ML16330A118
| ML16330A118 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Point Beach, Seabrook, Turkey Point  |
| Issue date: | 12/15/2016 |
| From: | Dion J Plant Licensing Branch II |
| To: | Nazar M Nextera Energy |
| Dion J | |
| References | |
| CAC MF8195, CAC MF8196, CAC MF8197, CAC MF8198, CAC MF8199, CAC MF8200, CAC MF8201 | |
| Download: ML16330A118 (9) | |
Text
Mr. Mano Nazar UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 15, 2016 President and Chief Nuclear Officer Nuclear Division NextEra Energy Mail Stop NT3/JW 15430 Endeavor Drive Jupiter, FL 33478
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2; SEABROOK STATION, UNIT NO. 1; ST. LUCIE PLANT, UNIT NOS. 1 AND 2; TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 - SAFETY EVALUATION FOR PROPOSED ALTERNATIVE TO THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS OPERATION AND MAINTENANCE CODE BY ADOPTION OF APPROVED CODE CASE OMN-20, "INSERVICE TEST FREQUENCY" (CAC NOS. MF8195 THROUGH MF8201)
Dear Mr. Nazar:
By application dated July 28, 2016 (L-2016-137), NextEra Energy Resources/Florida Power & Light Company (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to authorize a proposed alternative to the requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for Point Beach Nuclear Plant, Units 1 and 2; Seabrook Station, Unit No. 1; St. Lucie Plant, Unit Nos. 1 and 2; and Turkey Point Nuclear Generating Unit Nos. 3 and 4.
The proposed alternative would allow the licensee to use ASME Code Case OMN-20, "lnservice Test Frequency," as an alternative to the test frequencies for pumps and valves specified in ASME OM Division 1: Section IST, 2009 Edition through OMa-2011 addenda, and all earlier editions and addenda of the ASME OM Code. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 55a(z)(2), the licensee requested to use the alternative 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 staff 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(z)(2). Therefore, the staff authorizes the use of the proposed alternative described in the licensee's application for the remainder of each plant's current 10-year inservice testing interval, as specified in the application, or until such time as the NRC approves Code Case OMN-20 for general use through a revision of NRC Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," Revision 1, as referenced by 10 CFR 50.55a, whichever occurs first.
All other requirements of 10 CFR 50.55a and the ASME OM Code for which relief was not specifically requested and approved, remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
If you have any questions regarding this subject, please contact the project manager, Ms. Audrey Klett, at (301) 415-0489 or by e-mail at Audrey.Klett@nrc.gov.
Docket Nos. 50-250, 50-251, 50-266, 50-301, 50-335, 50-389, and 50-443
Enclosure:
Safety Evaluation cc w/encl.: Distribution via Listserv Sincerely, t~engChief Plant Licensing Branch 11-2 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 PROPOSED ALTERNATIVE TO USE ASME CODE CASE OMN-20 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SEABROOK STATION. UNIT NO. 1 ST. LUCIE PLANT, UNIT NOS. 1 AND 2 TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 NEXTERA ENERGY RESOURCES/FLORIDA POWER & LIGHT COMPANY, ET AL.
DOCKET NOS. 50-250, 50-251, 50-266, 50-301. 50-335. 50-389, AND 50-443
1.0 INTRODUCTION
By application dated July 28, 2016 (L-2016-137), 1 NextEra Energy Resources/Florida Power & Light Company, et al. (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to authorize a proposed alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach); Seabrook Station, Unit No. 1 (Seabrook), St. Lucie Plant, Unit Nos. 1 and 2 (St. Lucie); and Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point).
The proposed alternative (i.e., Nos. VR-02 for Point Beach and VR-01 for the other plants) would allow the licensee to use ASME Code Case OMN-20, "lnservice Test Frequency," as an alternative to the test frequencies for pumps and valves specified in ASME OM Division 1:
Section IST, 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of the ASME OM Code. Pursuant to Title 10 of the Code of Federal Regulations ( 10 CFR),
Part 50, Section 55a(z)(2), the licensee requested to use the alternative 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.
In its application dated July 28, 2016, the licensee also requested license amendments for the aforementioned plants and the Duane Arnold Energy Center2 to revise the Technical Specifications (TSs) to adopt Technical Specification Task Force (TSTF) Traveler 1 Agencywide Documents and Access Management System (ADAMS) Accession No. ML16214A276.
2 The NRC approved the use of Code Case OMN-20 for Duane Arnold Energy Center on June 9, 2014 (ADAMS Accession No. ML14144A002).
Enclosure TSTF-545, "TS lnservice Testing Program Removal & [and] Clarify SR [Surveillance Requirement] Usage Rule Application to Section 5.5 Testing."3 The staff is separately reviewing and processing the license amendment requests from the requested alternative to the ASME OM Code.
