NG-13-0401, Relief Request for Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety

Relief Request for Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety

ML13308A318
Person / Time
Site:	Duane Arnold
Issue date:	10/28/2013
From:	Richard Anderson NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-13-0401
Download: ML13308A318 (8)

Text

NEXTera EN ERGYýL DUANE ARNL October 28, 2013 NG-1 3-0401 10 CFR 50.55(a)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 Relief Request For Hardship Or Unusual Difficulty Without Compensating Increase In Level Of Quality or Safety Pursuant to 10 CFR 50.55a(g)(5)(iii), NextEra Energy Duane Arnold, LLC, (hereafter, NextEra Energy Duane Arnold) hereby requests NRC approval of the enclosed relief request from the American Society of Mechanical Engineers (ASME) OM Code Section. Relief is requested for the Fourth Ten Year Interval of the Inservice Inspection Program for the Duane Arnold Energy Center, which ends on October 31, 2016. The enclosure to this letter contains the request for relief.

NextEra Energy Duane Arnold requests approval of this request by the end of May, 2014.

Ifyou have any questions, please contact J. Michael Davis at (319) 851-7032.

Zihar* d L.nde Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-13-0401 Page 2 of 2 cc: Administrator, Region III, USNRC Project Manager, DAEC, USNRC Senior Resident Inspector, DAEC, USNRC

Enclosure to NG-13-0401 10 CFR 50.55a Request Pursuant To 10 CFR 50.55a(g)(5)(iii) For Hardship Or Unusual Difficulty Without Compensatinq Increase In Level Of Quality or Safety 5 pages follow

,General Relief Request - VR-03 "Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety" In Accordance with IOCFR50.55a(a)(3)(ii)

1. ASME Code Components Affected All pumps and valves contained within the Inservice Testing (IST) Program scope.

2. Applicable Code Edition and Addenda ASME OM Code 2001 Edition through 2003 Addenda

3. Applicable Code Requirement This request applies to the frequency specifications of the ASME OM Code. The frequencies for tests given in the ASME OM Code do not include a tolerance band.

Code Paragraph Description ISTA-3120(a)- "The frequency for the inservice testing shall be in accordance with the requirements of Section IST."

ISTB-3400- Frequency of Inservice Tests ISTC-3510- Exercising Test Frequency ISTC-3540- Manual Valves ISTC-3630(a) Frequency ISTC-3700- Position Verification Testing ISTC-5221(c)(3) - "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

Appendix 1,1-1320- Test Frequencies, Class 1 Pressure Relief Valves Appendix 1,1-1330- Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Appendix 1, 1-1340- Test Frequencies- Class 1 Pressure Relief Valves that are used for Thermal Relief Application Appendix 1,1-1350- Test Frequencies- Class 2 and 3 Pressure Relief Valves Appendix 1, 1-1360- Test Frequencies - Class 2 and 3 Nonreclosing I Pressure Relief Devices Page 1 of 5

Code Paragraph Description Appendix 1, 1-1370- Test Frequencies- Class 2 and 3 Primary Containment Vacuum Relief Valves Appendix 1, 1-1380- Test Frequencies- Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Appendix 1,1-1390- Test Frequencies- Class 1 Pressure Relief Valves that are used for Thermal Relief Application Appendix II, Performance Improvement Activities Interval 11-4000(a)(1)-

Appendix II, Optimization of Condition Monitoring Activities 11-4000(b)(1)(e)- Interval

4. Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a}{3}{ii), relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section Inservice Testing (IST) establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies and are defined in plant Technical Specifications (TS) Section 5.5.6, Administrative Controls, Programs and Manuals - Inservice Testing Program. Licensees routinely applied the surveillance extension time period (i.e., grace period) contained in the plant TS Surveillance Requirements (SR) Applicability, specifically SR 3.0.2. This TS allows for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance. However, regulatory issues have been raised concerning the applicability of the TS "grace period" to ASME OM Code required IST frequencies irrespective of allowances provided under TS SR 3.0.2.

The lack of a tolerance band on the ASME OM Code IST frequency restricts operational flexibility. There may be a conflict where a surveillance test could be required (i.e., its frequency could expire),

but where it is not possible or not desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation (LCO) is within its applicability. Therefore, to avoid this conflict, the surveillance test should be performed when it can and should be performed.

The NRC recognized this potential issue in the TS by allowing a Page 2 of 5

frequency tolerance as described in TS SR 3.0.2. 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 surveillance tests that minimize the conflicts between the need to complete the surveillance and plant conditions.

5. Proposed Alternative and Basis for Use Code Case OMN-20 is included in the ASME OM Code, 2009 Edition and will be used as the alternative to the frequencies specified in ASME OM Code.

The requirements of Code Case OMN-20 are described below.

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 based 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 Page 3 of 5

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 Subsection ISTD, Preservice and Inservice 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 (or every 92 days 3 months)

Semiannually (or every 184 days 6 months)

Annually (or every year) 366 days x Years x calendar years where 'x' is a whole number of years ->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 ASME OM Division: 1 Section IST 2009 Edition through OMa-2011 Addenda and earlier editions and addenda of ASME OM Code.

6. Duration of Proposed Alternative The proposed alternative identified in this relief request shall be utilized during the fourth 10-year IST Interval that began on February 1, 2006.

7. Precedent Request Number RV-01 for Quad Cities Units 1 and 2 was approved by the NRC by letter dated 2/14/2013 (TAC Nos. ME7981 through ME7988, ME7990 though ME7995), Accession No. ML13042A348.

Page 4 of 5

8. References

a. DAEC TS Section 1.4 Frequency

b. DAEC TS Section 5.5.6 Inservice Testing Program

c. DAEC TS SR 3.0.2 Specified Frequency (25% grace Period)

d. DAEC TS SR 3.0.4 Mode Entry Requirements Page 5 of 5