Text

Requests for Relief GR-01, PR-01, PR-02, VR-01, and VR-02, for the Fourth Inservice Testing Interval
	ML16343A057
Person / Time
Site:	Hope Creek
Issue date:	12/20/2016
From:	Stephen Koenick; Plant Licensing Branch 1
To:	Sena P; Public Service Enterprise Group
	Parker C, NRR/DORL/LPLI-II, 415-1603
References
	CAC MF7200, CAC MF7201, CAC MF7202, CAC MF7203, CAC MF7204
	Download: ML16343A057 (25)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2016 Mr. Peter P. Sena, Ill President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

HOPE CREEK GENERATING STATION- REQUESTS FOR RELIEF GR-01, PR-01, PR-02, VR-01, AND VR-02, FOR THE FOURTH INSERVICE TESTING INTERVAL (CAC NOS. MF7200, MF7201, MF7202, MF7203, AND MF7204)

Dear Mr. Sena:

By letter dated December 18, 2015, as supplemented by letters dated June 10, 2016, and September 23, 2016, PSEG Nuclear LLC submitted requests for relief from the requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for the Hope Creek Generating Station (Hope Creek). The subject relief requests are for the fourth 10-year inservice testing (IST) interval at Hope Creek, which is scheduled to begin on December 21, 2016.

The U.S. Nuclear Regulatory Commission staff has completed its review of the subject relief requests as documented in the enclosed Safety Evaluation. Our Safety Evaluation concludes the following:

(1) With respect to relief requests PR-01, PR-02, VR-01, and VR-02, the proposed alternatives will provide an acceptable level of quality and safety. Therefore, pursuant to Section 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (1 O CFR), the proposed alternatives are authorized for the fourth 10-year IST interval at Hope Creek.

(2) With respect to relief request GR-01, the proposed alternative will provide reasonable assurance that the components are operationally ready, and compliance with the specified requirements would result in a hardship or unusual difficulty, without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(z)(2), the proposed alternative is authorized for the fourth 10-year IST interval at Hope Creek.

P. Sena, Ill If you have any questions concerning this matter, please contact the Hope Creek Project Manager, Ms. Carleen Parker, at 301-415-1603 or by e-mail at Carleen.Parker@nrc.gov.

Sincerely, k7,/c~)//_>/

Stephen S. Koenick, Acting Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

Safety Evaluation cc w/enclosure: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUESTS GR-01, PR-01, PR-02, VR-01, AND VR-02 FOR THE FOURTH 10-YEAR INTERVAL OF THE INSERVICE TESTING PROGRAM PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1.0 INTRODUCTION

By letter dated December 18, 2015, 1 as supplemented by letters dated June 10, 2016, and September 23, 2016, 2 PSEG Nuclear LLC (PSEG or the licensee) submitted relief requests GR-01, PR-01, PR-02, VR-01, and VR-02, for the fourth 10-year inservice testing (IST) program interval at the Hope Creek Generating Station (Hope Creek). PSEG requested relief from certain IST requirements of the 2004 Edition through 2006 Addenda of the American Society of Mechanical Engineers (ASME) Code of Operation and Maintenance of Nuclear Power Plants (OM Code). The Hope Creek fourth 10-year IST interval is scheduled to begin on December 21, 2016.

2.0 REGULATORY EVALUATION

Section 50.55a of Title 1O of the Code of Federal Regulations (1 O CFR) requires, in part, that IST of certain ASME Code Class 1, 2, and 3 components must be performed at 120-month (10-year) IST program intervals, in accordance with the specified ASME Code incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the U.S. Nuclear Regulatory Commission (NRC or the Commission) pursuant to paragraphs (z)(1 ), (z)(2), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR55(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month IST program interval. In accordance with 50.55a(f)(4)(iv),

inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(a), subject to NRC approval.

Portions of editions or addenda may be used, provided that all related requirements of the respective editions and addend are met.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML15352A127 2

ADAMS Accession Nos. ML16162A709 and ML16267A370, respectively Enclosure

In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety (1 O CFR 50.55a(z)(1 ));

(2) compliance would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety (10 CFR 50.55a(z)(2)); or (3) conformance is impractical for the facility (50.55a(f)(6)(i)). Section 50.55a of 10 CFR allows the NRC to authorize alternatives and to grant relief from the ASME OM Code requirements, upon making necessary findings.

The Hope Creek fourth 10-year IST interval is scheduled to begin on December 21, 2016. The program was developed in accordance with the 2004 Edition through 2006 Addenda of the ASME OM Code. By letter dated December 18, 2015, as supplemented by letters dated June 10, 2016, and September 23, 2016, PSEG requested relief from certain requirements of the OM Code for the fourth 10-year IST interval at Hope Creek.

Based on the above, and subject to the technical evaluation below, the NRC staff finds that regulatory authority exists for the licensee to request, and the Commission to authorize, the alternatives requested.

3.0 TECHNICAL EVALUATION

3.1 PSEG's Alternative Request GR-01 3.1.1 Code Requirements This request applies to the frequency specifications of the ASME OM Code. By letter dated December 18, 2015, as supplemented by letter dated June 10, 2016, PSEG identified the applicable frequency specifications. The frequencies for tests given in the ASME OM Code include the following, but do not include a tolerance band:

ISTA-3120(a) - The frequency for IST shall be in accordance with the requirements of Section IST.

ISTB-3400 - "Frequency of lnservice Tests," states, "An inservice test shall be run on each pump as specified in Table ISTB-3400-1."

ISTC-3510 - "Exercising Test Frequency," states, "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months."

ISTC-3540 - "Manual Valves," states, "Manual valves shall be full-stroke exercised at least once every 2 years, except where adverse conditions may require the valve to be tested more frequently to ensure operational readiness."

