ML061030258

R. E. Ginna, RAI, Relief Request PR-3 for Use of Later Code Edition

ML061030258
Person / Time
Site:	Ginna
Issue date:	04/13/2006
From:	Milano P Plant Licensing Branch III-2
To:	Korsnick M Ginna
tsw1
References
TAC MD0316
Download: ML061030258 (6)

Text

April 13,2006Mrs. Mary G. KorsnickVice President R.E. Ginna Nuclear Power Plant R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, REQUEST FOR ADDITIONALINFORMATION RE: RELIEF REQUEST PR-3 FOR USE OF LATER CODE EDITION (TAC NO. MD0316)

Dear Mrs. Korsnick:

On March 7, 2006, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), requested approval,pursuant to Section 50.55a(f)(4)(iv) of Part 50 of Title 10 of the Code of Federal Regulations

,from the Nuclear Regulatory Commission (NRC) to use a later edition of the American Societyof Mechanical Engineers Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code). Specifically, Ginna LLC requested to use all related requirements of Subsections ISTA, "General requirements," and ISTB, "In-service Testing of Pumps in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2001 Edition through 2003 Addenda, for the auxiliary feedwater and standby auxiliary feedwater pumps.During its review of the information provided in support of the application, the NRC staff hasdetermined that additional information is needed to complete its review. Enclosed is the NRC staff's request for additional information (RAI). This RAI was discussed with your staff on April 13, 2006, and it was agreed that your response would be provided within 30 days from the date of this letter.If you have any questions, please contact me at (301) 415-1457.Sincerely,/RA/Patrick D. Milano, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-244

Enclosure:

Request for Additional Informationcc w/encl: See next page

ML061030258OFFICELPL1-1/PMLPL1-1/LADCI/CPTB/BCLPL1-1/BCNAMEPMilano:tsw1SLittleSLeeRLauferDATE04/13/0604/13/0604/13/0604/13/06 DISTRIBUTION

PUBLIC LPL1-1 Reading File R. LauferRidsNrrDorlLpla S. LeeRidsNrrDciCptb P. MilanoRidsNrrPMPMilano S. LittleRidsNrrLASLittle R. McNalley OGCRidsOgcRp ACRSRidsAcrsAcnwMailCenter B. McDermott, R-IRidsRgn1MailCenterB. Singal, DORL DPR R.E. Ginna Nuclear Power Plant cc:

Mr. Michael J. WallacePresident R.E. Ginna Nuclear Power Plant, LLC c/o Constellation Energy 750 East Pratt Street Baltimore, MD 21202Mr. John M. HeffleySenior Vice President and Chief Nuclear Officer Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 500 Annapolis, MD 21401Kenneth Kolaczyk, Sr. Resident InspectorR.E. Ginna Nuclear Power Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, NY 14519Regional Administrator, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406Mr. Peter R. Smith, PresidentNew York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399Mr. Carey W. Fleming, EsquireSenior Counsel - Nuclear Generation Constellation Generation Group, LLC 750 East Pratt Street, 17th Floor Baltimore, MD 21202Mr. Charles Donaldson, EsquireAssistant Attorney General New York Department of Law 120 Broadway New York, NY 10271Ms. Thelma Wideman, DirectorWayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489Ms. Mary Louise MeisenzahlAdministrator, Monroe County Office of Emergency Preparedness 1190 Scottsville Road, Suite 200Rochester, NY 14624Mr. Paul EddyNew York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 EnclosureREQUEST FOR ADDITIONAL INFORMATIONREGARDING INSERVICE TESTING OF AUXILIARY FEEDWATER PUMPSR.E. GINNA NUCLEAR POWER PLANTDOCKET NO. 50-244By letter dated March 7, 2006 (Agencywide Documents Access and Management SystemAccession No. ML060740421), R.E. Ginna Nuclear Power Plant, LLC (the licensee) requested approval to use a later code edition and addenda of the American Society of Mechanical Engineers Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code), inaccordance with Section 50.55a(f)(4)(iv) of Part 50 of Title 10 of the Code of FederalRegulations. Specifically, the licensee requested the use of the 2001 Edition through the 2003Addenda, of the ASME OM Code for the auxiliary feedwater (AFW) pumps and the standbyAFW (SAFW) pumps. In order to complete its review of the proposed Relief Request (RR) No.

PR-3, the Nuclear Regulatory Commission (NRC) staff requests the following additionalinformation:1. The description of alternate testing in RR No. PR-3 states that the licensee will performquarterly pump discharge pressure, differential pressure and vibration measurement for the two Group A AFW pumps and a differential pressure measurement for the two Group B SAFW pumps.Will rotational speed measurement also be performed on the two Group A and twoGroup B SAFW pumps, as required by Table ISTB-3000-1 of the ASME OM Code? If pump rotational speed will not be measured, provide a technical basis.2. NRC Generic Letter (GL) 89-04, Supplement 1, indicates that licensees should considervendor records of degradation at other facilities (operating experience) when evaluatingalternative testing. GL 89-04 also identifies the absence of flow instrumentation in the minimum flow lines as a potential generic deficiency. In addition, Template 1 from the Nuclear Energy Institute (NEI) White Paper (included in NRC Report NUREG-1482,Revision 1, "Guidelines for Inservice Testing Programs at Nuclear Power Plants")

suggests that precedents, which have similar situations, and NRC approval be identified. As specified in the introduction section of ASME OM Code, code cases may be issued for alternatives when the need is urgent. In the interest of obtaining a complete review by the Code Committee and improving regulatory efficiency, the use of code inquiries, including code cases, is the preferred method to address generic alternatives from the Code.In Relief Request No. PR-3, the licensee did not address industry-wide operatingexperience, plant-specific past precedence, or ASME Code inquiries for this type of alternative to the Code.Identify if there are any industry-wide operating experiences, plant-specific precedents,or ASME OM Code inquiries for alternatives to Code requirements that are similar to this type of relief request. If such experience, precedents and inquiries exist, evaluate their applicability to this relief request, and describe any compensatory actions that will beperformed in lieu of the Code requirements.3. In its letter dated March 7, 2006, the licensee identifies that the relief request is beingsubmitted in accordance with 10 CFR 50.55a(f)(4)(iv). This regulation applies to use of later Code Editions and Addenda rather than an impracticality. The licensee identifies that the basis for the relief request is that the Code is impractical and that costly majorhardware modifications would be required. As identified in the NEI White Paper, Template 4 is appropriate where the IST Code is impractical and the licensee requests relief under 10 CFR 50.55a(f)(5)(iii). Template 4 identifies that information concerningthe impracticality and burden be included in the relief request.Clarify the basis for this relief request, and/or reconsider the appropriate regulation.