ML14323A599

Relief Request RR-13, Relief from Inservice Testing Requirements to Perform Testing of 4 Valves During the April 2015 Refueling Outage

ML14323A599
Person / Time
Site:	Fort Calhoun
Issue date:	12/02/2014
From:	Eric Oesterle Plant Licensing Branch IV
To:	Cortopassi L Omaha Public Power District
Lyon C
References
TAC MF4167
Download: ML14323A599 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 2, 2014 Mr. Louis P. Cortopassi Site Vice President and Chief Nuclear Officer

. Omaha Public Power District Fort Calhoun Station 9610 Power Lane, Mail Stop FC-2-4 Blair, NE 68008

SUBJECT:

FORT CALHOUN STATION, UNIT NO.1- RELIEF REQUEST RR-13,

• PROPOSED ALTERNATIVE, INSERVICE TESTING OF CERTAIN PRESSURE RELIEF VALVES FOR THE FOURTH 10-YEAR PROGRAM INTERVAL (TAC NO. MF4167)

Dear Mr. Cortopassi:

By letter dated May 16, 2014, Omaha Public Power District (the licensee) requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition through 2000 Addenda for certain pressure relief valves at Fort Calhoun Station, Unit No. 1 (FCS). Pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(a)(3)(ii), the licensee submitted Relief Request RR-13, which requested relief from the current scheduling requirements of ASME OM Code, Appendix I, Section 1-1330 for valves RC-141 and RC-142, and for valves NG-HCV-438B-S2 and Sl-'217 for Section 1-1360, on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii). Therefore, the NRC authorizes the use of Relief Request RR-13 at FCS until the end of the next refueling outage, which is scheduled to begin in April 2015.

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

L. Cortopassi If you have any questions, please contact Fred Lyon at 301-415-2296 or via e-mail at Fred. Lyon@nrc.gov.

Sincerely, Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation*

Docket No. 50-285

Enclosure:

Safety Evaluat_ion 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 RR-13 FOR THE FOURTH 10-YEAR INSERVICE TESTING PROGRAM INTERVAL OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285

1.0 INTRODUCTION

By letter dated May 16, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14136A466), Omaha Public Power District (OPPD, the licensee),

submitted Relief Request RR-13 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 program at Fort Calhoun Station, Unit No. 1 (FCS) for the fourth 10-year 1ST program interval.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) paragraph 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in RR-13 on the basis that compliance with the specified requirements of ASME OM Code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

2.0 REGULATORY EVALUATION

The regulations in 10 CFR 50.55a(f), "lnservice testing requirements,*: require, 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.

Paragraph 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.

FCS's fourth 10-year 1ST interval began on September 25, 2003, and is currently scheduled to end on June 6, 2016 (ADAMS Accession No. ML14022A258). The 1ST program complies with the ASME OM Code, 1998 Edition through 2000 addenda.

Enclosure

Based on this information, and subject to the NRC's findings with respect to authorizing the proposed alternatives to the ASME OM Code given below, the NRC staff concludes 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 RR-13 ASME Code Components Affected This request applies to the test frequency specifications of the ASME OM Code for the below listed relief valves. -

Next Test Valve Number Description Class Due Date RC-141 Pressurizer Relief Valve 1 1/14/2015 RC-142 Pressurizer Relief Valve 1 1/15/2015 Component Cooling Water (CCW) Inlet NG-HCV-4~8B-S2 Valve HCV 438B Nitrogen Accumulator 3 3/6/2015 Supply Low Pressure Relief Valve Sl-217 Safety Injection Tank Sl-68 Relief Valve 2 3/11/2015

Applicable Code Edition and Addenda

By letter dated May 16, 2014, the licensee stated, in part, that Fort Calhoun Station (FCS) is currently in the fourth 10-year lnservice [Testing (1ST)] interval, which as noted in [OPPD's letter dated January 21, 2014, available at ADAMS Accession No. ML14022A258], ends on June 6, 2016. The code of record for the fourth 10-year [1ST] interval is American Society of Mechanical Engineers (ASME) Code for Operation and Maintenanqe of Nuclear Power Plants (ASME OM Code), 1998 Edition through 2000 Addenda ....

Applicable Code Requirements For RC-141 and RC-142:

ASME OM Code, Appendix I, "lnservice Testing of Pressure Relief Devices in* Light-Water Reactor Nuclear Power Plants," Section 1-1330, "Test Frequencies, Class 1 Pressure Relief Valves."

For NG-HCV-438B-S2 and Sl-217:

ASME OM Code, Appendix I, "lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants," Section 1-1360, "Test Frequency, Class 2 and 3 Pressure Relief Valves."

Reason for Request

By letter dated May 16, 2014, the licensee stated, in part, that Pursuant to 10 CFR 50.55a(a)(3)(ii), Omaha Public Power District (OPPD), the licensee for Fort Calhoun Station (FCS) Unit 1, requests relief from the current scheduling requirements of ASME OM Code, Appendix I Sections 1-1330 and 1-1360. The basis of the relief request is that the [ASME OM] Code requirement presents an undue hardship without a compensating increase in the

• level of quality or safety.

A. RC-141 and RC-142 Fort Calhoun Station, Unit No. 1 has two installed pressurizer safety valves.

Technical Specification (TS) 3.2, Table 3-5, Item 3, requires that the pressurizer safety valves be tested to "Verify each pressurizer safety valve is OPERABLE in accordance with the lnservice Testing Program. Following testing, lift settings shall be 2485 psig [pounds per square inch gauge] +/-1%

and 2530 psig +/-1% respectively."

