ML17201M289

Issuance of Relief Request No. RR-001 - Alternative to Certain Requirements of the ASME Code for Extension of the Fourth 10-Year Inservice Testing Interval

ML17201M289
Person / Time
Site:	FitzPatrick
Issue date:	08/04/2017
From:	James Danna Plant Licensing Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Venkataraman B, NRR/DORL/LPL1
References
CAC MF9819
Download: ML17201M289 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 4, 2017 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - ISSUANCE OF RELIEF REQUEST NO. RR-001 - ALTERNATIVE TO CERTAIN REQUIREMENTS OF THE ASME CODE FOR EXTENSION OF THE FOURTH 10-YEAR INSERVICE TESTING INTERVAL (CAC NO. MF9819)

Dear Mr. Hanson:

By letter dated June 7, 2017 (Agencywide Documents Access and Management System Accession No. ML17158B295), Exelon Generation Company, LLC (the licensee) submitted an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) associated with extending the fourth 10-year inservice testing (IST) interval at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick).

Specifically, pursuant to Title 1O of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested to use the proposed alternative in Relief Request No. RR-001 (RR-001) on the basis that the ASME OM Code requirements present an undue hardship, without a compensating increase in the level of quality and safety. The licensee is requesting an 8-month extension of the fourth 10-year IST interval. The end date of the fourth interval would be extended from September 30, 2017, to May 31, 2018.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that for RR-001 for FitzPatrick, 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(z)(2) for RR-001. Therefore, the NRC staff authorizes the use of the alternative in RR-001 for FitzPatrick for the fourth 10-year IST program interval, which began on October 1, 2007, and is scheduled to end on May 31, 2018.

All other ASME OM Code requirements for which relief was not specifically requested and approved in this proposed alternative, RR-001, remain in effect.

B. Hanson If you have any questions, please contact the Project Manager, Booma Venkataraman, at 301-415-2934 or Booma.Venkataraman@nrc.gov.

Sincerely,

(;~ D~~

Jam~s G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation 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 NO. RR-001 FOR ALTERNATIVE TO FOURTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM EXELON GENERATION COMPANY. LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By letter dated June 7, 2017 (Agencywide Documents Access and Management System Accession No. ML17158B295), Exelon Generation Company, LLC (the licensee) submitted an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), associated with extending the fourth 10-year inservice testing (IST) interval at James A FitzPatrick Nuclear Power Plant (FitzPatrick).

Specifically, pursuant to Title 1O of the Code of Federal Regulations (1 O CFR) 50.55a(z)(2), the licensee requested to use the proposed alternative in Relief Request No. RR-001 (RR-001) on the basis that the ASME OM Code requirements present an undue hardship, without a compensating increase in the level of quality or safety.

2.0 REGULATORY REQUIREMENTS Section 50.55a(f) of 10 CFR states that 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.

Section 50.55a(z) of 10 CFR states that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be used when authorized by the U.S. Nuclear Regulatory Commission (NRC or the Commission) if the licensee demonstrates (1) the proposed alternatives would provide 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 ASME OM Code Components Affected The licensee has requested to use the proposed alternative described below for all IST components.

3.2 ASME OM Code Requirements The applicable ASME OM Code edition and addenda for the FitzPatrick fourth 10-year IST program interval is the 2001 Edition through the 2003 Addenda.

3.3 Licensee's Reason for Request FitzPatrick, which was operated by Entergy Operations, Inc. (Entergy), was expected to shut down prior to the start of the fifth 10-year IST interval and be decommissioned. Therefore, no IST program was developed for the fifth 10-year IST interval, which is scheduled to begin on October 1, 2017. The licensee purchased FitzPatrick in April 2017. This allowed approximately 6 months to prepare for the fifth 10-year IST interval, develop a new IST program, and submit any necessary relief and alternative requests for NRG review and approval. Entergy had previously made two extensions of past IST intervals totaling 1 year, which is the maximum extension time allowed by the ASME OM Code. The FitzPatrick fourth 10-year IST program interval began on October 1, 2007, and is scheduled to end on September 30, 2017.

3.4 Licensee's Proposed Alternative The licensee requested an alternative to the IST interval duration requirement of the ASME OM Code.

ISTA-3120, "lnservice Test Interval," paragraph (c), states, in part:

The inservice test intervals shall comply with the following, except as modified by ISTA-3120(d) and ISTA-3120(e): ...

(2) Successive Test Intervals: 10 years following the previous test intervals.

The licensee is requesting an 8-month extension of the fourth 10-year IST interval in order to prepare for the fifth 10-year IST interval, develop a new IST program that is applicable to the latest edition of the ASME OM Code, and submit any applicable relief requests to the NRG to review and approve. The end date for the fourth interval would be extended from September 30, 2017, to May 31, 2018.

