NL-17-0082, Submittal of the Lnservice Testing Program Alternatives for the Fifth Ten-Year Interval

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Submittal of the Lnservice Testing Program Alternatives for the Fifth Ten-Year Interval
ML17037D324
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 02/06/2017
From: Pierce C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-0082
Download: ML17037D324 (20)
v • d • e


Text

~ Southern Nuclear Charles R. Pierce Regulatory AHairs Director 40 Inverness Center Parkway Posl Office Box 1295 Bim1ingham. AL 35242 205 992 7872 lei 205 992 760 I fax crpierce@soulhemco.com fEB 0 6 ZOi7 Docket Nos.: 50-348 NL-17-0082 50-364 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant- Units 1 and 2 Submittal of the lnservice Testing Program Alternatives for the Fifth Ten-Year Interval Ladies and Gentlemen:

Pursuant to 10 CFR 50.55a(z) and 10 CFR 50.55a(f), Southern Nuclear Operating Company (SNC) hereby requests Nuclear Regulatory Commission (NRC) approval of the following alternatives for Farley Nuclear Plant (FNP) Units 1 and 2. These alternatives are applicable to the Fifth Ten-Year lntervallnservice Testing Program which will start on December 1, 2017:

RR-PR-02 Establish test flow reference ranges per Code Case OMN-21 RR-PR-03 Service Water Pumps and Transfer Pumps Pressure Accuracy RR-VR-01 Establish 1st interval grace periods per Code Case OMN-20 SNC requests that the NRC approve the proposed alternatives for FNP Units 1 and 2 by November 15,2017.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.

R2e~lly~ed, C.R. Pierce Regulatory Affairs Director CRP/JMC/Iac

U. S. Nuclear Regulatory Commission NL-17-0082 Page2

Enclosures:

1. Proposed Alternative RR-PR-02, Version 1.0
2. Proposed Alternative RR-PR-03, Version 1.0
3. Proposed Alternative RR-VR-01, Version 1.0 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RTYPE: CFA04.054 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley

Joseph M. Farley Nuclear Plant Unit 1 and 2 Submittal of the lnservice Testing Program Alternatives for the Fifth Ten-Year Interval Enclosure 1 Proposed Alternative RR-PR-02, Version 1.0 to NL-17-0082 Proposed Alternative RR-PR-02, Version 1.0 PLANT/UNIT: Farley Nuclear Plant (FNP), Units 1 and 2 INTERVAL: 5th Interval beginning December 1, 2017, and ending November 30, 2027 COMPONENTS Refer to Table RR-PR-02 AFFECTED:

CODE EDITION ASME OM Code-2004 Edition with Addenda through OMb-2006 AND ADDENDA:

REQUIREMENTS: ISTB-5121, "Group A Test Procedure," paragraph ISTB-5121(b) states, in part, that The resistance of the system shall be varied until the flow rate equals the reference point. ... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point. .. "

ISTB-5122, "Group B Test Procedure," paragraph ISTB-5122(c) states, "System resistance may be varied as necessary to achieve the reference point."

ISTB-5123, "Comprehensive Test Procedure," paragraph ISTB-5123(b) states, in part, that the resistance of the system shall be varied until the flow rate equals the reference point.

... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point. .. "

ISTB-5221, "Group A Test Procedure," paragraph ISTB-5221 (b) states, in part, that The resistance of the system shall be varied until the flow rate equals the reference point. ... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point..."

ISTB-5222, "Group B Test Procedure," paragraph ISTB-5222(c) states, "System resistance may be varied as necessary to achieve the reference point."

ISTB-5223, "Comprehensive Test Procedure," paragraph ISTB-5123(b) states, in part, that The resistance of the system shall be varied until the flow rate equals the reference point.

... Alternatively, the flow rate shall be varied until the differential pressure equals the reference point..."

REASON FOR Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph REQUEST: (z)(1 ), an alternative is proposed to the pump testing reference value requirements of the ASME OM Code. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety. Specifically, this alternative is requested for all inservice testing of 1ST Program pumps for FNP, Units 1 and 2, as listed in attached Table RR-PR-02, Pumps Affected by Alternative Request RR-PR-02.