ISTC-3630(a) - "Leakage Rate for Other Than Containment Isolation Valves,"

"Frequency," states, "Tests shall be conducted at least once every 2 years."

ISTC-3700 - "Position Verification Testing," states, in part, "Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated."

ISTC-5221 c(3) - "Valve Obturator Movement," states, "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in each group shall be disassembled and examined at least once every 8 years."

ISTC-5260(b) - "Explosively Active Valves," states, in part, "Concurrent with the first test and at least once every 2 years .... "

ISTC-5260(b) - "Explosively Active Valves," states, in part, "At least 20% of the charges in explosively actuated valves shall be fired and replaced every 2 years."

Appendix I, l-1320(a) - "Test Frequencies, Class 1 Pressure Relief Valves," "5-Year Test Interval," states, in part, "Class 1 pressure relief valves shall be tested at least once every 5 years starting with initial electric power generation"; (b)(1) states, in part, " ... the valves removed from service shall be tested within 3 months of removal from the system ... "; and (b)(2) states, in part," ... the valves removed from service shall be tested with 12 months of removal from the system."

Appendix I, 1-1330- "Test Frequency, Class 1 Nonreclosing Pressure Relief Devices,"

states, in part, that Class 1 nonreclosing pressure relief devices shall be replaced every 5 years.

Appendix I, 1-1340- "Test Frequency, Class 1 Pressure Relief Valves that are Used for Thermal Relief Application," Refers to 1-1320 for test frequency.

Appendix I, 1-1350- "Test Frequency, Classes 2 and 3 Pressure Relief Valves,"

(a) "10-Year Test Interval," states, in part, "Class 2 and 3 pressure relief valves, with the exception of PWR [pressurized-water reactor] main steam safety valves, shall be tested every ten years, starting with initial electric power generation."

Appendix I, 1-1360 - "Test Frequency, Classes 2 and 3 Nonreclosing Pressure Relief Devices," states, "Classes 2 and 3 non-reclosing pressure relief devices shall be replaced every 5 years, unless historical data indicates a requirement for more frequent replacement."

Appendix I, l-1370(a) - "Test Frequency, Classes 2 and 3 Primary Containment Vacuum Relief Valves," states, "Tests shall be performed on all Classes 2 and 3 containment vacuum relief valves at each refueling outage or every 2 years ... "

Appendix I, 1-1380- "Test Frequency, Classes 2 and 3 Vacuum Relief Valves, Except for Primary Containment Vacuum Relief Valves," states, "All Classes 2 and 3 vacuum relief valves shall be tested every 2 years ... "

Appendix I, 1-1390- "Test Frequency, Classes 2 and 3 Pressure Relief Devices that are Used for Thermal Relief Application," states, "Tests shall be performed on all Classes 2 and 3 relief devices used in thermal relief application every 1O years ... "

Appendix II, ll-4000(a)(1) - "Condition-Monitoring Activities, Performance Improvement Activities," states, " ... the following activities shall be performed at sufficient intervals over an interim period of the next 5 years or two refueling outages, whichever is less ... "

Appendix II, ll-4000(a)(1 )(e) - "Condition-Monitoring Activities, Performance Improvement Activities," subparagraph (1)(e), requires the identification of the interval for each activity.

Appendix II, ll-4000(b)(1 )(e) - "Condition-Monitoring Activities, Optimization of Condition Monitoring Activities," "Intervals shall not exceed the maximum intervals shown in Table 11-4000-1." Table 11-4000-1 lists three intervals: 10, 12, and 16 years.

OMN-1, 3.3.1 (b)- "lnservice Test Interval,"" ... MOV [motor operated valve] inservice testing shall be conducted every 2 refueling cycles or 3 years (whichever is longer) ... "

OMN-1, 3.3.1 (c) - "lnservice Test Interval," "The maximum inservice test interval shall not exceed 10 years."

OMN-1, 3.6.1 - "Normal Exercising Requirements," " ... with the maximum time between exercises to be not greater than 24 months."

OMN-1, 3.7.2.1 - "HSSC [highly safety significant component] MOVs"; "HSSC MOVs that can be operated during plant operation shall be exercised quarterly ... "

OMN-1, 3.7.2.2(c) - "LSSC MOVs," " ... using an initial test interval of three refueling cycles or 5 years (whichever is longer) ... "

OMN-1, 3.7.2.2{d) - "LSSC [low safety significant component] MOVs," "LSSC MOVs shall be inservice tested at least every 10 years ... "

3.1.2 Components for Which Relief is Requested All pumps and valves contained within the Hope Creek IST program scope.

3.1.3 Licensee's Basis for Requesting Relief The licensee's basis for relief is as follows:

ASME OM Code Section IST establishes the inservice test frequencies for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG-1482, Revision 2) and Owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specification (TS) Surveillance Requirements (SRs). The TS typically allow 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 (SR 4.0.2). However, regulatory issues have been raised concerning the applicability of TS "grace period" to ASME OM Code required

inservice test frequencies irrespective of the allowance provided under TS Administrative Controls (i.e., TS 6.8.4.i, "lnservice Testing Program, invokes SR 4.0.2 for various OM Code frequencies of 2 years or less).

The lack of a tolerance band on the ASME OM Code inservice test frequencies restricts operational flexibility. There may be a conflict where an OM Code test is required (i.e., its Frequency could expire), but where it is not possible or not desired that the test be performed until the necessary supporting plant conditions can be established.

The NRG recognized this potential issue in the TS by allowing a frequency tolerance as described in TS SR 4.0.2. The lack of a similar tolerance applied to 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 OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling OM Code required tests that minimize the conflicts between the need to complete the testing and plant conditions.

3.1.4 Licensee's Proposed Alternative The licensee proposed to use ASME OM Code Case OMN-20, "lnservice Test Frequency,

repeated below, for flexibility in IST scheduling for pump and valve test frequencies. The proposed alternative will be utilized for the fourth 10-year interval and will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the IST program scope.

