ML14337A449

Relief Request Nos. RV-03, RV-02, RV-01, RP-06, RP-05, RP-04, RP-03, PV-04, RP-02, RP-01, RG-01, for the Fourth 10-Year Inservice Testing Interval (TAC MF3847-MF3849, MF3851-MF3858)

ML14337A449
Person / Time
Site:	Columbia
Issue date:	12/09/2014
From:	Eric Oesterle Plant Licensing Branch IV
To:	Reddemann M Energy Northwest
George A
References
TAC MF3847, TAC MF3848, TAC MF3849, TAC MF3851, TAC MF3852, TAC MF3853, TAC MF3854, TAC MF3855, TAC MF3856, TAC MF3857, TAC MF3858
Download: ML14337A449 (46)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 9, 2014 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION- REQUESTS FOR RELIEF NOS. RG01, RP01, RP02, RP03, RP04, RP05, RP06, RV01, RV02, RV03, AND RV04 FOR THE FOURTH 10-YEAR INSERVICE TESTING INTERVAL (TAC NOS. MF3847, MF3848, MF3849, MF3851, MF3852, MF3853, MF3854, MF3855, MF3856, MF3857, AND MF3858)

Dear Mr. Reddemann:

By letter dated April 2, 2014, as supplemented by letters dated July 21, October 13, and October 23, 2014, Energy Northwest (the licensee) submitted requests for relief, RG01, RP01 through RP06, and RV01 through RV04, from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the fourth 10-year inservice testing (1ST) program interval at Columbia Generating Station (CGS). The fourth 10-year 1ST program interval at CGS begins on December 13, 2014, and concludes on December 12, 2024.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed relief requests RP02, Revision 1, RP03, Revision 1, and RV01, and concludes, as set forth in the enclosed safety evaluation, that Energy Northwest has adequately addressed all of the regulatory requirements in paragraph 50.55a(f)(6)(i) of Title 10 of the Code of Federal Regulations (1 0 CFR), and that granting relief is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed upon the facility.

The NRC staff has reviewed the proposed alternatives in RP01, RP04, RP06, RV02, RV03, and RV04, and concludes, as set forth in the enclosed safety evaluation, that Energy Northwest has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(a)(3)(i), and that the proposed alternatives provide an acceptable level of quality and safety.

The NRC staff has reviewed the proposed alternatives in RG01 and RP05, and concludes, as set forth in the following safety evaluation, that Energy Northwest has provided reasonable assurance that the affected components are operationally ready and that complying with the specified ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(a)(3)(ii).

M. Reddemann All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

If you have any questions regarding this matter, Andrea George of my staff may be reached at (301) 415-1081 or via e-mail at andrea.george@nrc.gov.

Sincerely, Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOURTH 10-YEAR INSERVICE TESTING PROGRAM INTERVAL REQUEST FOR RELIEF NOS. RG01, RP01, RP02. RP03, RP04. RP05, RP06.

RV01. RV02. RV03, AND RV04 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397

1.0 INTRODUCTION

By letter dated April 2, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14101A365), as supplemented by letters dated July 21, October 13, and October 23, 2014 (ADAMS Accession Nos. ML14212A397, ML14296A385, and ML14310A665, respectively), Energy Northwest (the licensee), submitted requests RG01, RP01, RP02, RP03, RP04, RP05, RP06, RV01, RV02, RV03, and RV04, to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives to certain inservice testing (1ST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the 1ST program at Columbia Generating Station (CGS) for the fourth 10-year 1ST program interval, which begins on December 13, 2014, and is scheduled to end on December 12, 2024.

Specifically, pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (1 0 CFR), the licensee requested to use the proposed alternatives in RP01, RP04, RP06, RV02, RV03, and RV04 on the basis that the alternatives provide an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee requested to use the proposed alternatives in RG01 and RP05 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality and safety. Pursuant to 10 CFR 50.55a(f)(6)(i), the licensee requested to use the proposed alternatives in RP02, RP03, and RV01 on the basis that the ASME OM Code requirement is impractical.

2.0 REGULATORY EVALUATION

The regulations at 10 CFR 50.55a require that 1ST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (1 0-year) 1ST program intervals in accordance with the specified ASME Code incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In Enclosure

accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month 1ST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv), 1ST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b),

subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.

In proposing alternatives from 1ST requirements, the licensee must demonstrate in accordance with 10 CFR 50.55a(a)(3) "that: (i) The proposed alternatives would provide an acceptable level of quality and safety; or (ii) Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety."

In requesting relief from 1ST requirements, the licensee must demonstrate in accordance with 10 CFR 50.55a(f)(5)(iii) "that conformance with certain code requirements is impractical for its facility .... " Pursuant to 10 CFR 50.55a(f)(6)(i), the Commission is authorized to approve alternatives and to grant relief from ASME Code requirements upon making necessary findings.