E1 - 1 to NL-17-0082 Proposed Alternative RR-PR-02, Version 1.0 REASON FOR For pump testing, there is difficulty adjusting system throttle valves REQUEST: with sufficient precision to achieve exact flow reference values (continued) during subsequent 1ST tests. Subsection ISTB of the ASME OM Code does not allow for variance from a fixed reference value for pump testing. However, NUREG-1482, Revision 2, Section 5.3, acknowledges that certain pump system designs do not allow for the licensee to set the flow at an exact value because of limitations in the instruments and controls for maintaining steady flow.

ASME OM Code Case OMN-21, "Alternative Requirements for Adjusting Hydraulic Parameters to Specified Reference Points,"

provides guidance for adjusting reference flow or differential pressure (~P) to within a specified tolerance during pump inservice testing. The Code Case states that:

"It is the opinion of the Committee that when it is impractical to operate a pump at a specified reference point and adjust the resistance of the system to a specified reference point for either flow rate, differential pressure or discharge pressure, the pump may be operated as close as practical to the specified reference point with the following requirements. The Owner shall adjust the system resistance to as close as practical to the specified reference point where the variance from the reference point does not exceed + 2% or - 1% of the reference point when the reference point is flow rate, or+ 1% or - 2% of the reference point when the reference point is differential pressure or discharge pressure."

The NRC also discusses this ASME Code change in NUREG-1482, Revision 2, Section 5.3.

PROPOSED FNP seeks to perform future inservice pump testing in a manner ALTERNATIVE consistent with the requirements as stated in ASME OM Code Case AND BASIS: OMN-21. Specifically, testing of all pumps identified in Table RR-PR-02 will be performed such that the flow rate is adjusted as close as practical to the reference value and within proceduralized limits of

+2% I -1% of the reference flow rate when the reference point is flow rate and the differential pressure will be adjusted as close as practical to the reference value and within the proceduralized limits of + 1% I -2% of the reference differential pressure when the reference point is differential pressure.

FNP plant operators will continue to strive to achieve the exact test reference values (flow or differential pressure) during testing.

Typical test guidance will be to adjust flow or differential pressure to the specific reference value with additional guidance that if the reference value cannot be achieved with reasonable effort, the test will be considered valid if the steady state flow rate is within the proceduralized limits of +2% I -1% of the reference value or the steady state differential pressure is within the proceduralized limits of + 1% I -2% of the reference value.

E1- 2 to NL-17-0082 Proposed Alternative RR-PR-02, Version 1.0 PROPOSED Using the provisions of this request as an alternative to the specific ALTERNATIVE requirements of ISTB-5121, ISTB-5122, ISTB-5123, ISTB-5221, AND BASIS: ISTB-5222, and ISTB-5223, as described above, will provide (Continued) adequate indication of pump performance and continue to provide an acceptable level of quality and safety.

Based on the determination that the use of controlled reference value ranges provides an acceptable level of quality and safety, this proposed alternative should be granted pursuant to 10 CFR 50.55a{z)(1 ).

DURATION: 51h 1ST Interval, beginning December 1, 2017, and ending November 30,2027 PRECEDENTS: 1. Callaway Plant, Unit 1 - Relief Request PR-06, Alternative to ASME OM Code Requirements for 1ST for the Fourth Program Interval -

Safety Evaluation dated July 15,2014 (ML14178A769)

2. Wolf Creek Generating Station -Request for Relief 4PR-01 for the Fourth 10-Year lnservice Testing Program Interval- Safety Evaluation dated May 15,2015 (ML15134A002)

REFERENCES:

1. ASME Code Case OMN-21, Alternative Requirements for Adjusting Hydraulic Parameters to Specified Reference Points
2. 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, Section 5.3, Allowable Variance from Reference Points and Fixed-Resistance Systems, dated October 2013 (ML13295A020)