ASME OM Code Case OMN-20 lnservice Test Frequency ASME OM Division: 1 Section IST and earlier editions and addenda of ASME OM Code specify component test frequencies based either on elapsed time periods (e.g.,

quarterly, 2 years, etc.) or on 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 IST with a specified time period between tests as shown in the table below. The specified time period between tests may be reduced or extended as follows:

1) For periods specified as less than 2 years, the period may be extended by up to 25% 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 less than two year test frequencies not specified in the table below.

Period extensions may not be applied to the test frequency requirements specified in [ASME OM Code] 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.

Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 months)

Semiannually 184 days (or every 6 months)

Annually 366 days Cor everv vear) x calendar years x Years where *x* is a whole number of years c:a: 2 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 the [ASME OM Code].

3.1.5 NRC Staff Evaluation Historically, licensees have applied, and the NRC staff has accepted, the standard TS definitions for IST intervals (including allowable interval extensions) to ASME OM Code required testing (Section 3.1.3 of NUREG-1482, Revision 2, "Guidelines for lnservice Testing at Nuclear Power Plants." 3 ) Recently, the NRC staff reconsidered the allowance of the TS testing intervals and interval extensions, for IST 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," dated August 23, 2012, 4 the NRC determined that 3 ADAMS Accession No. ML13295A020 4 ADAMS Accession No. ML12079A393

programmatic test frequencies cannot be extended in accordance with TS SR 3.0.2. This includes all IST described in the ASME OM Code. The lack of a tolerance band on the ASME OM Code IST frequency restricts operational flexibility. There may be a conflict where IST could be required (i.e., the frequency could expire), but where it is not possible or not desired that it be performed until after a plant condition or associated limiting condition for operation is within its applicability. Therefore, to avoid this conflict, the IST should be performed when plant conditions allow.

The NRC staff recognized that, 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. To provide operational flexibility, when scheduling IST that minimize the conflicts between the need to complete the testing and plant conditions, the NRC 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-approved Code Case OMN-20, as described above, was approved by the ASME Operation and Maintenance Standards Committee on February 15, 2012, with the NRC representative voting in the affirmative. Code Case OMN-20 was subsequently published in conjunction with the 2012 Edition of the ASME OM Code. However, as stated in Code Case OMN-20, the period extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified.

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 results in a hardship, without a compensating increase in the level of quality and safety. Based on this, the licensee's proposal to adopt the ASME OM Code Case OMN-20 in its entirety, and the licensee's prior acceptance of the similar TS test interval definitions and interval extension criteria, the NRC staff finds that implementation of this ASME OM Code Case provides reasonable assurance of operational readiness of pumps and valves, subject to the IST requirements of the ASME OM Code.

3.1.6 Conclusion As set forth above, the NRC staff determines that for request GR-01, the proposed alternative provides reasonable assurance that the affected components are operationally ready, and complying with the ASME OM Code requirements would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2).

3.2 PSEG's Alternative Request PR-01 3.2.1 Code Requirements ISTB-351 O(a) requires that flow instrument accuracy shall be within +/-2 percent of full-scale as defined in Table ISTB-3500-1, and ISTB-351 O(b)(1) requires that the full-scale range of each analog instrument shall not be greater than three times the reference values. The combination of these two requirements (i.e., accuracy of +/-2 percent of full scale, and full scale being up to 3 times the reference value) yields an allowable tolerance of +/-6 percent of the reference value.

3.2.2 Components for Which Relief is Requested 1OP204 High Pressure Coolant Injection (HPCI) Pump 1OP217 HPCI Booster Pump The HPCI pump is an emergency core cooling system (ECCS) component that is also used to maintain reactor vessel inventory following reactor isolation.

The HPCI booster pump is integral with the HPCI pump in that they are driven off the same turbine. The booster pump ensures that the minimum net positive suction head requirement of the HPCI pump is maintained for the design-accident flow rates.

3.2.3 Licensee's Basis for Requesting Relief The permanently installed flow instrument, 1FDFIC-R600-E41, has an accuracy of +3.83 percent and -0.67 percent of full-scale. The accuracy of +3.83 percent does not meet the OM Code requirement of +2 percent specified in Table ISTB-3500-1.

3.2.4 Licensee's Proposed Alternative The licensee proposes to use the existing instrumentation, as discussed below:

As indicated in the table below, the installed instrumentation has a full-scale range of 6000 gpm, which only slightly exceeds the pump flow reference value of 5600 gpm (full scale equals 1.07 times reference) with an accuracy of +3.83%

and -0.67% of full-scale. This results in flow rate measurement accurate to

+4.1% or -0.72% of indicated flow at reference conditions (5600 gpm), which is more conservative than the 6% minimum accuracy allowed by combination of instrument full-scale range and accuracy allowed in Subsection ISTB [of the OM Code]. The current instrumentation provides sufficient repeatability to allow for an evaluation of the pump hydraulic condition and detect pump degradation.

Supporting Data Table Instrument Number: 1FDFIC-R600-E41 Actual Instrument Range: O - 6000 gpm [gallons per minute]

Actual Gauge (Loop) Accuracy: +3.83 /-0.67% of full-scale Test Reference Value: 5600 gpm Code Allowable Instrument Range: 16,800 gpm (3X ref. value)

Code Allowable Instrument Tolerance: +/-336 gpm (2% full-scale at 3X reference value)

Actual Instrument Tolerance: +229.8 gpm I -40.2 gpm Actual Indicated Accuracy: +4.1 I -0.72% (at reference value)

3.2.5 NRC Staff Evaluation The instrument accuracy requirements of ISTB-351 O(a) and range requirements of ISTB-351 O(b)(1) are to ensure that test measurements are sufficiently sensitive to changes in pump condition to allow detection of degradation. ISTB-351 O(b)(1) states that the full-scale range of each analog instrument shall not be greater than three times of the reference values, and ISTB-351 O(a) states that the instrument accuracy shall be within the limits of Table-3500-1, e.g., +/- 2 percent for flow rate measurements.