The FCS lnservice Testing Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance-of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda.

Appendix I of the ASME OM Code specifies frequency requirements for testing of pressure relief valves. Requirements applicable to the Fort Calhoun Station pressurizer safety valves appear in Section 1[-]1330, Test Frequencies, Class 1 Pressure Relief Valves. This section specifies that the test interval for any individual valve shall not exceed 5-years. In addition, it indicates that at least 20% of the valves from each valve group shall be tested within any 24-month interval.

Both FCS pressurizer safety valves were removed from service in April 2011 at the end of the last operating cycle (i.e., Operating Cycle 26). At that time, both valves were tested and found to open within the lift settings specified in TS 2.1.6(1) (i.e., 2485 psig + 1%/-3% and 2530 psig + 1%/-3% respectively).

In January 2013, in anticipation of plant restart in 2013, the two pressurizer safety valves that had been removed and tested in April 2011 were re-tested.

The as-left lift settings for these two valves were demonstrated by testing at a vendor facility on January 14, 2013, and January 15, 2013 respectively. The lift settings of both valves were within a tolerance of +/-1% of setpoint, as discussed in the TS 2.1.6 Basis. These valves were subsequently installed and are now in service.

The proposed one-time frequency change would allow performance of the next valve tests during the next scheduled refueling outage that is scheduled to begin April 13, 2015. Technical Specification 2.1.6(1) requires two pressurizer safety valves to be operable in Modes 1 and 2. The valves were required to be operable beginning in December 2013, wben the plant was first returned to Mode 2 after the extended plant shutdown. The period during which the valves are required to be operable will be less than 18 months (i.e., from December 2013 to April 2015). Therefore, the period of required operability will be no longer than a typical operating cycle. Also, the time interval between tests with the proposed frequency change remains well within the maximum 5-year test interval for any individual valve as specified by the ASME OM Code and lnservice Testing Program.

As the valves are sent offsite to a vendor facility, the setpoints were last set in January 2013 with the expectation of startup from the refueling outage in the spring of 2013; therefore, the need for this proposed alternative was not expected.

B. NG-HCV-438B-S2 and Sl-217 The ASME OM Code indicates that applicable Class 2 and 3 pressure relief valves shall be tested at least once every 10 years, and that 20% of the valves from each applicable valve group shall be tested within any 48 month interval. The test intervals for NG-HCV-438B-S2 and Sl-217 have not yet expired, but will expire before the next planned refueling outage (planned for April 2015).

All four valves require a plant shutdown to perform relief valve testing.

Additionally, Fort Calhoun does not have the facilities required to perform set-point tests on large relief and safety valves (RC-141 and RC-142). These valves are unbolted from their mounting flanges, decontaminated, and shipped to an off-site test facility. Because of the lengthy period required for removal, transportation, testing, and re-installation, this would represent a significant hardship.

Proposed Alternative and Basis for Use By letter dated May 16, 2014, the licensee stated, in part, that The proposed alternative is to perform testing of the four valves during the next refueling outage which is scheduled to start in April 2015. This is the next opportunity to perform the required testing.

'Duration of Proposed Alternative By letter dated May *16, 2014, the licensee stated, in part, that The proposed alternative will. be utilized until the next refueling outage scheduled for April 2015.

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, "Guidelines for lnservice Testing at Nuclear Power Plants: lnservice Testing of Pumps and Valves and lnservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants- Final Report," Revision 2, Section 3.1.3; ADAMS Accession No. ML13295A020). Recently, the NRC staff reconsioerecttt-,~ a.llowance of using TS testing intervals and interval extensions for 1ST not associated with TS surveillance requirements (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," dated August 23, 2012 (ADAMS Accession No. ML12079A393), the NRC determined that programmatic test frequencies cannot be extended in accordance with the TS SR 3.0.2.

Following this development, the NRC staff sponsored and c,o-authored an ASME OM Code inquiry I

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 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 does not propose to adopt Code Cas*e OMN-20, but rather proposes one-time extensions to the test intervals for the subject valves that are within the test interval extension criteria of OMN-20.

For RC-141 and RC-142, the licensee proposes an interval extension of approximately 3 months, whereas OMN-20 would 'allow an extension of up to 6 months.

For NG-HCV-438B-S2 and Sl-217, the licensee proposes an interval extension of approximately 1 month, whereas OMN-20 would allow an extension of up to 6 months.

Requiring the licensee to meet the ASME OM Code requirements, without an allowance for frequency extensions for 1ST of these 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 OMN-20 interval extension criteria, the staff concludes that implementation of the test interval extension criteria proposed by tl)e licensee is acceptable and provides reasonable assurance of operational readiness of the subject valves.

4.0 CONCLUSION

. Based on the above, the NRC staff determines that for alternative request RR-13, 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. Therefore, the NRC staff authorizes alternative request RR-13 at FCS until the end of the next refueling outage, which is scheduled to begin in April 2015.

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

Principal Contributor: J. Billerbeck, NRR/DE/EPNB Date: December 2, 2014

ML14323A599 *email dated OFFICE NRR/DORLILPL4-1/PM N RR/DORLILPL4-2/LA NRR/DGRLILPL4-1/LA NAME Flyon PBiechman JBurkhardt DATE 11/25/14 11/24/14 11/24/14 OFFICE NRR/DE/EPNB/BC(A)* N RR/DSS/SRXB/BC NRR/DORLILPL4-1/BC(A)

NAME JTsao CJackson EOesterle DATE 11/18/14 12/01/14 12/02/14