E1- 3 to NL-17-0082 Proposed Alternative RR-PR-02, Version 1.0 Table RR-PR-02, Pumps Affected by Alternative Request RR-PR-02 ASME ASMEOM Pump Groups Description Pump Type Code Code (Unit 1)

Class Category 01 E11 P001A Residual Heat Removal Centrifugal 2 Group A 01 E11 P001B (RHR) 01E13P001A Containment Spray (CS) Centrifugal 2 Group B 01E13P001B 01E21P002A Charging/High Head Safety Centrifugal 2 Group A 01E21P002B Injection (HHSI) 01E21P002C 01E21P005A Boric Acid Transfer (BAT} Centrifugal 3 Group A 01E21P005B 01N23P001A Motor Driven Auxiliary Centrifugal 3 Group A 01N23P001B Feedwater (AFW) 01N23P002 Turbine Driven AFW Centrifugal 3 Group B 01P16P001A Service Water Vertical Line 3 Group A 01P16P001B Shaft Centrifugal 01P16P001C 01P16P001D 01P16P001E 01P17P001A Component Cooling Water Centrifugal 3 Group A 01P17P001B 01P17P001C E1- 4 to NL-17-0082 Proposed Alternative RR-PR-02, Version 1.0 Table RR-PR-02, Pumps Affected by Alternative Request RR-PR-02 ASME ASMEOM Pump Groups Description Pump Type Code Code (Unit 2)

Class Category Q2E11P001A Residual Heat Removal Centrifugal 2 Group A Q2E11P001B (AHA)

Q2E13P001A Containment Spray (CS) Centrifugal 2 Group B Q2E13P001B Q2E21P002A Charging/High Head Safety Centrifugal 2 Group A Q2E21P002B Injection (HHSI)

Q2E21P002C Q2E21P005A Boric Acid Transfer (BAT) Centrifugal 3 Group A Q2E21P005B Q2N23P001A Motor Driven AFW Centrifugal 3 Group A Q2N23P001B Q2N23P002 Turbine Driven AFW Centrifugal 3 Group B Q2P16P001A Service Water Vertical Line 3 Group A Q2P16P001B Shaft Centrifugal Q2P16P001C Q2P16P001D Q2P16P001E Q2P17P001A Component Cooling Water Centrifugal 3 Group A Q2P17P001B Q2P17P001C E1- 5

Joseph M. Farley Nuclear Plant Unit 1 and 2 Submittal of the lnservice Testing Program Alternatives for the Fifth Ten-Year Interval Enclosure 2 Proposed Alternative RR-PR-03, Version 1.0 to NL-17-0082 Proposed Alternative RR-PR-03, Version 1.0 PLANT/UNIT: Farley Nuclear Plant, Units 1 and 2 INTERVAL: 5th Interval beginning December 1, 2017, and ending November 30, 2027 COMPONENTS Refer to Table RR-PR-03, Applicable Pumps AFFECTED:

CODE EDITION ASME OM Code-2004 Edition with Addenda through OMb-2006 AND ADDENDA:

REQUIREMENTS: ISTB-351 O(a), Accuracy, states, "Instrument accuracy shall be within the limits of Table ISTB-3510-1."

Table ISTB-3510-1, Required Instrument Accuracy, requires pressure instrument accuracy for Comprehensive and Preservice Test pressure instrument accuracy to be +/-0.5%.

REASON FOR In accordance with 10 CFR 50.55a, "Codes and standards," paragraph REQUEST: (z)(1 ), an alternative is proposed to the accuracy requirement of ASME OM Code ISTB, Table ISTB-351 0-1. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety.

Table ISTB-3510-1 specifies the pressure instrument accuracy to +/-0.5%

during the comprehensive pump test. Due to the design of the Service Water (SW) pumps (vertical line shaft), the suction pressure is determined using the SW wet pit level (WPL) and pump elevation. The WPL is recorded by reading the gauge on a concrete column in the wet pit. This gauge does not meet the accuracy requirements of Table ISTB-351 0-1 for determining pressure.