Hope Creek installed gauges for HPCI and booster pump test are Oto 6000 gpm and have an accuracy of +3.83 percent and -0.67 percent. The accuracy of +3.83 percent does not meet Code requirement of +2 percent. In lieu of replacing the flow instrument, the licensee proposed to use the current installed instrument on the basis that the combination of range and accuracy of the flow instrument meets the intent of accuracy requirements of +/- 6 percent of the flow reference value.

Based on the flow reference value of 5600 gpm and maximum Code-allowed full range of 16800 gpm (3x5600gpm), the maximum Code allowable flow instrument tolerance is 336 gpm

(.02x16800). As indicated in the Table above, the installed flow instrument range is 6000 gpm with an accuracy of 3.83 percent of full scale. This would result in flow rate measurements accurate to +229.8/-40.2 gpm, which are +4.1 percent /-0.72 percent of indicated accuracy of the reference value.

In this relief request the range meets the Code requirements, but the accuracy slightly exceeds the Code requirements. However, considered the range and accuracy together, the actual reading accuracy achieved from the installed instruments is +4.1 percent or -0.72 percent, which is more conservative than the Code allowed (+/-6 percent). Therefore, the proposed alternative meets the intent of the Code and provides an acceptable level of quality and safety.

The use of the existing instrument is also supported by NUREG-1482 paragraph 5.5.1, which states that when the combination of range and accuracy yields a reading at least equivalent to that achieved using instruments that meet the Code requirements, relief may be granted by the NRC staff.

3.2.6 Conclusion As set forth above, the NRC staff determines that for request PR-01, the proposed alternatives provide an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ).

3.3 PSEG's Alternative Request PR-02 3.3.1 Code Requirements ISTB-351 O(a) requires that flow instrument accuracy shall be within +/-2 percent of full-scale as defined in Table ISTB-3500-1, and ISTB-351 O(b)(1) states that the full-scale range of each analog instrument shall not be greater than three times of the reference values. The

combination of these two requirements (i.e., accuracy of +/-2 percent of full scale and full scale being up to 3 times of the reference value) yields an allowable tolerance of +/-6 percent of the reference value.

3.3.2 Components for Which Relief is Requested 1OP203 Reactor Core Isolation Cooling (RCIC) Pump The RCIC pump is safety-related and provides demineralized make-up water to the reactor vessel in the event that the reactor vessel is isolated.

3.3.3 Licensee's Basis for Relief The permanently installed flow instrument 1FCFIC-R600-E51 has an accuracy of +/-2.94 percent of full-scale. The instrument accuracy of +/-2.94 percent does not meet the OM Code requirement of +/-2 percent specified in Table ISTB-3500-1.

3.3.4 Licensee's Proposed Alternative The licensee's proposes to use the existing instrumentation as discussed below:

As indicated in the table below, the installed instrumentation has a full-scale range of 700 gpm, which only slightly exceeds the pump flow reference value of 600 gpm (full scale equals 1.17 times reference) with an accuracy of +2.49% and

-2.49% of full-scale. This results in flow rate measurement accurate to +2.9% or

-2.9% of indicated flow at reference conditions (600 gpm), which is more conservative than the 6% minimum accuracy allowed by the combination of instrument full-scale range and accuracy allowed in Subsection ISTB [of the OM Code]. The current instrumentation provides sufficient repeatability to allow for an evaluation of the pump hydraulic condition and detect pump degradation.

Supporting Data Table Instrument Number: 1FCFIC-R600-E51 Actual Instrument Range: O - 700 gpm Actual Gauge (Loop) Accuracy: +2.49% I -2.49%

Test Reference Value: 600 gpm Code Allowable Instrument Range: 1,800 gpm (3X ref. value)

Code Allowable Instrument Tolerance: +/-36 gpm (2% full-scale at 3X ref. value)

Actual Instrument Tolerance: 17.43 gpm /-17.43 gpm Actual Indicated Accuracy: +2.9 % I -2.9% (at reference value)

3.3.5 NRC Staff Evaluation The instrument accuracy requirements of ISTB-351 O(a) and range requirements of ISTB-351 O(b)(1) are to ensure that test measurements are sufficiently sensitive to changes in pump condition to allow detection of degradation. ISTB-351 O(b)(1) states that the full-scale range of each analog instrument shall not be greater than three times of the reference values, and ISTB-3510(a) states that the instrument accuracy shall be within the limits of Table-3500-1 (e.g., +/- 2 percent for flow rate measurements).

Hope Creek installed gauges for RCIC pump test are 0 to 700 gpm and have an accuracy of

+/-2.49 percent, which does not meet the Code requirement of +/-2 percent. In lieu of replacing the flow instrument, the licensee proposed to use the current installed instrument on the basis that the combination of range and accuracy of the flow instrument meets the intent of OM Code requirements.

Based on the flow reference value of 600 gpm and maximum Code-allowed full range of 1800 gpm (3x600gpm), the maximum Code allowable flow instrument tolerance is 36 gpm

(.02x1800). As indicated in the table above, the installed flow instrument range is 700 gpm, with an accuracy of +/-2.49 percent of full scale. This would result in flow rate measurements accurate to +/-17.43 gpm, which is +/-2.9 percent of indicated accuracy of the reference value.

In this relief request, the range meets the Code requirements, but the accuracy slightly exceeds the Code requirements. However, considering the range and accuracy together, the actual reading accuracy achieved from the installed instruments is +/-2.9 percent, which is more conservative than the Code allowed (+/-6 percent). Therefore, the proposed alternative meets the intent of the Code and provides an acceptable level of quality and safety.

