NRC-19-0017, Submittal of the Snubber Program Relief Request RR-S1 for the Fourth 10-Year Interval

Submittal of the Snubber Program Relief Request RR-S1 for the Fourth 10-Year Interval

ML19059A254
Person / Time
Site:	Fermi
Issue date:	02/28/2019
From:	Fessler P DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-19-0017
Download: ML19059A254 (5)

Text

Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: paul.fessler@dteenergy.com February 28, 2019 10 CFR 50.55a NRC-19-0017 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Submittal of the Snubber Program Relief Request RR-S1 for the Fourth 10-Year Interval Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), DTE Electric Company (DTE) hereby requests NRC approval of the following relief request for the fourth Snubber Inservice Testing (IST) 10-year interval, which begins on May 2, 2019.

ASME has approved Code Case OMN-13, Revision 2, Performance-Based Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants. This Code Case is unconditionally approved for use in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 2. Fermi 2s Code of Record for the fourth interval is the ASME OM-2012 Edition. However, Code Case OMN-13, Revision 2, states in the Applicability section that it is applicable to ASME OM Code 1995 Edition through 2011 Addenda. Fermi 2 will be implementing the ASME Code OM-2012 Edition and proposes to also implement Code Case OMN-13, Revision 2, for extending the examination interval for snubbers.

Fermi 2 has used Code Case OMN-13, Revision 0, during the previous Inservice Inspection (ISI) 10-year interval and proposes to continue with Revision 2 of this Code Case for the subsequent Snubber IST 10-year interval. Based on the required update of the ISI program and 10 CFR 50.55a(b)(3)(v), OM Condition: Snubbers ISTD, item (B), requirements for snubbers are moving from Section XI to the OM Code and hence this Code Case OMN-13 request is associated with the next Snubber IST 10-year interval.

USNRC NRC-19-0017 Page 2 DTE requests NRC approval of this relief request by February 28, 2020 to support planned testing for the fourth Snubber IST 10-year interval during the next refueling outage scheduled in the spring of 2020.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

Sincerely, Paul Fessler Senior Vice President and CNO

Enclosure:

Relief Request RR-S1 for the Fourth 10-Year Interval cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure to NRC-19-0017 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Relief Request RR-S1 for the Fourth 10-Year Interval

Enclosure to NRC-19-0017 Page 1 10 CFR 50.55a Relief Request RR-S1 Code Case OMN-13 for Snubbers Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected All snubbers within the scope of the Fermi 2 Snubber Program.

2. Applicable Code Edition and Addenda

American Society of Mechanical Engineers (ASME) code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition, no Addenda.

3. Applicable Code Requirement

ISTA-3130, Application of Code Cases, subparagraph (b) states, Code Cases shall be applicable to the edition and addenda specified in the test plan.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), an alternative is proposed to the ISTA-3130(b) requirement for implementation of Code Case OMN-13, Performance-Based Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants, Revision 2. The basis for the request is that the proposed alternative would provide an acceptable level of quality and safety.

ISTA-3130(b) states, Code Cases shall be applicable to the edition and addenda specified in the test plan. ASME has approved Code Case OMN-13, Revision 2 (Ref. 8.1). This Code Case is unconditionally approved for use in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 2 (Ref. 8.2). Fermi 2s Code of Record for the fourth interval is the ASME OM-2012 Edition. However, Code Case OMN-13, Revision 2, states in the Applicability section that it is applicable to ASME OM Code 1995 Edition through 2011 Addenda. Fermi 2 will be implementing the ASME Code OM-2012 Edition and proposes to also implement Code Case OMN-13, Revision 2, for extending the examination interval for snubbers. Fermi 2 has used Code Case OMN-13, Revision 0, during the previous Inservice Inspection (ISI) 10-year interval and proposes to continue with Revision 2 of this Code Case for the subsequent Snubber Inservice Testing (IST) 10-year interval. Based on the required update of the ISI program and 10 CFR 50.55a(b)(3)(v), OM Condition: Snubbers ISTD, item (B), requirements for snubbers are moving from Section XI to the OM Code and hence this Code Case OMN-13 request is associated with the next Snubber IST 10-year interval.

Enclosure to NRC-19-0017 Page 2 10 CFR 50.55a Relief Request RR-S1 Code Case OMN-13 for Snubbers

5. Proposed Alternative and Basis for Use The proposed alternative to ISTA-3130(b) is requested to implement this Code Case since the Code Case Applicability statement covers only the 1995 Edition through the 2011 Addenda and ISTA-3130(b) requires applicability to the edition specified in the test plan, which will be the ASME OM-2012 Edition. A review of the 2012 Edition of the OM Code and Code Case OMN-13, Revision 2, confirmed that there are no changes in the applicable Code sections referenced within the Code Case when comparing the 2011 Addenda to the 2012 Edition. Regulatory Guide 1.192, Revision 2, Table 1, Acceptable OM Code Cases, lists Code Case OMN-13, Revision 2 (2012 Edition) as acceptable to the NRC for application in a licensee's IST program without conditions. Using the provisions of this request as an alternative to the requirements of ISTA-3130(b) will provide adequate detection of observable snubber degradation and, along with the testing and service life monitoring requirements of Subsection ISTD, will continue to provide reasonable assurance of the operational readiness of Fermi 2 snubbers. Therefore, the proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(z)(1).

6. Duration of Proposed Alternative The proposed alternative, upon approval, shall be utilized during the entire fourth Snubber IST 10-year interval which begins May 2, 2019 and is scheduled to end December 31, 2029 by using the provisions of ISTA-3120(d) to extend the interval to include the planned refueling outage in fall of 2029.

7. Precedent A similar relief request for snubber examinations was approved by the NRC for Nine Mile Point on December 10, 2018 (ML18318A422).

8. References

1. Code Case OMN-13, Performance-Based Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants, Revision 2.

2. RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 2, dated March 2017; published January 2018 (ML16321A337).