PROPOSED The SW pumps draw suction from the Service Water Intake Structure ALTERNATIVE (SWIS) wet pit. The WPL determines the suction pressure when AND BASIS: determining the pump differential pressure for inservice testing of the SW pumps. Pump inservice testing is performed by setting the pump differential pressure to within a fixed "band" based on WPL and discharge pressure. This results in a differential pressure within a 2% band around a reference differential pressure (~Pr) value of 82.37 psig as shown in Table 1 below. The flow rate is then measured and compared to OM Code acceptance ranges.

E2- 1 to NL-17-0082 Proposed Alternative RR-PR-03, Version 1.0 PROPOSED Table 1, Pump Differential Pressure ALTERNATIVE AND BASIS: Discharge Pressure (PD)

(continued)

Wet Pit Level (WPL) 78.00 81.00 L\P L\P/L\Pr L\P L\P/L\Pr 185.0 81.08 0.98 84.08 1.02 185.5 80.86 0.98 83.86 1.02 Instrument Accuracy/Precision:

A WPL gauge located on the wet pit concrete column is used to determine the SW pump suction pressure. The WPL gauge is a 5 foot gauge that is divided into increments of 0.2 foot. The best possible reading of this gauge is to the 0.1 foot markings due to location and system conditions. Therefore, the best accuracy for the suction pressure reading is 2% (0.1 ft/5.0 ft) which does not meet the accuracy requirement of Table ISTB-351 0-1 for the comprehensive pump test.

The test procedures include an acceptance criterion that requires the WPL remain in a "band" between 185.0 and 185.5 feet (6 inch range).

For an acceptable test, the variance in the WPL can be no more than the difference between the upper and lower acceptance criteria limits. By restricting the WPL range, the suction pressure for each SW pump test is essentially a constant value. A constant WPL reference of 185.25 feet can be assigned by the test procedure resulting in the maximum level difference of 0.25 feet, which equates to a maximum pressure difference of 0.109 pounds per square inch (psi) [(0.25 ft)/(2.31 ft per psi)].

The maximum difference in suction pressure equates to only 0.14% of the minimum reference value for the pump differential pressure [(0.1 09 psi I 80.86 psi)]. The precision of the suction pressure reading based on the WPL results in an acceptable method for setting the reference value for pump differential pressure.

FNP proposes to perform SW pump Group A and comprehensive pump testing using the installed WPL gauge to confirm the near constant suction pressure for the SW pumps. All other measurements for SW pump testing will comply with OM Code requirements.

Using the provisions of this request, as an alternative to the specific requirements of ISTB Table 3510-1 identified above, will provide an acceptable level of quality and safety for testing the pumps listed in Table RR-PR-03. Therefore, pursuant to 10 CFR 50.55a(z)(1), FNP requests approval of this proposed alternative to these specific ISTB requirements.

E2 -2 to NL-17-0082 Proposed Alternative RR-PR-03, Version 1.0 DURATION: 51h 1ST Interval, beginning December 1, 2017, and ending November 30, 2027 PRECEDENT: Edwin I. Hatch Nuclear Plant, Units 1 and 2, lnservice Testing Program Relief Request [RR-11] and Alternatives for Pumps and Valves- Fifth Ten-Year Interval, dated December 30, 2015 (ML15310A406)

E2- 3 to NL-17-0082 Proposed Alternative RR-PR-03, Version 1.0 Table RR-PR-03, Applicable Pumps Pumps (Units 1 & 2) Description Pump Type Code OM Code Class Category 01P16P001A-A Service Water Vertical Line Shaft 3 Group A 01 P16P001 B-A Pumps Centrifugal 01 P16P001 C-AB 01 P16P001 D-B 01 P16P001 F-B Q2P16P001A-A 02P16P001 B-A 02P16P001 C-AB 02P16P001 D-B 02P16P001 E-B E2- 4

Joseph M. Farley Nuclear Plant Unit 1 and 2 Submittal of the lnservice Testing Program Alternatives for the Fifth Ten-Year Interval Enclosure 3 Proposed Alternative RR-VR-01, Version 1.0 to NL-17-0082 Proposed Alternative RR-VR-01, Version 1.0 PLANT/UNIT: Farley Nuclear Plant (FNP), Units 1 and 2 INTERVAL: 5th Interval beginning December 1, 2017, and ending November 30, 2027 COMPONENTS Pumps and Valves contained within the lnservice Testing Program AFFECTED: scope CODE EDITION ASME OM Code-2004 Edition with Addenda through OMb-2006 AND ADDENDA:

REQUIREMENTS: This request applies to the following test frequency requirements of the ASME OM Code.

