View source for LIC-14-0040, CFR 50.55a Request Number RR-13, Omaha Public Power District Request for Relief from Certain In-service Testing (IST) Requirements

{{Adams
| number = ML14136A466
| issue date = 05/16/2014
| title = CFR 50.55a Request Number RR-13, Omaha Public Power District Request for Relief from Certain In-service Testing (IST) Requirements
| author name = Cortopassi L
| author affiliation = Omaha Public Power District
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000285
| license number = DPR-040
| contact person = 
| case reference number = LIC-14-0040
| document type = Letter type:LIC
| page count = 6
}}

=Text=
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jjjjjjjj Omaha Public Power District 444 South 1flh Street Mall Omaha, NE 68102-2247 10 CFR 50.55a 1I C-14-0040 May 16, 2014 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No.1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

==Subject:==
10 CFR 50.55a Request Number RR-13, Omaha Public Power District (OPPD)
Request for Relief from Certain In-service Testing (1ST) Requirements

==Reference:==
: 1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk) "License Amendment Request (LAR) 14-01, One-Time Extension of Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3," dated February 10, 2014, ADAMS Accession No. ML14041A408, (lIC-14-0011)
Pursuant to 10 CFR 50.55a(a)(3)(ii), OPPD requests NRC approval of the attached relief request, which is being submitted in support of License Amendment Request (LAR) 14-01 (Reference 1),
"One-Time Extension of Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3."
LAR 14-01 proposes a one-time extension of the surveillance frequency for the pressurizer safety valves from a refueling frequency (i.e., 18 months +25%) to a maximum of 28 months.
Subsequent to the submittal of LAR 14-01, it was determined that relief from American SOCiety of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda is also required for the pressurizer safety valves. The pressurizer safety va lves (Le., RC-141 and RC-142) were tested on January 14, 2013 and January 15,2013 respectively. Appendix I, Section 1-1330(a) of the ASME OM Code requires a minimum of 20% of the valves from each valve group to be tested within any 24 month interval. However, RC-141 and RC-142, which are part of the same valve group are tested during refueling outages as they cannot be tested during power operations. Relief is requested because the next refueling outage is scheduled to begin on April 13, 2015, which exceeds the interval permitted by Appendix I, Section 1-1330(a) of the ASME OM Code.
Further review was conducted to determine the extent of this condition . That review determined that two (2) additional valves will also need relief from ASME OM Code requirements.
Accordingly, 10 CFR 50.55a Request RR-13 is attached.
Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LlC-14-0040 Page 2 There are no regulatory commitments contained in this submittal.
If you should you have questions, please contact Mr. Bill Hansher at (402) 533-6894.
Respectfully, Louis P. Cortopassi Site Vice President and CND LPC/BM/mle

==Attachment:==
10 CFR 50.55a Request Number RR-13 c:     M. L. Dapas, NRC Regional Administrator, Region IV J. W. Sebrosky, NRC Senior Project Manager J. C. Kirkland, NRC Senior Resident Inspector

LlC-14-0040 Attachment Page 1 10 CFR SO.SSa Request Number RR-13 Relief Requested In Accordance with 10 CFR SO.SSa(a)(3)(i)
Alternate Provides Acceptable Level of Quality and Safety
: 1. ASME Code Component(s) Affected Valve No.              Description               Class    Number of   Current Test valves in   Due Date group RC-141                Pressurizer RC-4 Relief   1        2           01/14/2015 Valve RC-142                Pressurizer RC-4 Relief   1        2           01/15/2015 Valve NG-HCV-4388-S2        CCW Inlet Valve HCV       3        6           03/06/2015 4388 Nitrogen Accumulator Supply Low Pressure Relief SI-217                Safety Injection Tank     2        4           03/11/2015 SI-68 Relief Valve

===2. Applicable Code Edition and Addenda===
Fort Calhoun Station (FCS) is currently in the fourth 10-year Inservice Inspection (lSI) interval, which as noted in Reference 1, ends in June 2016. The code of record for the fourth 10-year lSI interval is American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), 1998 Edition through 2000 Addenda (Reference 2).