The licensee stated that the CGS's fourth 10-year 1ST program interval is scheduled to commence on December 13, 2014, and to conclude on December 12, 2024. The licensee also stated that the fourth 10-year 1ST program at CGS will comply with the requirements of ASME OM Code 2004 Edition through 2006 Addenda, as required by 10 CFR 50.55a(f)(4).

The NRC staff previously approved similar relief requests to RP01, RP02, RP03, RP04, RP05, RV01, RV02, RV03, and RV04 for CGS for the third 10-year 1ST interval, as documented in NRC letters dated March 23 and May 15, 2007 (ADAMS Accession Nos. ML070600111 and ML071010344, respectively).

For each request for relief below, the licensee stated that the applicable ASME Code Edition and Addenda is the 2004 Edition and the 2005 and 2006 Addenda.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Alternative Request RG01 3.1.1 ASME Code Components Affected (as stated by the licensee)

All Pumps and Valves contained within the lnservice Testing Program scope.

3.1.2 Applicable Code Requirements (as stated by the licensee)

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.

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

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

ISTC-3510 Exercising Test Frequency. Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222. Power-operated relief valves shall be exercise tested once per fuel cycle.

ISTC-3540 Manual Valves. 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. Any increased testing frequency shall be specified by the Owner. The valve shall exhibit the required change of obturator position.

ISTC-3630 (a) Leakage Rate for Other Than Containment Isolation Valves. Frequency. Tests shall be conducted at least once every 2 years .

. ISTC-3700 Position Verification Testing. 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 (c)(3) Valve Obturator Movement. 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.

ISTC-5260 Explosively Actuated Valves. (b) Concurrent with the first test and at least once every 2 years, the service life records of each valve shall be reviewed to verify that the service life of the charges have not been exceeded and will not be exceeded before the next refueling. (c) At least 20% of the charges in explosively actuated valves shall be fired and replaced at least once every 2 years.

Appendix I, l-1320(a) Test Frequencies. Class 1 Pressure Relief Valves.

5-Year Test Interval. Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24 month interval.

Appendix I, 1-1330 Test Frequency. Class 1 Nonreclosing Pressure Relief Devices. Class 1 nonreclosing pressure relief devices shall be replaced every 5 years unless historical data indicates a requirement for more frequent replacement.

Appendix I, 1-1340 Test Frequency. Class 1 Pressure Relief Valves that are used for Thermal Relief Application. Tests shall be performed in accordance with 1-1320, Test Frequencies, Class 1 Pressure Relief Valves.

Appendix I, l-1350(a) Test Frequency. Class 2 and 3 Pressure Relief Valves. 10-Year Test Interval, Classes 2 and 3 pressure relief valves, with the exception of PWR

[pressurized-water reactor] main steam safety valves, shall be tested every 10 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested during any single plant operating cycle; however, a minimum of 20% of the valves from each valve group shall be tested within any 48 month interval.

Appendix I, 1-1360 Test Frequency. Class 2 and 3 Nonreclosing Pressure Relief Devices. Classes 2 and 3 nonreclosing pressure relief devices shall be replaced every 5 years, unless historical data indicates a requirement for more frequent replacement.

Appendix I, 1-1370 Test Frequency. Class 2 and 3 Primary Containment Vacuum Relief Valves. (a) 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, unless historical data requires more frequent testing. (b) Leak tests shall be performed on all Classes 2 and 3 containment vacuum relief valves at a frequency designated by the Owner in accordance with Table ISTC-3500-1.

Appendix I, 1-1380 Test Frequency. Classes 2 and 3 Vacuum Relief Valves. Except for Primary Containment Vacuum Relief Valves. All Classes 2 and 3 vacuum relief valves shall be tested every 2 yr, unless performance data suggest the need for a more appropriate test interval.

Appendix I, 1-1390 Test Frequency. Classes 2 and 3 Pressure Relief Devices That Are Used for Thermal Relief Application. 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 yr, unless performance data indicate more frequent replacements are necessary.

Appendix II, 11-4000 Performance Improvement Activities. (a)(1) 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. (e) Identify the interval of each activity.

Appendix II, 11-4000 Optimization of Condition Monitoring Activities.

(b)(1)(e) Identify the interval of each activity. Interval extensions shall be limited to one fuel cycle per extension. Intervals shall not exceed the maximum intervals shown in table 11-4000-1. All valves in a group sampling plan must be tested or examined again, before the interval can be extended again, or until the maximum interval would be exceeded. The requirements of ISTA-3120, lnservice Test Interval, do not apply.