ISTA-3120(a), lnservice Test Interval, states, "The frequency for inservice testing shall be in accordance with the requirements of Section 1ST."

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

Table ISTB-3400-1, lnservice Test Frequency, notes that Group A and Group B pump tests are to be conducted quarterly and comprehensive pump tests are to be conducted biennially.

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, in part, that "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, Leakage Rate for Other Than Containment Isolation Valves, (a) Frequency, states, "Tests shall be conducted at least once every 2 years."

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."

ISTC-5221, Valve Obturator Movement, (c)(3) 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."

Mandatory Appendix I, lnservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants, 1-1320, Test Frequencies, Class 1 Pressure Relief Valves, (a) 5-Year Test Interval, states, in part, that "Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power E3 -1 to NL-17-0082 Proposed Alternative RR-VR-01, Version 1.0 REQUIREMENTS: generation."

(Continued)

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, states, Tests shall be performed in accordance with 1-1320, Test Frequencies, Class 1 Pressure Relief Valves."

Appendix I, 1-1350, Test Frequency, Classes 2 and 3 Pressure Relief Valves, (a) 1OYear Test Interval, states, in part, that "Classes 2 and 3 pressure relief valves, with the exception of PWR main steam safety valves, shall be tested every 10 years, starting with initial electric power generation."

Appendix I, 1-1360, Test Frequency, Classes 2 and 3 Nonreclosing Pressure Relief Devices, states, in part, that "Classes 2 and 3 nonreclosing pressure relief devices shall be replaced every 5 years ... "

Appendix I, 1-1370, Test Frequency, Classes 2 and 3 Primary Containment Vacuum Relief Valves, (a) states, in part, that "Tests shall be performed on all Classes 2 and 3 containment vacuum relief valves at each refueling outage or every 2 years, whichever is sooner ... "

Appendix I, 1-1380, Test Frequency, Classes 2 and 3 Vacuum Relief Valves, Except for Primary Containment Vacuum Relief Valves, states, in part, that "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 10 years, unless performance data indicate more frequent testing is necessary. In lieu of tests the Owner may replace the relief devices at a frequency of every 10 years, unless performance data indicate more frequent replacements are necessary."

Mandatory Appendix II, Check Valve Condition Monitoring Program, 11-4000, Condition Monitoring Activities, (a) Performance Improvement Activities, (1) states, in part, that "If sufficient information is not currently available to complete the analysis required in 11-3000, or if this analysis is inconclusive, then 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, to determine the cause of the failure or the maintenance patterns."

E3 -2 to NL-17-0082 Proposed Alternative RR-VR-01, Version 1.0 REQUIREMENTS: Appendix II, ll-4000(b), Optimization of Condition-Monitoring (Continued) Activities, (1 )(e) states, in part, that "Interval extensions shall be limited to one fuel cycle per extension. Intervals shall not exceed the maximum intervals shown in Table 11-4000-1."

REASON FOR Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph REQUEST: (z)(2), an alternative is requested from the frequency specifications of the ASME OM Code. The basis of the request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

The ASME OM Code Section 1ST 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 (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 Specifications (TS) Surveillance Requirements (SRs).

The TS typically allow 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 (SR 3.0.2).

However, regulatory issues have been raised concerning the applicability of the TS "Grace Period" to ASME OM Code-required 1ST frequencies irrespective of allowances provided under TS Administrative Controls (i.e., TS 5.5.8, "lnservice Testing Program,"

invokes SR 3.0.2 for various OM Code frequencies). FNP submitted TSTF-545 on July 28,2016 (NL-16-0091) that removed the specified frequencies from TS 5.5.8 and defaulted control of the frequencies to the lnservice Testing Program.