The use of the existing instrument is also supported by NUREG-1482, paragraph 5.5.1, which states that when the combination of range and accuracy yields a reading at least equivalent to that achieved using instruments that meet the Code requirements, relief may be granted by the NRC staff.

3.3.6 Conclusion As set forth above, the NRC staff determines that for request PR-02, the proposed alternatives provide an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ).

3.4 Licensee's Alternative Request VR-01 3.4.1 Code Requirements

ISTC-3510, "Exercising Test Frequency, states, in part, that, "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months, except as provided by ISTC-3520 .... "

ISTC-3522(a), "Category C Check Valves, states that, "During operation at power, each check valve shall be exercised or examined in a manner that verifies obturator travel by using the methods in ISTC-5221."

ISTC-3522(c), "Category C Check Valves, states that, "If exercising is not practicable during operation at power and cold shutdowns, it shall be performed during refueling outages."

ISTC-3700, "Position Verification Testing," states, in part, that, "Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated."

3.4.2 Components for Which Relief is Requested Alternative testing is requested for the following valves:

Table 1 Valve ID System Cat ASME Class 1ABXV-3666A Excess Flow Check Valve (EFCV) c 1 1ABXV-36668 EFCV c 1 1ABXV-3666C EFCV c 1 1ABXV-36660 EFCV c 1 1ABXV-3667A EFCV c 1 1ABXV-36678 EFCV c 1 1ABXV-3667C EFCV c 1 1ABXV-3667D EFCV c 1 1ABXV-3668A EFCV c 1 1ABXV-3668B EFCV c 1 1ABXV-3668C EFCV c 1 1ABXV-36680 EFCV c 1 1ABXV-3669A EFCV c 1 1ABXV-3669B EFCV c 1 1ABXV-3669C EFCV c 1 1ABXV-36690 EFCV c 1 1BBXV-3621 EFCV c 1 1BBXV-3649 EFCV c 1 1BBXV-3725 EFCV c 1 1BBXV-3726A EFCV c 1

Table 1 Valve ID System Cat ASME Class 188XV-3801 8 EFCV c 1 188XV-3801 C EFCV c 1 188XV-38010 EFCV c 1 188XV-3802A EFCV c 1 188XV-38028 EFCV c 1 188XV-3802C EFCV c 1 188XV-38020 EFCV c 1 188XV-3803A EFCV c 1 188XV-38038 EFCV c 1 188XV-3803C EFCV c 1 188XV-38030 EFCV c 1 188XV-3804A EFCV c 1 188XV-38048 EFCV c 1 188XV-3804C EFCV c 1 188XV-38040 EFCV c 1 188XV-3820 EFCV c 1 188XV-3821 EFCV c 1 188XV-3826 EFCV c 1 188XV-3827 EFCV c 1 18CXV-4411 A EFCV c 1 18CXV-44118 EFCV c 1 18CXV-4411 C EFCV c 1 18CXV-44110 EFCV c 1 18CXV-4429A EFCV c 1 18CXV-44298 EFCV c 1 18CXV-4429C EFCV c 1 18CXV-44290 EFCV c 1 18EXV-F018A EFCV c 1 18EXV-F0188 EFCV c 1 18GXV-3882 EFCV c 1 18GXV-3884A EFCV c 1 18GXV-38848 EFCV c 1 18GXV-3884C EFCV c 1 18GXV-38840 EFCV c 1 1FCXV-4150A EFCV c 1 1FCXV-41508 EFCV c 1 1FCXV-4150C EFCV c 1 1FCXV-41500 EFCV c 1 1FOXV-4800A EFCV c 1 1FOXV-48008 EFCV c 1 1FOXV-4800C EFCV c 1 1FOXV-48000 EFCV c 1

3.4.3 Licensee's Basis for Requesting Relief The licensee's basis for relief is as follows:

The OM Code requires check valves to be exercised quarterly during plant operation, or if valve exercising is not practicable during plant operation and cold shutdown, it shall be performed during refueling outages. The OM Code also requires verification of valve position indication at least once every 2 years. HCGS

[Hope Creek Generating Station] tests a representative sample of EFCVs every 18 months such that all valves (except for 1BBXV-3469, as exempted by TS note) are tested once in 10 years per TS SR 4.6.3.4 (reference 8.4).

The EFCVs have position indication at local panels in the reactor building. Check valve remote position indication is excluded from Regulatory Guide 1.97, Revision 2, dated, May 1983, as a required parameter for evaluating containment isolation. The remote position indication is verified accurate at the same frequency as the exercise test prescribed in TS SR 4.6.3.4.

The testing described above requires removal of the associated instrument or instruments from service. Since these instruments are in use during plant operation, removal of any of these instruments from service may cause a spurious signal, which could result in a plant trip or an unnecessary challenge to safety systems.

Additionally, process fluid will be contaminated to some degree, requiring special measures to collect flow from the vented instrument side and also contribute to an increase in personnel radiation exposure.

The EFCVs are classified as ASME Code Category C and are also containment isolation valves. However, these valves are excluded from 10 CFR 50, Appendix J, Type C leak rate testing, due to the size of the instrument lines and upstream orifices. Therefore, they have no safety-related seat leakage criterion.

3.4.4 Licensee's Proposed Alternative The licensee proposes to test the EFCVs at a frequency specified in Hope Creek TS SR 4.6.3.4.