2.0 REGULATORY EVALUATION
Paragraph 50.55a(f) of 1 O CFR states, in part, that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with the specified ASME OM Code and applicable addenda incorporated by reference in the regulations.
Paragraph 50.55a(z)(2) of 10 CFR states, in part, that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternative requested by the licensee.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Proposed Alternative The licensee requested to use ASME OM Code Case OMN-20 as an alternative to the frequency requirements for testing of pumps and valves applicable to ASME OM Code, Division 1: Section IST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of the ASME OM Code. This request is also applicable to any ASME OM Code Cases listed in NRC Regulatory Guide (RG) 1.192, Revision 1, "Operation and Maintenance Code Case Acceptability, ASME OM Code,"4 that pertain to pumps and valves that the licensee adopted. The OMN 20 discussions for this proposed alternative refer to Standard Technical Specifications Surveillance Requirements (SRs) 3.0.2 and 3.0.3. The Point Beach TSs use this numbering (i.e., SRs 3.0.2 and 3.0.3). The equivalent SRs for the Seabrook, St. Lucie, and Turkey Point TSs are SRs 4.0.2 and 4.0.3.
In its application, the licensee stated that the request is being made in accordance with 10 CFR 50.55a(z)(2), in that the existing requirements are considered a hardship without a compensating increase in quality and safety for the following reasons.
For IST periods up to and including 2 years, 5 Code Case OMN-20 provides an allowance to extend the IST periods by up to 25 percent. The 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 3 ADAMS Accession No. ML15294A555.
4 ADAMS Accession No. ML13340A034.
5 See footnote 5. Code Case OMN-20 specifies for IST periods fewer than 2 years; however, 25 percent of 2 years is 6 months.
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. The test period extension and the statements regarding the appropriate use of the period extension are equivalent to the existing allowances in SR 3.0.2 (or SR 4.0.2) and the statements regarding their use in the SR 3.0.2 (or SR 4.0.2) Bases. Use of the SR 3.0.2 (or SR 4.0.2) period extension has been a practice in the nuclear industry for many decades and elimination of this allowance would place a hardship on the plants when there is no evidence that the period extensions affect component reliability.
For IST periods of greater than 2 years, 6 OMN-20 allows an extension of up to 6 months. The ASME OM Committee determined that such an extension is appropriate. The 6-month extension will have a minimal impact on component reliability considering that the most probable result of performing any inservice test is satisfactory verification of the test acceptance criteria. As such, pumps and valves will continue to be adequately assessed for operational readiness when tested in accordance with the requirements specified in 10 CFR 50.55a(f) with the frequency extensions allowed by Code Case OMN-20.
As stated in NRC Enforcement Guidance Memorandum (EGM) 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests,"7 if an inservice test is not performed within its frequency, SR 3.0.3 (or SR 4.0.3) will not be applied. The effect of a missed inservice test on the operability of TS equipment will be assessed under the licensee's Operability Determination Program.
3.2 Licensee's Reason for the Request In its application, the licensee stated that the IST Program controls specified in the TSs provide the following items: (a) a table specifying certain IST frequencies; (b) an allowance to apply SR 3.0.2 for Point Beach and SR 4.0.2 for Seabrook, St. Lucie, and Turkey Point to inservice tests required by the OM Code and with frequencies of 2 years or less; (c) an allowance to apply SR 3.0.3 for Point Beach and SR 4.0.3 for St. Lucie to inservice tests required by the OM Code; and (d) the statement, "Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS." The licensee stated that in NRC Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirement 3.0.2 and 3.0.3 to Administrative Controls Program Tests,"8 and EGM 2012-001, the NRC stated that items b, c, and d of the TS IST Program were inappropriately added to the TS and may not be applied, although the EGM allows licensees to continue to apply those paragraphs pending a generic resolution of the issue.
6 See footnote 4. Code Case OMN-20 specifies for IST periods greater than or equal to 2 years; however 25 percent of 2 years is 6 months.
7 ADAMS Accession No. ML11258A243.
8 ADAMS Accession No. ML12079A393.
In its application, the licensee stated that RIS 2012-10 and EGM 2012-001 state that the current TS allowance to apply SR 3.0.2 and SR 3.0.3 to the IST Program would no longer be permitted. The licensee stated that in response, OMN-20, which provides allowances similar to SR 3.0.2 (or 4.0.2), was approved and is proposed to be used as an alternative to the test periods specified in the OM code. The licensee stated that the proposed alternative substitutes an approved code case for the existing TS requirements that the NRC has determined are not legally acceptable as a TS allowance. The licensee stated that this proposed alternative provides an equivalent level of safety as the existing TS allowance, while maintaining consistency with 10 CFR 50.55a and the ASME OM Code.