The lack of a tolerance band on the ASME OM Code 1ST frequency restricts operational flexibility. There may be a conflict where a surveillance test could be required but where it is not possible or not desired that it be performed until sometime after a certain restricted plant condition is cleared. Therefore, to avoid this conflict, the surveillance test should be performed as soon as it is practicable. The NRC recognized this potential issue in the TS by allowing a 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 the ASME OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. Interval 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 E3- 3 to NL-17-0082 Proposed Alternative RR-VR-01, Version 1.0 REASON FOR maintenance activities). Such extensions are not intended to be REQUEST used repeatedly merely as an operational convenience to extend (Continued): test intervals beyond those specified.

PROPOSED ASME OM Code establishes component test frequencies that are ALTERNATIVE based either on elapsed time periods (e.g., quarterly, 2 years, etc.)

AND BASIS: 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 undergo lnservice Testing at frequencies as specified in the Farley TS (TS 5.5.8) and shown in the following table:

Frequency Specified Time Period Between Tests Quarterly At least once per 92 days Semiannually At least once per 184 days Yearly or At least once per 366 days Annually x years X calendar years where 'x' is a whole number of years <:: 2 b) 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).

c) Components whose test frequencies are based on the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenance, etc.) may not have their period between tests extended except as allowed by the ASME OM Code.

d) Period extensions may not be applied to the test frequency requirements specified in 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.

E3- 4

Enclosure 3 to NL-17-0082 Proposed Alternative RR-VR-01, Version 1.0 PROPOSED e) Period extensions of 25% may also be applied to ALTERNATIVE accelerated test frequencies (e.g., pumps in Alert Range)

AND BASIS and other less than 2-year test frequencies not specified in (Continued): the table above.

This alternative is requested citing the above guidance found in ASME-approved Code Case OMN-20 for determining acceptable tolerances for pump and valve test frequencies. The ASME OM Code Standards Committee approved this Code Case in February 2012. Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code, 2012 Edition.

Based on the determination that compliance with the Code requirement results in a hardship without a compensating increase in the level of quality and safety, this proposed alternative is requested pursuant to 10 CFR 50.55a(z)(2).

DURATION: 5th Interval beginning December 1, 2017, and ending November 30, 2027 PRECEDENCE: 1. Quad Cities Nuclear Power Station, Units 1 and 2, Safety Evaluation in Support of Request for Relief Associated with the Fifth 10-Year Interval 1ST Program [RR RV-01], dated February 14, 2013 (ML13042A348)

2. Callaway Plant, Unit 1, Requests for Relief [RR PR-04],

Alternatives to ASME OM Code Requirements for 1ST for the Fourth Program Interval- Safety Evaluation dated July 15, 2014 (ML14178A769)

3. Calvert Cliffs Nuclear Power, Units 1 and 2, Relief Request IST-RR-01 Re: Frequency of 1ST Requirements of Pumps and Valves - Safety Evaluation dated September 24, 2014 (ML14247A555)
4. Three Mile Island, Unit 1 Relief Request VR-02 Associated with Fifth 10-Year 1ST Interval- Safety Evaluation dated August 15, 2013 (ML13227A024)
5. Dresden Nuclear Power Station, Units 2 and 3, Safety Evaluation in Support of Request for Reliefs [RR RV-01]

Associated with the Fifth 10-Year Interval 1ST Program, dated October 31,2013 (ML13297A515)

E3- 5 to NL-17-0082 Proposed Alternative RR-VR-01, Version

1.0 REFERENCES

1. NRC Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests
2. ASME OM Code Case OMN-20, lnservice Test Frequency
3. Federal Register Vol. 80, No. 181, Proposed 10 CFR 50.55a Rulemaking, dated September 18, 2015 (Pages 56839-56840)
4. Farley Nuclear Plant Technical Specifications E3- 6
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