ML14144A002

Relief Request No. VR-03 Related to the Inservice Testing Program for the Fourth 10-Year Interval

ML14144A002
Person / Time
Site:	Duane Arnold
Issue date:	06/09/2014
From:	Robert Carlson Plant Licensing Branch III
To:	Richard Anderson NextEra Energy Duane Arnold
M Chawla, NRR/DORL 415-8371
References
TAC MF3076
Download: ML14144A002 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 9, 2014 Mr. Richard L. Anderson Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, lA 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - RELIEF REQUEST NO. VR-03 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FOURTH 10-YEAR INVERVAL (TAC NO. MF3076)

Dear Mr. Anderson :

By letter dated October 28, 2013 (Agencywide Document Access and Management System (ADAMS) Accession No. ML13308A318), as supplemented by letter dated April 30, 2014 (ADAMS Accession Number ML14126A599), NextEra Energy Duane Arnold , LLC (the licensee) submitted alternative request VR-03 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives to and relief from 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 program at Duane Arnold Energy Center (Duane Arnold) for the fourth 10-year 1ST program interval , which began on February 1, 2006, and is scheduled to end on January 31 , 2016.

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 VR-03 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.

As set forth above, the NRC staff determines that alternative request VR-03 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). Therefore , the NRC staff authorizes alternative request VR-03 at Duane Arnold for the remainder of the fourth 10-year 1ST interval which began on February 1, 2006, and is scheduled to end on January 31 , 2016.

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

R. Anderson If you have any questions, please contact the Project Manager, Mahesh Chawla at 301-415-8371 or via e-mail at Mahesh.chawla@nrc.gov.

Sincerely, Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

Safety Evaluation cc w/encls: Distribution via ListServ

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST NO. VR-03 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FOURTH 10-YEAR INTERVALS NEXTERA ENERGY DUANE ARNOLD. LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 TAC NO. MF3076

1.0 INTRODUCTION

By letter dated October 28, 2013 (Agencywide Document Access and Management System (ADAMS) Accession No. ML13308A318), as supplemented by letter dated April 30, 2014 (ADAMS Accession Number ML14126A599), NextEra Energy Duane Arnold, LLC, the licensee, submitted alternative request VR-03 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives to and relief from 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 program at Duane Arnold Energy Center (Duane Arnold) for the fourth 10-year 1ST program interval , which began on February 1, 2006, and is scheduled to end on January 31 , 2016.

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 VR-03 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.

10 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 Duane Arnold fourth 10-year 1ST interval began on February 1, 2006, and is scheduled to end on January 31 , 2016. The fourth interval 1ST program code of record is the ASME OM Code, 2001 Edition through 2003 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 VR-03 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 :

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"The frequency for the inservice testing shall be in accordance with the ISTA-3120(a) requirements of Section 1ST."

ISTB-3400 Frequency of lnservice 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 I, 1-1320 Test Frequencies, Class 1 Pressure Relief Valves Appendix I, 1-1330 Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Test Frequencies- Class 1 Pressure Relief Valves that are used for Appendix I, 1-1340 Thermal Relief Application Appendix I, 1-1350 Test Frequencies- Class 2 and 3 Pressure Relief Valves Appendix I, 1-1360 Test Frequencies- Class 2 and 3 Nonreclosing Pressure Relief Devices Test Frequencies - Class 2 and 3 Primary Containment Vacuum Relief Appendix 1, 1-1370 Valves Test Frequencies - Class 2 and 3 Vacuum Relief Valves Except for Primary Appendix I, 1-1 380 Containment Vacuum Relief Valves Test Frequencies- Class 2 and 3 Pressure Relief Valves that are used for Appendix I, 1-1390 Thermal Relief Application Appendix II ,

Performance Improvement Activities Interval ll-4000(a)(1)

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

Reason for Request

ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the ASME OM Code . The frequencies (e .g., quarterly) have always been interpreted as "nominal" frequencies and are defined in plant technical specification (TS)

Section 5.5.6, "Administrative Controls, Programs and Manuals- lnservice Testing Program."

The licensee routinely applied the surveillance extension time period (i.e., grace period) contained in the plant TS Surveillance Requirement (SR) applicability, specifically SR 3.0.2.

The TS allows 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.

However, regulatory issues have been raised concerning the applicability of the TS "grace period" to ASME OM Code-required 1ST frequencies irrespective of allowances provided under TS SR 3.0.2.

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 TS SR 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, minimizing 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, lnservice 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. This alternative will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the 1ST program. The text of Code Case OMN-20 is shown below.

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 two years, the period may be extended by up to 25 percent for any given test.

2) For periods specified as greater than or equal to two 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 two-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)

An nually 366 days (or every yea r) x years x ca lendar years where x is a who le nu mber of years ;:: 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 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 ASME 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 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 IST.

4.0 CONCLUSION

As set forth above, the NRC staff determines that alternative request VR-03 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) . Therefore, the NRC staff authorizes alternative request VR-03 at Duane Arnold for the remainder of the fourth 10-year 1ST interval which began on February 1, 2006, and is scheduled to end on January 31 , 2016.

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

Principle Contributor: Gurjendra S. Bedi , NRR

R. Anderson If you have any questions, please contact the Project Manager, Mahesh Chawla at 301-415-8371 or via e-mail at Mahesh .chawla@nrc.gov.

Sincerely, IRA/

Robert D. Carlson , Chief Plant Licensing Branch II 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

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PUBLIC LPL3-1 r/f RidsNrrDorllpl3-1 Resource RidsNrrPMDuaneArnold Resource RidsNrrLAMHenderson Resource RidsOgcRp Resource RidsAcrsAcnw MaiiCTR Resource RidsNrrDirsltsb Resource GBedi, EPNB RidsRgn3MaiiCenter Resource RidsNrrDoriDpr Resource ADAMS ACCESSION No.: ML14144A002 *via memo- ML14127A218 OFFICE LPL3-1/PM LPL3-1/LA EPNB/BC* LPL3-1/BC NAME Mahesh Chawla MHenderson Tlupold RCarlson DATE 06/06/14 06/02/14 05/06/14 06/9/14 OFFICIAL RECORD COPY