3.3 Duration of Proposed Alternative The licensee requested to use the proposed alternative for the plants' current 10-year IST intervals, which are listed in Table 1, or until Code Case OMN-20 is incorporated into a future revision of NRC RG 1.192, as referenced by a future revision of 10 CFR 50.55a, whichever occurs first.
3.4
Applicable Code Edition and Addenda
Table 1 provides the IST program interval dates and the applicable ASME OM Code edition and addenda for each plant.
Table 1 Plant IST 10-Year Interval Start Date Interval Scheduled ASME OM Code Edition and Interval No.
End Date Addenda Point Beach 1 Fifth September 1, 2012 August 31, 2022 2004 Edition through 2006 Addenda Point Beach 2 Fifth October 1, 2012 September 30, 2022 2004 Edition through 2006 Addenda Seabrook Third AUClUSt 18, 2010 Auaust17,2020 2004 Edition St. Lucie 1 Fourth February 11, 2008 February 10, 2018 2001 Edition through 2003 Addenda St. Lucie 2 Fourth February 11, 2008 February 10, 2018 2001 Edition through 2003 Addenda Turkey Point 3 Fifth February 22, 2015 February 21, 2025 2004 Edition through 2006 Addenda Turkey Point 4 Fifth April 15, 2015 April 14, 2025 2004 Edition through 2006 Addenda 3.5 Applicable Code Requirements and Components Affected by the Proposed Alternative The licensee requested to use ASME OM Code Case OMN-20 as an alternative to the frequency requirements for pumps and valves applicable to ASME OM Code, Division 1:
Section IST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of the ASME OM Code. Frequency extensions may also be applied to accelerated test frequencies (e.g., pumps in the Alert Range) as specified in OMN-20.
3.6
NRC Staff Evaluation
Historically, licensees have applied, and the staff has accepted, the TS definitions for IST intervals, including allowable interval extensions, to ASME OM Code-required testing. 9 The staff reconsidered the allowance of using TS testing intervals and interval extensions for IST not associated with TS SRs. As noted in RIS 2012-10, the NRC determined that programmatic test frequencies cannot be extended in accordance with SR 3.0.2 nor delayed in accordance with SR 3.0.3. This includes all IST described in the ASME OM Code not specifically required by the TS SRs. As previously noted in this safety evaluation, SR 3.0.2 and SR 3.0.3 from RIS 2012-10 are equivalent to SR 4.0.2 and SR 4.0.3 for Seabrook, St. Lucie, and Turkey Point.
The staff sponsored and co-authored an ASME OM Code inquiry and code case to modify the ASME OM Code to include TS-like 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 proposes to adopt ASME Code Case OMN-20.
The staff has determined that requiring the licensee to meet the ASME OM Code requirements without an allowance for defined frequency and frequency extensions for IST of pumps and valves would cause a loss of operational flexibility for meeting ASME OM Code requirements and would result in a hardship without a compensating increase in the level of quality and safety. Based on the prior acceptance by the 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 staff determines that the proposed alternative for OMN-20, as described in request Nos. VR-01 for Seabrook, St. Lucie, and Turkey Point and VR-02 for Point Beach, provides reasonable assurance that the affected components are operationally ready. The staff concludes that complying with the specified ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Accordingly, the staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 1 O CFR 50.55a(z)(2). Therefore, the staff authorizes alternative requests VR-01 for Seabrook, St. Lucie, and Turkey Point and VR-02 for Point Beach, for the remainder of their 10-year IST program intervals listed in Table 1, or until Code Case OMN-20 is incorporated into a future revision of RG 1.192, as referenced by a future revision of 10 CFR 50.55a, whichever occurs first.
9 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, "Scheduling of lnservice Tests," at ADAMS Accession No. ML13295A020.
All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable.
Principal Contributor: Robert Wolfgang Date: December 15, 2016
All other requirements of 10 CFR 50.55a and the ASME OM Code for which relief was not specifically requested and approved, remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
If you have any questions regarding this subject, please contact the project manager, Ms. Audrey Klett, at (301) 415-0489 or by e-mail at Audrey.Klett@nrc.gov.
Sincerely, IRA/
Jeanne A. Dion, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250, 50-251, 50-266, 50-301, 50-335, 50-389, and 50-443
Enclosure:
Safety Evaluation cc w/encl.: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL 1-2 R/F RidsNrrDorlLPL 1-2 RidsRgn 1 MailCenter RidsNrrLALRonewicz RidsNrrPMSeabrook RidsNrrPMPointBeach RidsNrrDeEpnb LPL2-2 R/F RidsN rrDorl Lpl2-2 RidsRgn2Mai1Center RidsNrrLABClayton RidsNrrPMTurkeyPoint RWolfgang, NRR LPL3-1 R/F RidsNrrDorlLPL3-1 RidsRgn3MailCenter RidsNrrLASRohrer RidsNrrPMStLucie RidsACRS _MailCTR ADAMS Accession N o.: M L16 330A 118
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