SR 4.6.3.4 allows a 'representative sample' of EFCVs to be tested every refueling outage such that each EFCV will be individually tested approximately every 1O years. In its application dated December 18, 2015, as supplemented by letter dated June 10, 2016, the licensee stated that if an EFCV should fail its test, the licensee will take the following actions:

Excess flow check valve testing procedures contain guidance for the appropriate steps to be taken in response to a test failure. If any EFCV fails its functional test, a notification is entered into the CAP [corrective action] program. Testing scope is expanded to include 2 additional EFCVs from a population scheduled for a future refuel outage. If 1 of 2 of the additional EFCVs fails its functional test, then a second notification is entered into the CAP program to document the failure. In addition, the Maintenance Rule program is used to track the performance of the excess flow check valves. At Hope Creek, EFCVs are

condition monitored to comply with paragraph (a){2) of the Maintenance Rule. If failures are discovered, they are evaluated as "preventable system functional failures" in the corrective action program. Maintenance Rule a(1) status is entered based on repeat system functional failures of an EFCV, and the performance or condition of the EFCV shall be monitored in a manner sufficient to provide reasonable assurance that it is capable of fulfilling its intended function.

Operations shift management reviews all CAP notifications which involve a condition adverse to quality, including component failures, to ensure the appropriate corrective actions are taken. After Operations shift management screens the notification and takes the appropriate actions required by the Technical Specifications, the notification is screened by the Station Ownership Committee. The significance level and evaluation type for the notification are assigned based upon the impact of the condition, as defined by the procedure for issue identification and screening. Acceptance criteria for valve operability are provided in the applicable test procedures and the completed test packages are reviewed by the IST program engineer.

The licensee's justification for this request is based on General Electric (GE) Topical Report {TR) NED0-32977-A, "Excess Flow Check Valve Testing Relaxation,"

June 2000. 5 As part of this justification, PSEG was required to perform a plant-specific radiological dose assessment and release frequency analysis to confirm Hope Creek was bounded by the generic analysis of the TR. In its application dated December 18, 2015, as supplemented by letter dated June 10, 2016, the licensee provided the following information regarding the radiological dose assessment and release frequency analysis at Hope Creek:

The radiological consequences for an instrument line break have been evaluated in Updated Final Safety Analysis Report (UFSAR) Section 15.6.2.5. The analysis does not credit the EFCVs for isolating the break and assumes a discharge of reactor water through an instrument line with a 1.4 inch restricting orifice throughout the event. The analysis confirms that the radiological consequence of EFCVs failing to function upon demand is sufficiently low to be considered insignificant.

The calculations contained in GE TR NED0-32977-A utilize the results of surveillance testing at 12 BWR plants. These results represent a total of 12,424.5 valve operating years with a plant average of 1035 valve years per plant. There were 11 reported EFCV failures during this period, resulting in a composite failure rate of 1.01 E-7/hr. At Hope Creek, there were no EFCV failures in over 5 years of testing experience for 105 valves (525 valve operating years), resulting in a failure rate of O failures/hr. The Hope Creek data is consistent both in service time sampled, and reliability, with the results listed in the BWROG report. Therefore, we have concluded that the report bounds the reliability of Hope Creek's EFCVs.

5 ADAMS Accession No. ML003729011

Hope Creek has failure rates consistent with the results of the GE TR NED0-32977-A. Seven plants reported no failures of EFCVs during the operating period, while the remaining 5 plants reported between 1 and 4 failures.

The remote position indication will be verified accurate at the same frequency as the exercise test prescribed in TS SR 4.6.3.4. Although inadvertent actuation of an EFCV during operation is highly unlikely due to the spring poppet design, corrective action documents are initiated for any EFCV with abnormal position indication displays.

3.4.5 NRC Staff Evaluation EFCVs are installed on instrument lines to limit the release of fluid in the event of an instrument line break. Examples of EFCV installations include reactor pressure vessel level and pressure instrumentation, main steam line flow instrumentation, recirculation pump suction pressure, and RCIC steam line flow instrumentation. EFCVs are not required to close in response to a containment isolation signal and are not required to operate under post-loss-of-coolant accident (LOCA) conditions.

EFCVs are required to be tested in accordance with ASME OM Code ISTC-3510, which states, in part, that, "Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months." The ASME OM Code recognizes that some valves cannot be tested at this frequency. Deferral of this requirement is allowed by ISTC-3522(c), which states, "If exercising is not practical during operation at power and cold shutdowns, it shall be performed during refueling outages." The EFCVs listed in Table 1 above cannot be exercised during normal operation, because closing these valves would isolate instrumentation required for power operation. These valves can only be tested during a refueling outage. The licensee has proposed an alternative to the required test interval. The proposed change revises the surveillance frequency by allowing a "representative sample" of EFCVs to be tested every refueling outage. The "representative sample" is based on an approximately equal number of EFCVs being tested each refueling outage such that each valve is tested at least once every 1O years. As noted in the licensee's TS SRs, the surveillance frequency is governed by the Surveillance Frequency Control Program (SFCP). Changes to the frequencies in the SFCP shall be made in accordance with NEI 04-10, Revision 1, "Risk Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies,"

dated April 2007. The NRC staff reviewed NEI 04-10, Revision 1, and issued its evaluation on September 19, 2007. 6 In its evaluation, the NRC staff found that the methodology is acceptable, with conditions, for licensees to amend their TSs to establish an SFCP. The NRC approved the use of the SFCP at Hope Creek by Amendment No. 187, dated February 25, 2011. 7 The licensee's justification for the relief request is based on GE TR NED0-32977-A. The TR provided: (1) an estimate of steam release frequency (into the reactor building) due to a break in an instrument line concurrent with an EFCV failure to close, and (2) assessment of the 6 ADAMS Accession No. ML072570267 7 ADAMS Accession No. ML103410243

radiological consequences of such a release. The NRC staff reviewed the GE TR and issued its evaluation on March 14, 2000. 8 In its evaluation, the NRC staff found that the test interval could be extended up to a maximum of 10 years. In conjunction with this finding, the NRC staff noted that each licensee that adopts the relaxed test interval program for EFCVs must have a failure feedback mechanism and CAP to ensure EFCV performance continues to be bounded by the TR results. Also, each licensee is required to perform a plant-specific radiological dose assessment, EFCV failure analysis, and release frequency analysis to confirm that the facility is bounded by the generic analyses of the TR.

