ML14247A555

Relief Request IST-RR-01 Regarding the Frequency of Inservice Testing Requirements of the Pumps and Valves

ML14247A555
Person / Time
Site:	Calvert Cliffs
Issue date:	09/24/2014
From:	Benjamin Beasley Plant Licensing Branch 1
To:	George Gellrich Calvert Cliffs, Exelon Generation Co
Morgan N
References
TAC MF3066, TAC MF3067
Download: ML14247A555 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 24, 2014 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2- RELIEF REQUEST IST-RR-01 REGARDING THE FREQUENCY OF INSERVICE TESTING REQUIREMENTS OF THE PUMPS AND VALVES (TAC NOS.

MF3066 AND MF3067)

Dear Mr. Gellrich:

By letter dated October 18, 2013, Calvert Cliffs Nuclear Power Plant, LLC, the licensee, submitted relief request IST-RR-01 for authorization of a proposed alternative to certain inservice testing (1ST) requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) at Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (Calvert Cliffs).

Specifically, the licensee proposed to adopt ASME Code Case OMN-20, "lnservice Test Frequency" for determining acceptable tolerances for pump and valve test frequencies contained within the 1ST program for the remainder of the Calvert Cliffs fourth 10-year 1ST interval, which began on July 1, 2008 and is scheduled to end on June 30, 2018. Pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative on the basis that compliance with the specified requirement would result in hardship without a compensating increase of the level of quality and safety.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed IST-RR-01 and determined that the licensee's proposed alternative provides reasonable assurance that the affected components are operationally ready, as set forth in the enclosed safety evaluation. Accordingly, the NRC staff concludes that the licensee adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii). Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the license's proposed alternative, as described in IST-RR-01, at Calvert Cliffs for the remainder of the fourth 10-year 1ST interval, which began on July 1, 2008 and is scheduled to end on June 30, 2018.

Use of the ASME Code Case OMN-20 is authorized until such time as the ASME Code Case is published in a future version of RG 1.192 and incorporated by reference in 10 CFR 50.55a(b).

At that time, if the licensee intends to continue implementing this ASME Code Case, it must follow all provisions of ASME Code Case OMN-20 with conditions specified in RG 1.192 and limitations as specified in 10 CFR 50.55a(b)(4), (b)(5), and (b)(6), if any.

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

If you have any questions, please contact the Calvert Cliffs Project Manager, Nadiyah S.

Morgan, at (301) 415-1016.

Sincerely, Benjamin G. Beasley, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated 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 IST-RR-01 REGARDING THE FREQUENCY OF INSERVICE TESTING REQUIREMENTS OF THE PUMPS AND VALVES EXELON GENERATION COMPANY, LLC CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318 TAC NOS. MF3066 AND MF3067

1.0 INTRODUCTION

By letter dated October 18, 2013 (Agencywide Document Access and Management System Accession No. ML13296A014), Calvert Cliffs Nuclear Power Plant, LLC, the licensee, submitted relief request IST-RR-01 for authorization of a proposed alternative to certain inservice testing (1ST) requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) at Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (Calvert Cliffs).

Specifically, the licensee proposed to adopt ASME Code Case OMN-20, "lnservice Test Frequency" for determining acceptable tolerances for pump and valve test frequencies contained within the 1ST program for the remainder of the Calvert Cliffs fourth 10-year 1ST interval, which began on July 1, 2008 and is scheduled to end on June 30, 2018. Pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative on the basis that compliance with the specified requirement would result in hardship without a compensating increase of the level of quality and safety.

2.0 REGULATORY EVALUATION

The regulation at 10 CFR 50.55a(f), "lnservice Testing Requirements," states, 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.

Enclosure

The regulation at 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 Nuclear Regulatory Commission (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 Calvert Cliffs fourth 10-year 1ST interval began on July 1, 2008 and is scheduled to end on June 30, 2018. The fourth 10-year interval 1ST program Code of Record is the ASME OM Code 2004 Edition.