MOV Diagnostic Tests GL 96-05 required periodic static and dynamic diagnostic test intervals. The MOV Program is required by condition [of the regulation at]

10 CFR 50.55a(b)(3)(ii).

3.1.3 Reason for Request (as stated by the licensee)

ASME OM Code Section 1ST establishes the 1ST 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 the 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 TSs 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 Technical Specification (TS) "grace period" to ASME OM Code required 1ST frequencies irrespective of allowances provided under TS Administrative Controls (i.e., TS 5.5.6, "lnservice Testing Program," invokes Surveillance Requirement (SR) 3.0.2 for various ASME OM Code frequencies).

The lack of a tolerance band on the ASME OM Code 1ST frequency restricts operational flexibility. There may be a conflict where 1ST could be required (i.e.,

its frequency could expire), but where it is not possible or not desired that it be performed until after a plant condition or associated Limiting Condition for Operation (LCO) is within its applicability. Therefore, to avoid this conflict, the 1ST should be performed when it can and should be performed.

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 the ASME 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 ASME OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling 1ST that minimizes the conflicts between the need to complete the testing and plant conditions.

3.1.4 Proposed Alternative and Basis for Use (as stated by the licensee)

Columbia Generating Station proposes to use ASME OM Code Case OMN-20 as published in ASME OM-2012 edition for the fourth ten year interval of 1ST Program. The ASME OM-2012 edition was approved by the ASME Board on Nuclear Codes and Standards on December 21, 2012. Code case OMN-20 will be used for determining acceptable tolerances for pump and valve testing

frequencies. The code case as published in ASME OM-2012 edition is repeated below.

Published OMN-20 Code Case 1 TEST FREQUENCY GRACE ASME OM, Division 1, Section 1ST and all earlier editions and addenda specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2 years, etc.) or 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 1ST with a specified time period between tests as shown in Table 1. The specified time period between tests may be reduced or extended as follows:

1) For periods specified as fewer than 2 yr, the period may be extended by up to 25% for any given test.

2) For periods specified as greater than or equal to 2 yr, the period may be extended by up to 6 mo 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 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 fewer than 2 yr test frequencies not specified in Table 1.

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.

b) Components whose test frequencies are based on the occurrence of plant conditions or events may not have their period between tests extended excepts as allowed by ASME OM, Division 1, Section 1ST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda.

Table 1 Specified Test Frequencies Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 months)

Semiannually 184 days (or every 6 months)

Annually 366 days (or every year)

X calendar years X years Where X is a whole number of years ~ 2 3.1.5 Quality/Safety Impact (as stated by the licensee)

Allowing use of the Code Case OMN-20 will provide reasonable assurance of operational readiness of pumps and valves subject to ASME OM code 2004 edition through OMb-2006 addenda testing requirements.

3.1.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.1. 7 NRC Staff Evaluation Historically, licensees have applied, and the NRC staff has accepted, the standard TS definitions for 1ST intervals, including allowable interval extensions, to ASME OM Code required testing (see Section 3.1.3 of NUREG-1482, "Guidelines for lnservice Testing at Nuclear Power Plants," Revision 2, dated October 2013, available at ADAMS Accession No. ML13295A020).

Recently, the NRC staff reconsidered the allowance of using TS testing intervals and interval extensions for 1ST not associated with TS SRs. As noted in Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests," dated August 23, 2012 (ADAMS Accession No. ML12079A393), the NRC staff concluded that programmatic test frequencies for non-TS testing cannot be extended in accordance with the TS SR 3.0.2 or 3.0.3 for those plants who have adopted Standard TS (STS) based on NUREG-1430 through NUREG-1434. This includes all 1ST described in the ASME OM Code not specifically required by the TS SRs.

Following this development, the NRC staff sponsored and co-authored an ASME OM Code inquiry and Code Case to modify the ASME OM Code to include test interval definitions and interval extension criteria similar toTS SR 3.0.2 and 3.0.3. The resultant ASME Code Case OMN-20, as shown above, was approved by the ASME Operation and Maintenance Standards Committee on February 15, 2012, with the NRC representative voting in the affirmative. ASME

Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code, 2012 Edition. The licensee proposes to adopt Code Case OMN-20 for the fourth 10-year 1ST interval at CGS.

Requiring the licensee to meet the ASME OM Code requirements, without an allowance for defined frequency and frequency extensions for 1ST of pumps and valves, results in a hardship without a compensating increase in the level of quality and safety. Based on the prior acceptance by the NRC staff of the similar TS test interval definitions and interval extension criteria, the NRC staff concludes that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable for the duration of the fourth 10-year 1ST interval at CGS. Allowing usage of ASME Code Case OMN-20 provides reasonable assurance of operational readiness of pumps and valves subject to the ASME OM Code 1ST.

3.2 Licensee's Alternative Request RP01 3.2.1 ASME Code Components Affected The licensee requested to use an alternative to the applicable ASME OM Code requirements for CGS station service water (SSW) pumps SW-P-1A and SW-P-1 B, and high pressure core spray (HPCS) pump HPCS-P-2. The pumps are classified as ASME Class 3 and ASME OM Code Group A.

