ML20217N232

Requests NRC Approval to Use Alternative to Requirements of 10CFR50.55a(f)(4)(ii).Licensee Requests Extension to Specified Schedule for Implementing Updates to IST Program

ML20217N232
Person / Time
Site:	Davis Besse
Issue date:	10/15/1999
From:	Campbell G CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2618, NUDOCS 9910280148
Download: ML20217N232 (6)

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---$f E EE Davis-Besse Nudear Power Statix 5501 North State Route 2 m Oak Harbor, ohio 43449 9760 Quy G. Campbell 419 421 8588 Vee President- Nudear Fax:419-321-8337

. Docket Number 50-346 License Number NPF-3 l

Serial Number 2618 4

October 15, 1999 United States Nuclear Regulatory Commission Document Control Desk -

Washington, D. C. 20555-0001

Subject:

Request for Alternative to 10 CFR 50.55a(f)(4)(ii), Inservice Testing Requirements Ladies and Gentlemen:

In accordance with the provisions of Title 10 of the Code of Federal Regulations (CFR),

Part 50.55a(a)(3)(i), the Davis-Besse Nuclear Power Station (DBNPS) requests authorization from the Nuclear Regulatory Commission (NRC) to use an attemative to the requirements of 10 CFR 50.55a(f)(4)(ii). This subsection states that licensees must comply with the requirements of the latest edition and addenda of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (B&PV) Code incorporated by reference in paragraph (b) of 10 CFR 50.55a on the date 12 months prior to the start of the 120-month interval. The DBNPS requests an extension to the specified schedule for implementing updates to the Inservice Testing (IST) program.

The current 120-month IST interval for the DBNPS ends September 12,2000. The DBNPS requests approval to submit the 120-month update to the IST Program Plan after this date.

Additional time is needed for development and approval of risk-informed IST (RI-IST) portions of the Program Plan, and for updating the remainder of the IST Program Plan which may not be

. risk-informed to the 1989 Edition of the ASME Code,Section XI. With NRC authorization, the DBNPS will continue to comply with the Code requirements as approved for the current 120-  !

. month interval beyond September 12,2000. During this extension period, the IST Program Plan  !

will be incrementally converted to the 1989 Edition of the ASME Code,Section XI, on a system-  !

by-system or component-by-component approach. Submittals of the RI-IST Program Plan to the NRC will be staggered on approximate six-month intervals. It is the intention of the DBNPS to i make a licensing submittal in the fourth quarter of 1999 for RI-IST of Air Operated Valves (AOVs), invoking the ASME OMN-3 Code Case, as the lead plant for the Babcock & Wilcox l (B&W) Owners Group project for the RI-IST of AOVs. Subsequently, the DBNPS would expand the RI-IST Program Plan to include Motor Operated Valves (MOVs), and possibly Check Valves or other components, on approximate six-month intervals. As RI-IST submittals  ;

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9910280148 991015 S' PDR- ADOCK 05000346 P pm _

. Document Number 50-346 Lic',ense Number NPF-3 Serial Number 2618 Page 2 s are approved, they will be incorporated into the RI-IST Program Plan. By January 2002, the DBNPS would complete the IST program update to the 1989 Edition of the ASME Code for any components not included in the RI-IST Program Plan. Therefore, the next interval will begin no later than February 1,2002. The attached relief request includes the basis andjustification for the proposed alternative to the regulatory requirements and an implementation plan. The proposed alternative will provide an acceptable level of quality and safety.

The DBNPS understands that an ASME Code Section XI edition later than the 1989 "ersion may

- be incorporated into 10 CFR 50.55a twelve months prior to the proposed start of the rcxt 120-month interval (start date of February 1,2002). Revising the IST program from the 1989 version at that later date for the purpose of complying with the new Code edition would further delay the start of the next IST interval. Consequently, the DBNPS also requests that the NRC approve updating the IST Program Plan to the 1989 Edition of the ASME B&PV Code,Section XI for the next interval even if a later edition is applicable.

Should you have any questions or require additional information, please conta-t Mr. James L. Fre-els, Manager - Regulatory Affairs, at (419) 321-8466.

Very truly yours, 4

GMW/s Attachments cc: J. E. Dyer, Regional Administrator, Region III S. N. Bailey, NRC/NRR Project Manager K. S. Zellers, DB-1 Senior Resident Inspector Utility Radiological Safety Board k

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. Docket Number 50-346 Lic[ense Number NPF-3 Serial Number 2618

-Attachment 1 Page1 RELIEF REQUEST RC-1 Reference Regulation: Title 10, Code of Federal Regulations, Part 50, Article 55a, " Codes and Standards," 10 CFR 50.55a(f)(4)(ii), " Inservice Testing Requirements."

Components for Which Alternative is Reauested:

l Name and Identification Number: All components (pumps and valves) listed in the Inservice Test (IST) Program Plan plus components to be added to comply with the 1989 American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI (ASME XI Code).

Function: Inservice Testing Program Plan includes components (pumps and valves) required to perform a specific function in shutting down the reactor to a safe shutdown condition, maintaining the reactor in a safe shutdown condition, or mitigating the consequences of an accident.

Class: ASME Class 1,2, and 3 Reculatory Reauirement from Which Altemative is Reauested:

10 CFR 50.55a(f)(4)(ii) states:

" Inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed in paragraph (b) of this section." i Compliance with this regulatory requirement would result in the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS) using the 1989 edition of the ASME XI Code at the beginning of the next 120-month IST interol However, the DBNPS proposes to extend the interval of the existing IST Program Plan that complies with the 1986 edition (no addenda) of the ASME XI Code. A revised Program Plan incorporating risk-informed (RI) portions and general updates utilizing the 1989 edition of the ASME XI Code will be phased in over the duration of the j requested extension, and will be fully implemented no later than February 1,2002. The next interval will begin no later than February 1,2002.

