ML17096A627

Proposed Alternative to Use ASME OM Code Case OMN-20

ML17096A627
Person / Time
Site:	Cook
Issue date:	04/12/2017
From:	David Wrona Plant Licensing Branch III
To:	Gebbie J Indiana Michigan Power Co
Dietrich A, NRR/DORL/LPLIII, 415-2846
References
CAC MF8152, CAC MF8153
Download: ML17096A627 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 12, 2017 Mr. Joel P. Gebbie Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 - PROPOSED ALTERNATIVE TO USEASME OM CODE CASE OMN-20 (CAC NOS. MF8152 AND MF8153)

Dear Mr. Gebbie:

By letter dated July 21, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16208A076), as supplemented by letter dated September 26, 2016 (ADAMS Accession No. ML16272A165), Indiana Michigan Power Company (l&M, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of alternatives to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the Donald C. Cook Nuclear Plant (CNP), Unit Nos. 1 and 2. The licensee requested to use the ASME OM Code Case OMN-20, "lnservice Test [IST] Frequency," as an alternative to the IST frequencies for pumps and valves specified in ASME OM Code, Division 1, Section IST.

Specifically, pursuant to Title 1O of the Code of Federal Regulations (1 O CFR), Section 55a(z)(2), the licensee requested to use the proposed alternative on the basis that complying with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The 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(z)(2).

Therefore, the NRC authorizes the use of the proposed alternative at CNP for the remainder of the fifth 10-year IST interval, which will end on June 30, 2026.

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

J. Gebbie If you have any questions, please contact Allison W. Dietrich at 301-415-2846, or via e-mail at Allison. Dietrich@nrc.gov.

David J. Wrona, Chief Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

Safety Evaluation cc: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED ALTERNATIVE FOR THE INSERVICE TESTING PROGRAM INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-315 AND 50-316

1.0 INTRODUCTION

By letter dated July 21, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16208A076), as supplemented by letter dated September 26, 2016, (ADAMS Accession No. ML16272A165), Indiana Michigan Power Company (l&M, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC or the Commission) for the use of an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the Donald C. Cook Nuclear Plant (CNP), Unit Nos. 1 and 2. The licensee requested to use the ASME OM Code Case OMN-20, "lnservice Test [IST] Frequency," as an alternative to the IST frequencies for pumps and valves specified in ASME OM Code, Division 1, Section IST, during the current fifth 10-year IST interval, which will end on June 30, 2026.

Specifically, pursuant to Title 1O of the Code of Federal Regulations (1 O CFR) Section 50.55a(z)(2),

the licensee requested to use proposed alternatives, since complying with the current ASME OM Code requirements 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 IST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs 10 CFR 50.55a(z)(1) or 10 CFR 50.55a(z)(2).

The regulations in 10 CFR 50.55a(z) state, in part, that alternatives to the ASME Code requirements may be authorized by the NRC if the licensee demonstrates that: (1) the proposed alternative provides an acceptable level of quality and safety, or (2) 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.

Enclosure

3.0 TECHNICAL EVALUATION

3.1. Licensee's Alternative Requests ASME OM Code Requirements:

This request relates to the test frequency requirements for pumps and valves applicable to ASME OM Division 1, Section IST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of the ASME OM Code. The CNP code edition and addenda that are applicable to the current fifth program interval is ASME OM Code 2004 Edition through the 2006 Addenda. to the letter dated July 21, 2016, states, in part:

Reason for Request

The IST Program controls specified in Section 5.5.6 of [technical specifications (TSs)] provide: a) a table specifying certain IST frequencies; b) an allowance to apply SR [surveillance requirement] 3.0.2 to inservice tests required by the OM Code and with frequencies of two years or less; c) an allowance to apply SR 3.0.3 to inservice tests required by the OM Code; and d) a statement that, "Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS."

In 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," and 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," the Nuclear Regulatory Commission (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).

In RIS 2012-10 and EGM 2012-001, the NRC stated 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.

In response, OMN-20, which provides allowances similar to SR 3.0.2, was approved and is proposed to be used as an alternative to the test periods specified in the OM code.

Proposed Alternative and Basis for Use The proposed alternative is OMN-20, "lnservice Test Frequency," which addresses testing periods 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 ASME OM Code.

This 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:

1) For IST testing periods up to and including 2 years, Code Case OMN-20 provides an allowance to extend the IST testing periods by up to 25%. 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 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 TS SR 3.0.2 allowance and the statements regarding its use in the SR 3.0.2 Bases. Use of the SR 3.0.2 period extension has been a practice in the nuclear industry for many decades and elimination of this allowance would place a hardship on CNP when there is no evidence that the period extensions affect component reliability.

2) For IST periods of greater than 2 years, 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.

3) As stated in EGM 2012-001, if an lnservice Test is not performed within its frequency, SR 3.0.3 will not be applied. The effect of a missed lnservice Test on the Operability of TS equipment will be assessed under the licensee's Operability Determination Program.

The proposed alternative is requested for the current 10-year CNP IST interval or until Code Case OMN-20 is incorporated into a future revision of Regulatory Guide 1.192 referenced by a future revision of 10 CFR 50.55a, whichever occurs first. Currently, CNP is in its fifth interval.

3.2 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 (see Section 3.1.3 of NUREG-1482, Revision 2, "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," October 2013 (ADAMS Accession No. ML13295A020)). Recently, the NRC 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, "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 intervals cannot be extended in accordance with TS SR 3.0.2. This includes all IST 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-like test interval definitions and interval extension criteria. The resultant 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. Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code, 2012 Edition. The licensee has proposed to adopt Code Case OMN-20 at CNP, as an alternative to the IST frequencies for pumps and valves specified in the ASME OM Code, Division 1, Section IST.

The NRC staff has determined that requiring the licensee to meet the ASME OM Code requirements and applicable adopted ASME OM Code Cases, without an allowance for defined test intervals and test interval extensions for IST of pumps and valves, would cause a loss of operational flexibility for meeting the 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 NRC staff of similar TS test interval definitions and interval extension criteria, the staff concludes that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. Allowing the use of Code Case OMN-20 provides reasonable assurance of operational readiness of pumps and valves subject to the ASME OM Code, Division 1, Section IST, requirements.

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. The NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2).

Accordingly, the NRC staff authorizes the adoption of Code Case OMN-20 for the remainder of the fifth 10-year IST interval at CNP, which is currently scheduled to end on June 30, 2026. All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

Principal Contributor: J. Billerbeck

ML17096A627 *via memorandum OFFICE DORL/LPL3/PM DORL/LPL3/LA DE/EPN B/BC* DORL/LPL3/BC NAME A Dietrich SRohrer DAiiey DWrona (RKuntz for)

DATE 4/6/17 4/10/17 3/30/17 4/12/17