Based on the above, and subject to the NRC staff's technical evaluation below, the NRC staff finds that regulatory authority exists to authorize the proposed alternative, as requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Relief Request IST-RR-01 This request applies to the 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.

Code Paragraph Description ISTA-3120(a) The frequency for inservice testing shall be in accordance with the 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 ISTC-5221(c)(3) 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 I, 1-1330 Test Frequency, Class 1 Nonreclosing Pressure Relief Devices Appendix I, 1-1340 Test Frequency, Class 1 Pressure Relief Valves That Are Used For Thermal Relief Application Appendix I, 1-1350 Test Frequency, Classes 2 and 3 Pressure Relief Valves Appendix I, 1-1360 Test Frequency, Classes 2 and 3 Nonreclosing Pressure Relief Devices Appendix I, 1-1370 Test Frequency, Classes 2 and 3 Primary Containment Vacuum Relief Valves Appendix I, 1-1380 Test Frequency, Classes 2 and 3 Vacuum Relief Valves, Except for Primary Containment Vacuum Relief Valves Appendix I, 1-1390 Test Frequency, Classes 2 and 3 Pressure Relief Valves That Are Used for Thermal Relief Application Appendix II**, ll-4000(a)(1) Performance Improvement Activities Interval Appendix II, ll-4000(b)(1 )(e) Optimization of Condition-Monitoring Activities Interval Notes *Appendix I is for Pressure Relief Valves

• • Appendix II is for Check Valve Condition Monitoring Program

Reason for Request

The licensee stated, The 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 Calvert Cliffs Technical Specification (TS) Section 5.5.8, "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 licensee further stated, The lack of a tolerance band on the ASME OM Code 1ST frequencies restricts operational flexibility. There may be a conflict where a surveillance test [1ST]

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 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 surveillance tests [ISTs] and minimizes conflict between the need to complete the surveillance [testing] and plant conditions.

Licensee's Proposed Alternative The licensee proposed 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 ASME 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-20 -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 percent 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 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 OM Standards Committee on February 15, 2012 with the NRC representative voting in the affirmative. The ASME Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code 2012 Edition, and its use is allowed with the ASME OM Code 2009 Edition through 2011 Addenda and all earlier editions and addenda. 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 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 has determined that the proposed alternative provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff has concluded that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii). Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes the license's proposed alternative, as described in IST-RR-01, at Calvert Cliffs for the remainder of the fourth 10 year 1ST interval, which began on July 1, 2008 and is scheduled to end on June 30, 2018.

Use of the ASME Code Case OMN-20 is authorized until such time as the ASME Code Case is published in a future version of RG 1.192 and incorporated by reference in 10 CFR 50.55a(b).

At that time, if the licensee intends to continue implementing this ASME Code Case, it must follow all provisions of ASME Code Case OMN-20 with conditions specified in RG 1.192 and limitations as specified in 10 CFR 50.55a(b)(4), (b)(5), and (b)(6), if any.

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 Date:September 24, 2014

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

If you have any questions, please contact the Calvert Cliffs Project Manager, Nadiyah S.

Morgan, at (301) 415-1016.

Sincerely, IRA/

Benjamin G. Beasley, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDoriLpl1-1 RidsNrrPMCalvertCiiffs LPLI-1 Reading File RidsNrrLAKGoldstein RidsAcrsAcnw_MaiiCTR RidsNrrDoriDpr RidsRgn1 Mail Center RidsNrrDeEpnb R. Wolfgang A. Chereskin ADAMS ACCESSION NO.: ML14247A555 OFFICE LPLI-1/PM LPLI-1/PM LPLI-1/LA NRR/EPNB/BC LPLI-1/BC NAME AChereskin NMorgan KGoldstein DAIIey BBeasley DATE 09/04/2014 9/23/14 09/22/14 07/16/2014 9/24/14 OFFICIAL RECORD COPY