The staff reviewed the licensee's proposal for its applicability to GE TR NED0-32977-A and conformance with the NRC staff's guidance regarding radiological dose assessment, EFCV failure rate and release frequency, and the proposed failure feedback mechanism and CAP. Based on its review, the NRC staff concludes that the radiological consequences of an EFCV failure are sufficiently low and acceptable, and that the alternative testing, in conjunction with the CAP and the SFCP, provides a high degree of valve reliability and operability. Additionally, an orifice is installed upstream of the EFCVs to limit reactor water leakage in the event of rupture. The orifice limits leakage to a level where the integrity and functional performance of secondary containment and associated safety systems are maintained. Therefore, the staff finds that the licensee's proposed test alternative provides an acceptable level of quality and safety.

3.4.6 Conclusion As set forth above, the NRC staff finds that the proposed alternative described in alternative request VR-01 provides an acceptable level of quality and safety for valves listed in Table 1 above. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ).

3.5 Licensee's Alternative Request VR-02 3.5.1 Code Requirements Paragraph 1-331 O of Mandatory Appendix I specifies the periodic testing requirements of ASME Class 1 main steam pressure relief valves with auxiliary actuating devices. The Code-required periodic testing for these valves includes, in part, seat tightness determination, set pressure determination, determination of electrical characteristics and pressure integrity of solenoid valve(s), determination of pressure integrity and stroke capability of air actuator, and determination of operation and electrical characteristics of position indicators.

The frequency of the required testing is specified in paragraph l-1320(a), which requires that these main steam relief valves be periodically tested at least once every 5 years, with a minimum of 20 percent of the valves tested within any 24 months, where the 20 percent shall be previously untested valves, if they exist.

3.4.2 Components for Which Relief is Requested The licensee requested relief from the OM Code requirements of Mandatory Appendix I for testing main steam safety relief valves (SRVs):

8 ADAMS Accession No. ML003691722

1SNPSV-F013A 1SNPSV-F013B 1SNPSV-F013C 1SNPSV-F013D 1SNPSV-F013E 1ABPSV-F013F 1ABPSV-F013G 1ABPSV-F013H 1ABPSV-F013J 1ABPSV-F013K 1ABPSV-F013L 1ABPSV-F013M 1ABPSV-F013P 1ABPSV-F013R These valves have a safety function in the open position to provide overpressure protection for the main steam header and reactor vessel. Additionally, valves 1SNPSV-F013A through E also serve an ECCS function in the automatic depressurization system (ADS) to depressurize the reactor vessel in the event of a small-break LOCA, coincident with a failure of the HPCI system.

3.5.3 Licensee's Basis for Requesting Relief The licensee is requesting to apply the SRV testing frequency required by Mandatory Appendix I to the pilot portion of these valves, but not to the main body of these valves. The valves are classified as OM Code Category C.

The licensee's basis for relief is as follows:

Hope Creek UFSAR Section 5.2.2.4.2.1.3 discusses the testing frequency of the safety relief valves (SRVs). This section states that Hope Creek "can achieve optimum SRV operability by disassembly of the pilot section of at least 50 percent of the operating SRVs after each cycle." PSEG implements the appropriate inspection guidance specified in General Electric Service Information Letter (SIL) No. 196.

Based on valve design, proper SRV operation and its ability to perform its intended function at the required set point are primarily determined by the pilot stage assembly of the valve. Target Rock Safety I Relief Valve Technical Manuals( ... for 2-stage and ... for 3-stage [valves]) describe the pilot stage assembly as the "pressure sensing and control elemenf' of the valve. A review of NRC Information Notices 82-41, 83-39, 83-82, 86-12, and 88-30 supports this conclusion, indicating that the pilot portions of these valves require diligent testing.

Hope Creek TS SR 4.4.2.2 requires that at least one-half (1/2) of the safety relief pilot stage assemblies be removed, set pressure tested and reinstalled or replaced with spares that have been previously set pressure tested and stored per manufacturer's recommendations in accordance with the Surveillance Frequency Control Program (18 months), and they shall be rotated such that all 14 SRV pilot stage assemblies are removed, set pressure tested and reinstalled or replaced with spares that have been previously set pressure tested and stored in accordance with the manufacturer's recommendations in accordance with the Surveillance Frequency Control Program (40 months). All safety relief valves will be re-certified to meet a +/- 1% tolerance prior to returning the valves to service after set point testing.

Hope Creek TS SR 4.4.2.3 requires that the safety relief valve main (mechanical) stage assemblies shall be set pressure tested and reinstalled or replaced with

spares that have been previously set pressure tested and stored in accordance with manufacturer's recommendations in accordance with the Surveillance Frequency Control Program (5 years).

3.5.4 Licensee's Proposed Alternative The licensee plans on testing the Hope Creek main steam SRVs in the following manner:

The Hope Creek Main Steam SRVs will be tested in accordance with TS SR 4.4.2.2 and 4.4.2.3. One-half (1/2) of the SRV's pilot stages will be removed and set pressure tested or replaced with previously tested assemblies every 18 months. In the event the "as-found" setpoint fails the setpoint testing, sample expansion of the other pilot valves will be conducted in accordance with paragraph l-1320(c) of Mandatory Appendix I. All 14 main stages (with the entire assembly} will be removed, tested and reinstalled or replaced every 5 years.

The true setpoint adjustment (and operability determination) of the valve is contained within the pilot portion of the SRV.

By applying the SRV testing frequency required by Mandatory Appendix I to the pilot portion (achieved by meeting TS SR 4.4.2.2), set point accuracy and pilot sticking verification can be maintained, providing an acceptable level of safety.