===3. Applicable Code Requirement===
ASME OM Code, Appendix I, "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants":
A. RC-141 and RC-142:
Section 1-1330 Test Frequencies, Class 1 Pressure Relief Valves
: 8. NG-HCV-4388-S2 and SI-217:
Section 1-1360 Test Frequency, Class 2 and 3 Pressure Relief Valves

===4. Reason for Request===
Pursuant to 10 CFR 50.55a(a)(3)(ii), Omaha Public Power District (OPPD), the licensee for Fort Calhoun Station (FCS) Unit 1, requests relief from the current scheduling requirements of ASME OM Code, Appendix I Sections 1-1330 and 1-1360. The basis of

LlC-14-0040 Attachment Page 2 the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.
A. RC-141 and RC-142 Fort Calhoun Station, Unit No.1 has two installed pressurizer safety valves. Technical Specification (TS) 3.2, Table 3-5, Item 3, requires that the pressurizer safety valves be tested to "Verify each pressurizer safety valve is OPERABLE in accordance with the Inservice Testing Program. Following testing, lift settings shall be 2485 psig +/-1% and 2530 psig +/-1% respectively." The table specifies a frequency of "R" designating a "Refueling" interval.
The FCS Inservice Testing Program is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1998 Edition, through 2000 Addenda. Appendix I of the ASME OM Code specifies frequency requirements for testing of pressure relief valves. Requirements applicable to the Fort Calhoun Station pressurizer safety valves appear in Section I 1330, Test Frequencies, Class 1 Pressure Relief Valves. This section specifies that the test interval for any individual valve shall not exceed 5-years. In addition, it indicates that at least 20% of the valves from each valve group shall be tested within any 24-month interval. Testing requirements may be satisfied by installing pre-tested valves if certain additional requirements are met regarding testing of the removed valves.
Both FCS pressurizer safety valves were removed from service in April 2011 at the end of the last operating cycle (Le., Operating Cycle 26). At that time, both valves were tested and found to open within the lift settings specified in TS 2.1.6( 1) (Le.,
2485 psig +1%/-3% and 2530 psig +1%/-3% respectively). In January 2013, in anticipation of plant restart in 2013, the two pressurizer safety valves that had been removed and tested in April 2011 were re-tested. The as-left lift settings for these two valves were demonstrated by testing at a vendor facility on January 14, 2013, and January 15, 2013 respectively. The lift settings of both valves were within a tolerance of +/-1% of setpoint, as discussed in the TS 2.1.6 Basis. These valves were subsequently installed and are now in service.
The proposed one-time frequency change would allow performance of the next valve tests during the next scheduled refueling outage that is scheduled to begin April 13, 2015. Technical Specification 2.1.6(1) requires two pressurizer safety valves to be operable in Modes 1 and 2. The valves were required to be operable beginning in December 2013, when the plant was first returned to Mode 2 after the extended plant shutdown. The period during which the valves are required to be operable will be less than 18 months (Le., from December 2013 to April 2015). Therefore, the period of required operability will be no longer than a typical operating cycle. Also, the time interval between tests with the proposed frequency change remains well within the maximum 5-year test interval for any individual valve as specified by the ASME Code and Inservice Testing Program.

LlC-14-0040 Attachment Page 3 As the valves are sent offsite to a vendor facility, the setpoints were last set in January 2013 with the expectation of startup from the refueling outage in the spring of 2013; therefore, the need for this relief was not expected.
B. NG-HCV-438B-S2 and SI-217 The ASME OM Code indicates that applicable Class 2 and 3 pressure relief valves shall be tested at least once every 10 years, and that 20% of the valves from each applicable valve group shall be tested within any 48 month interval. The test intervals for NG-HCV-438B-S2 and SI-217 have not yet expired, but will expire before the next planned refueling outage (planned for April 2015).
All four valves require a plant shutdown to perform relief valve testing. Additionally, Fort Calhoun does not have the facilities required to perform set-point tests on large relief and safety valves (RC-141 and RC-142). These valves are unbolted from their mounting flanges, decontaminated, and shipped to an off-site test facility. Because of the lengthy period required for removal, transportation, testing, and re-installation, this would represent a significant hardship.
: 5. Proposed Alternative and Basis for Use The proposed alternative is to perform testing of the four valves during the next refueling outage which is scheduled to start in April 2015. This is the next opportunity to perform the required testing.
: 6. Duration of Proposed Alternative The proposed alternative will be utilized until the next refueling outage scheduled for April 2015.
: 7. Precedent Generic relief has not been specifically granted to the requirements of the ASME testing interval requirements. Code Case OMN-20, Inservice Test Frequency, (Reference 3, pending approval) concluded that 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 (Le., there is no minimum period requirement).
: 8. References
: 1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Revised In-service Inspection (lSI) and In-service Test (1ST) Interval End Dates as a Result of Extended Refueling Outage," dated January 21, 2014 (ML14022A258) (LlC-14-0002)

LlC-14-0040 Attachment Page 4
: 2. ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), 1998 Edition through 2000 Addenda
: 3. Code Case OMN-20, Inservice Test Frequency}}