the licensee shall notify the Commission and submit information in support of the determination.

10 CFR 50.55a(f)(6)(i), states that the Commission will evaluate determinations under paragraph (f)(S) of this section that code requirements are impractical. The Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Surry, Units 1 and 2, fifth 10-year 1ST program intervals are scheduled to begin on May 10, 2014, and end on May 9, 2024.

Based on the above, the NRC staff finds that it has the regulatory authority to grant the proposed alternatives of the ASME OM Code, as requested by Dominion.

3.0 TECHNICAL EVALUATION

3.1 Surry, Units 1 and 2 ,Alternative Request P-2 In the licensee's submittal, Dominion requested an alternative to ASME OM Code ISTB-3400, "Frequency of lnservice Tests," and Table ISTB-3400-1, "lnservice Test Frequency" for Residual Heat Removal (RHR) pumps 1-RH-P-1 A, 1-RH-P-1 B, 2-RH-P-1 A, and 2-RH-P-1 B.

ISTB-3400, states that an inservice test shall be run on each pump as specified in Table ISTB-3400-1 .

Table ISTB-3400-1, states that Group A tests shall be performed quarterly, and comprehensive pump tests shall be performed biennially.

Reason for Request

The RHR pumps are located inside containment. The pumps are low pressure {600 psig design pressure) pumps that take suction from and discharge to the reactor coolant system (RCS).

The RCS is maintained at 2235 psig and the containment atmosphere is maintained at sub-atmospheric pressure during normal operation. The RHR motor operated suction and discharge isolation valves are interlocked with an output signal from RCS pressure transmitters which prevent the valves from being opened when the RCS pressure exceeds 460 psig.

Therefore, testing the RHR pumps during normal operation is not possible.

Proposed Alternative These pumps will be tested every cold shutdown outage and reactor refueling outage, unless the pump has been tested within the previous three months. During back-to-back cold shutdown or refueling outages, the test period remains valid for three months following each test, and no additional periodic testing needs to be performed within this three month test

period. For a cold shutdown or reactor refueling that extends longer than three months, the pumps will be tested every three months in accordance with the Table IST8 3400-1.

3.2 NRC Staff Evaluation RHR pumps 1-RH-P-1A, 1-RH-P-18, 2-RH-P-1A, and 2-RH-P-18 are located inside the containment and are classified as Group A pumps in the 1ST Program. These pumps are low-pressure (600 psig design pressure) pumps that take suction from the RCS hot leg, pass flow through the RHR heat exchangers, and discharge to the RCS cold leg. These pumps are in a standby condition during power operation and only activate when the RCS is at a low pressure and the RHR system is needed. The RHR system is a low-pressure system controlled by two motor-operated valves that are interlocked with RCS pressure transmitters to prevent the motor-operated valves from being opened whenever the RCS system pressure exceeds 460 psig (Surry Updated Final Safety Analysis Report Section 9.3.3.2). This prevents testing of the RHR pumps during normal operations.

Technical Specification (TS} 3.8.A.2 requires the containment to be in a subatmospheric condition when the RCS temperature exceeds 200° F. As such, personnel who enter the containment to perform RHR pump testing when the containment is at subatmospheric pressure are required to wear a self-contained breathing apparatus (SC8A). The SC8A restricts personnel movement and field of vision. This creates a difficult and hazardous environment for personnel conducting vibration testing of the RHR pumps.

The ASME OM Code Table IST8-3400-1 requires that a Group A test be performed quarterly on each Group A pump. The NRC staff has reviewed the Table IST8-3400-1 requirements and has determined that due to the difficulty of wearing a SC8A when performing pump testing, the standby condition of the RHR pumps, and the isolation of the RHR system during power operation, compliance with the quarterly testing requirements is not practical. Major plant and system modifications would be needed in order to implement the ASME OM Code-required quarterly testing of the RHR pumps. These modifications would be costly and burdensome for the licensee and, therefore, not practicable.

As an alternative to the Table IST8-3400-1 requirements, the licensee proposed to test RHR pumps 1-RH-P-1 A, 1-RH-P-1 8, 2-RH-P-1 A, and 2-RH-P-1 8 every cold shutdown outage and reactor refueling outage unless the pump has been tested within the previous 3 months. During back-to-back cold shutdown or refueling outages, the test period remains valid for 3 months following each test, and no additional periodic testing needs to be performed within this 3-month test period. For a cold shutdown or reactor refueling outage that extends longer than 3 months, the pumps will be tested every 3 months in accordance with IST8 3400-1. The NRC staff finds that the licensee's proposed alternative for testing the RHR pumps will provide reasonable assurance that the affected pumps are performing adequately, and imposing the ASME OM Code requirements is impractical.

4.0 CONCLUSION

As set forth above, the NRC staff determines that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Furthermore, the proposed alternative described in Relief Request P-2 provides reasonable assurance that RHR pumps 1-RH-P-1A, 1-RH-P-1 8, 2-RH-P-1A, and 2-RH-P-1 8 are performing adequately. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(f)(5)(iii), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff grants the proposed Relief Request P-2 for the fifth 10-year 1ST interval at Surry, Units 1 and 2, which are schedule to begin on May 10, 2014, and end on May 9, 2024.

All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable.

Principal Contributor: John Huang Date: April 25, 2014

ML14113A346 *via e-mail OFFICE NRR/DORLILPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DE/EPNB* NRR/DORLILPL2-1/BC NAME MBarillas SFigueroa TLupold RPascarelli DATE 4/24/14 4/24/14 2/4/14 4/25/14