Testing of the main body (mechanical portion), which contains only the main disc, piston rings and a preload spring that is non-adjustable, at the Mandatory Appendix I specified frequency will not result in a significant increase in the level of safety. Testing of the mechanical portion of all 14 SRVs to provide verification of blowdown and flow rates is conducted every 5 years when the valves are tested as a complete assembly per TS SR 4.4.2.3.

3.5.5 NRC Staff Evaluation Paragraph 1-1320 of Mandatory Appendix I to the ASME OM Code states that all Class 1 pressure relief valves shall be tested at least once every 5 years, and a minimum of 20 percent of the valves from the group shall be tested within any 24-month interval. This 20 percent shall consist of valves that have not been tested during the current 5-year interval, if they exist. The test interval shall not exceed 5 years. Paragraph 1-331 O lists specific tests required to be performed.

The licensee has proposed to test the main steam SRVs in accordance with the TSs. The pilot stage will be tested separately from the main valve using a schedule of seven pilot stage assemblies (i.e., 50 percent) in accordance with the SFCP (every 18 months). At least one-half of the SRV pilot stage assemblies shall be removed, set pressure tested, and reinstalled or replaced with spares that have been previously set pressure tested and stored per manufacturer's recommendations in accordance with the SFCP (at least once per 18 months).

Additionally, those removed shall be rotated such that all 14 SRV pilot stage assemblies are removed, set pressure tested, and reinstalled or replaced with spares, in accordance with the SFCP (at least once per 40 months). This would result in the pilot stage assemblies being tested more frequently than required by the Code (i.e., at least every 40 months versus every 60 months, and a sample size of 50 percent per fuel cycle versus 20 percent per fuel cycle).

However, the complete sequence of tests will not be performed. The entire valve assembly (main stage with pilot stage) will be tested once every 5 years during a single outage.

The various discrete tests required by OM Code, Mandatory Appendix I, paragraph 1-3310, will be accomplished as follows: OM Code, Mandatory Appendix I, paragraph 1-3310, main stage tests and inspections will be performed once every 5 years, including:

(a) visual examination (b) seat tightness determination, if practicable (i) determination of compliance with the owner's seat tightness criteria OM Code, Mandatory Appendix I, paragraph 1-3310, pilot stage tests and inspections will be performed once every 18 months, including:

(a) visual examination (b) seat tightness determination, if practicable (c) set pressure determination (d) determination of electrical characteristics and pressure integrity of solenoid valve(s)

(e) determination of pressure integrity and stroke capability of air actuator (h) determination of actuating pressure of auxiliary actuating device sensing element, where applicable, and electrical continuity (i) determination of compliance with the Owner's seat tightness criteria The following tests are not applicable to the Hope Creek SRVs:

(f) determination of operation and electrical characteristics of position indicators (g) determination of operation and electrical characteristics of bellows alarm switch Although the proposed testing does not meet the sampling approach required by the Code, given the increased frequency of the pilot stage assembly test and that the overall test frequency complies with the Code (i.e., once every 5 years), this alternative will provide an acceptable level of quality and safety. Therefore, the NRC staff finds that the licensee's proposed alternative to the requirements of paragraphs 1-1320 and 1-3310 of Mandatory Appendix I to the ASME OM Code is acceptable.

Hope Creek has historically used, and continues to use, Target Rock 2-stage Model 7567F valves in the 14 main steam SRV locations identified above. Target Rock has begun supplying a new 3-stage Model 0867F replacement valve for this application at various plants, and these valves have shown to have main stage reliability characteristics different than the 2-stage valves. PSEG has excluded 3-stage Target Rock main steam SRVs from the scope of this

alternative request and has indicated that testing of the main stage of 3-stage Target Rock Model 0867F valves, if installed in the future, will be performed at the Mandatory Appendix I specified frequency. Authorization of alternative request VR-02 is, therefore, only applicable to Target Rock 2-stage Model 7567F valves at Hope Creek.

3.5.6 Conclusion As set forth above, the NRC staff determines that for alternative request VR-02 for Hope Creek, the proposed alternatives provide an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1) for request VR-02 for Hope Creek.

4.0 CONCLUSION

The following summarizes the conclusions as discussed in this Safety Evaluation in Section 3.0:

(1) With respect to relief requests PR-01, PR-02, VR-01, and VR-02, the proposed alternatives will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(z)(1 ), the proposed alternatives are authorized for the fourth 10-year IST interval at Hope Creek.

(2) With respect to relief request GR-01, the proposed alternative will provide reasonable assurance that the components are operationally ready, and compliance with the specified requirements would result in a hardship or unusual difficulty, without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(z)(2), the proposed alternative is authorized for the fourth 10-year IST interval at Hope Creek.

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

Principal Contributors: J. Billerbeck M. Farnan J. Huang D~e: December 20, 2016

ML16343A057 *b memos with safet evaluations dated OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NRR/DE/EPNB/BC* NRR/DE/EPNB/BC*

NAME CParker LRonewicz DAiiey DAiiey DATE 12/12/2016 12/09/2016 06/23/2016 07/12/2016 OFFICE NRR/DE/EPNB/BC* NRR/DORL/LPL 1/BC(A) NRR/DORL/LPL 1/PM NAME DAiiey SKoenick CParker DATE 12/03/2016 12/20/2016 12/20/2016

v t e Letter Sequence Other
CAC:MF7200, (Open) CAC:MF7201, (Open) CAC:MF7202, (Open) CAC:MF7203, (Open) CAC:MF7204, (Open)
Initiation Request, Request, Request Acceptance Administration Questions 5 May 2016 24 August 2016 Answers Results Approval... Other: ML16343A057
MONTHYEAR2016-05-05 [Table View]

ML16343A057