Basis for Relief from Reculatory Reauirements:

l The risk-informed IST (RI-IST) portions of the Program Plan, as well as implementing procedures, must be developed and approved. Implementation of RI-IST requires evaluation of components for safety significance. This will be done by working groups and reviewed by an expert panel to assess risk effects as a result of RI-IST. Submittals of the RI-IST Program Plan l

a Do.cket Number 50-346 Lic,ense Number NPF-3 Serial Number 2618 Attachment 1 Page 2 will be staggc.J on approximate six-month intervals. It is the intention of the DBNPS to make a a licensing submittal in t! e fourth quarter of 1999 for a RI-IST Program Plan for Air Operated Valves (AOVs), invoking the ASME OMN-3 Code Case, as the lead plant for the Babcock &

Wilcox (B&W) Owners Group project for the RI-IST for AOVs. Subsequently, the DBNPS would expand the RI-IST Program Plan to include Motor Operated Valves (MOVs), and possibly Check Valves or other components, on approximate six-month intervals.

The 1989 edition of the ASME XI Code must also be applied for the remainder of the IST Program Plan that may nu N rkk-informed. The new r, cope of the IST program for the 1989 edition of the ASME Xi Cod: changes the acceptance criteria for stroke time testing of power-operated valves, and pump vibration readings based on velocity (in/sec) rather than displacement 4

(mils). D-velopment or alteration of pump and valve testing procedures to inc6rporate these changcs will require significant resources.

In addition to the resource requirements for the ASME XI Code update, the Twelfth Refueling outage activities will require preparation and support. This outage, scheduled to begin in April 2000, includes a full core offload for Inservice Inspectior. of the reactor vessel in addition to steam generator cleaning.

In order to accommodate the activities described above, the DBNPS requests an extension of the current 120-month interval to provide sufficient time to allow development of the RI-IST/IST Program Plan for the next 120-month interval. Furthermore, maintaining the applicable ASME XI Code as the 1989 edition will allow the DBNPS to plan and schedule resources for the updated program for pump and valve testing without needing another schedule extension for implementation beyond the one requested in this submittal.

Proposed Alternative Testin,_g:

Pursuant to 10 CFR 50.55a(a)(3)(i). the DBNPS proposes an alternative to 10 CFR 50.55a(f)(4)(ii) that would provide an acceptable level of safety.

As an alternative to the referenced regulation, the DBNPS will continue using the existing IST I Program Plan (1986 edition of the ASME XI Code) beyond the end date of the current interval, l which is September 12,2000. The DBNPS will continue to perform IST requirements as specified in the current IST Program Plan, until the requirements of the updated RI-IST/IST Program Plan are invoked. The current IST Program Plan is in compliance with the 1986 edition of the ASME XI Code (no addenda), which is similar to the 1989 edition of the ASME XI Code,  !

and provides an acceptable level of quality and safety.

The DBNPS willimplement a RI-IST/IST Program Plan. The risk-informed portion of the l Program Plan will require the developme..t ofimplementing procedures / guidelines. Once the implementing procedures / guidelines are developed and approved, RI-IST submittals that have been approved will be incorporated into the Program Plan. Portions of the Program Plan that

. o Docket Number.50-346 Lic,ense Number NPF-3 Serial Number 2618 Attachment 1 Page 3 may not be risk-informed will be altered to comply with the 1989 edition of the ASME XI Code.

This conversion to the new code will be incrementally implemented on a system-by-system or component-by-component approach, over the extension period.

Based on new ASME XI Code testing requirements and in conjunction with new testing frequencies and strategies from the rid-informed decisions, the scope of changes to inservice tests will be determined. This evaluation will maximize testing efforts while minimizing impact on the plant. Consequently, many of the components will be in compliance before the extended date requested for full compliance with the regulation for ASME XI Code updates to the IST Program Plan.

Development of the IST Program Plan for the next 120-month interval based on the 1989 edition of the' ASME XI Code rather than the later version is appropriate because the 1989 edition, currently approved by the NRC, will result in a program that provides an acceptable level of quality and safety.

Implementation Plan:

Upon approval of this request by the NRC, the DBNPS will begin the risk-informed program review. This process will include evaluation of the risk significance of scoped components by working groups, followed by approval of the risk rankings by an expert panel. For the portion of j the Program Plan that may not be risk-informed, the DBNPS will also begin the system-by-system or component-by-component conversion to the 1989 ASME XI Code. The estimated comple: don date for the entire RI-IST/IST Program Plan development is the winter of 2002. The updated IST Program Plan, including RI portions, will be fully implemented no later than Febmary 1,2002.

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, , .. o _ . Do,cket Number 50-346 Lic,ense Number NPF-3 l Serial Number 2618

! Attachment 2 Page1 l

COMMITMENT LIST i The following list identifies those actions committed to by the Davis-Besse Nuclear Pov/er l Station in this document. Any other actions discussed in the submittal represent intended or planned actions by Davis-Besse. They are described only as information and are not regulatory commitments. Please notify the Manager- Regulatory Affairs (419-321-8466) at Davis-Besse of )

any questions regarding this document or associated regulatory commitments.

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! C_OMMITMENTS DUE DATE Continue to comply with the ASME XI Code requirements Until associated requirements of as approved for the current 120-month interval Inservice the updated RI-IST/IST Program I

Testing Program. Plan are invoked.

For the portions of the Inservice Testir.3 Program Plan that January 31,2002, are not risk-informed, complete the 120-month update to the 1989 edition of the ASME XI Code.

Fully implement the updated Inservice Testing Program February 1,2002. j Plan (including Risk-Informed portions).

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