The requested 8-month extension will be recovered by ending the fifth 10-year IST interval on September 30, 2027. The fifth interval will start on June 1, 2018, if the fourth interval is extended 8 months.

All the alternatives and relief requests that were approved by the NRG for the fourth 10-year IST interval (see Table 1) will be extended until May 31, 2018, the proposed end date of the interval.

The licensee will comply with the requirements specified in the ASME OM Code, 2001 Edition through the 2003 Addenda, and the approved alternatives and relief requests listed in Table 1.

Table 1 Alternatives and Relief Requests Approved for the Fourth 10-Year IST Interval Request No. Description VRR-01 Withdrawn VRR-02 Traversing In-Core Probe Containment Isolation Valve Stroke Time VRR-03 Excess Flow Check Valve Exercise Testinq Durinq Refuelinq Outaqes VRR-04 Hiqh Pressure Coolant Injection Check Valve Online Testinq VRR-05 Power-Operated System Control Valves With Safety Function VRR-06 Safety Relief Valve Testinq Interval VRR-07 Pressure Isolation Valve Testing at Appendix J Frequency VRR-08 Solenoid Operated Valve Position Indication Testinq At Appendix J Frequency PRR-01 Withdrawn PRR-02 Core Spray Pump Suction Pressure Gauge Range PRR-03 Emerqencv Service Water Pumps Use Of A Pump Curve PRR-04 Residual Heat Removal Service Water And Emergency Service Water Smooth Runninq Pumps PRR-05 Residual Heat Removal Pump Vibration Alert Range 3.5 NRC Staff Evaluation of the Alternative An IST program was not developed for the fifth 10-year IST interval for FitzPatrick because Entergy, the owner at the time, was planning to shut down and decommission the plant.

However, the licensee bought the plant in April 2017. With the fifth 10-year IST interval scheduled to begin on October 1, 2017, the licensee has approximately 6 months to develop a new IST program that is applicable to the latest edition of the ASME OM Code, 2004 Edition through the 2006 Addenda, and submit any applicable alternatives and relief requests to the NRC for review and approval. A time period of 6 months is not enough to perform these tasks.

The typical turnaround time on alternatives and relief requests submitted to the NRC is 1 year.

The NRC staff considers it a hardship for the licensee to perform these tasks in 6 months.

The licensee proposed to extend the current fourth 10-year IST interval by approximately 6 months, to May 31, 2018, in order to make the necessary preparations for the fifth 10-year IST interval. The fifth interval would end on September 30, 2027, which would recover the 8-month extension of the fourth 10-year IST interval. Because Entergy previously extended the Fitzpatrick IST interval for a total of 12 months, which is the maximum extension allowed by the ASME OM Code, the end date of the fifth 10-year IST interval will keep the future IST intervals a year off the initial schedule. The currently NRG-approved alternatives and relief requests for the fourth interval will be in effect until the end of the extended fourth interval. The extended fourth 10-year IST interval will not affect the testing of the IST components. Given that there are no substantial differences in the IST requirements of the licensee's current Code of Record for the fourth 10-year IST interval and the Code of Record that will be adopted in the fifth 10-year IST interval, the NRC staff finds that there will be no significant difference in the quality or safety as a result of the proposed extension.

4.0 CONCLUSION

As set forth above, the NRC staff determined that for the alternative in RR-001 for FitzPatrick, 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(z)(2) for RR-001.

Therefore, the NRC staff authorizes the use of the alternative in RR-001 for FitzPatrick for the fourth 10-year IST program interval, which began on October 1, 2007, and is scheduled to end on May 31, 2018.

All other ASME OM Code requirements for which relief was not specifically requested and approved in this proposed alternative, RR-001, remain in effect.

Principal Contributor: Robert Wolfgang Date: August 4, 2017

B. Hanson

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT-ALTERNATIVE TO THE REQUIREMENTS OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE FOR OPERATION AND MAINTENANCE OF NUCLEAR POWER PLANTS (CAC NO. MF9819) DATED AUGUST 4, 2017 DISTRIBUTION:

Public RidsNrrLALRonewicz RidsNrrDorlLpl1 RidsACRS_MailCTR RidsNrrPMFitzPatrick RidsRgn1 MailCenter RidsNrrDeEpnb RWolfgang, NRR JBowen, OEDO ADAMS Access1on Num ber: ML17201M289 *b1y e-ma1*1 OFFICE DORULPL 1/PM DOR UL PL 1/LA DE/EPNB/BC* DORULPL 1/BC DOR UL PL 1/PM NAME BVenkataraman LRonewicz DAiiey JDanna BVenkataraman DATE 07/31/2017 07/31/2017 07/20/2017 08/04/2017 08/04/2017 OFFICIAL RECORD COPY