3.2.2 Applicable Code Requirement (as stated by the licensee)

Measure pump differential pressure, ~P. Vertical line shaft centrifugal pumps preservice and inservice testing (ISTB-5210, ISTB-5220, and Table ISTB-3000-1).

Relief is required for Group A and comprehensive and preservice tests.

3.2.3 Reason for Request (as stated by the licensee)

There are no inlet pressure gauges installed in the inlet of these vertical line shaft centrifugal pumps, making it impractical to directly measure inlet pressure for use in determining differential pressure for the pump.

3.2.4 Proposed Alternative and Basis for Use (as stated by the licensee)

Pump discharge pressure will be recorded during the testing of these pumps.

[ASME OM] Code Acceptance Criteria will be based on discharge pressure instead of differential pressure as specified in the Code Table ISTB-5221-1. The effect of setting the [ASME OM] Code Acceptance Criteria on discharge pressure instead of differential pressure as specified in the [ASME OM] Code will have no negative impact on detecting pump degradation.

1. SW-P-1A, [SW-P-]1 B, and HPCS-P-2 are vertical line shaft centrifugal pumps which are immersed in their water source. They have no suction line which can be instrumented.

2. Technical Specification SR 3.7.1.1 specifies the minimum allowable spray pond level to assure adequate NPSH [Net Positive Suction Head] and ultimate heat sink capability.

3. The difference between allowable minimum and overflow pond level is only 21 inches of water or 0.8 pounds per square inch (psi). This small difference will not be significant to the Test Program and suction pressure will be considered constant. Administratively, the pond level is controlled within a nine (9) inch band.

4. Acceptable flow rate and discharge pressure will suffice as proof of adequate suction pressure.

5. These pumps operate with a suction lift. Maximum elevation of spray pond level is 434 feet 6 inches and minimum elevation of discharge piping for these pumps is 442 feet 5/8 inches. Thus discharge pressure for these pumps will always be lower than the calculated differential pressure for the entire range of suction pressures. Thus acceptance criteria based on discharge pressure is conservative. This is further illustrated below.

Differential pressure is defined as discharge pressure minus suction pressure. In the case of a pump with suction lift the suction pressure is negative, thus:

L1P = Pd- (- Ps)

L1P = Pd + Ps This concept is more easily understood when head is used instead of pressure.

The ASME Code uses the term differential pressure instead of total head since differential pressure is required to be measured. However, most literature on pumps deals with hydraulic parameters in terms of head and flow. In case 1:

Total Head= Discharge Head- Suction Head But in Case 2 (Service Water Pumps)

Total Head = Discharge Head + Suction Lift When one converts head to pressure, the equivalent formula for differential pressure would be:

L1P(psi) = Pd(psi) + 0.431 (psi/ft) X (Elpump(ft) - EL water level (ft))

Since pump discharge pipe elevation for these pumps is always more than spray pond water level, discharge pressure is always less than the calculated differential pressure.

3.2.5 Quality/Safety Impact (as stated by the licensee)

The effect of setting the [ASME OM] Code Acceptance Criteria on discharge pressure instead of differential pressure as specified in the Code provides a more conservative test methodology.

3.2.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.2.7 NRC Staff Evaluation The licensee requested an alternative to the ASME OM Code requirements of Table ISTB-3000-1 and Subsections ISTB-5210 and ISTB-5220 for measuring pump differential pressure during Group A preservice and comprehensive tests for SSW pumps SW-P-1A and SW-P-1 B, and HPCS pump HPCS-P-2. The licensee-proposed alternative measures and evaluates the pumps' operational readiness based on the discharge pressure of these pumps, because inlet suction pressure instrumentation is not available.

The licensee stated in the application that the difference between minimum and overflow pond level is only 21 inches of water, or 0.8 psi, which is further administratively controlled to a 9-inch band, which equates to 0.33 psi. This small variation makes the suction pressure essentially constant. Based on the information provided by the licensee in its response, dated July 21, 2014, to a request for additional information from the NRC staff dated July 2, 2014 (ADAMS Accession No. ML141838704), the SSW pumps' discharge pressure for the past year has ranged from 204.63 psig (pounds per square inch gauge) to 213.60 psig, making the 0.33 psig subtraction less than 0.2 percent of discharge pressure. The HPCS pump's discharge pressure for the past year was 60 psig, making the 0.33 subtraction less than 0.6 percent of the discharge pressure. In addition, the licensee stated that measuring discharge pressure is more conservative for these pumps because the measurement is uncorrected for elevation. In the calculation, it is assumed that the spray pond level is at a lower elevation than the discharge piping; therefore, the discharge pressure is less than the pump differential pressure simply because of the difference in the static head. Since the discharge pressure for each pump is less than the calculated differential pressure considering the entire range of suction pressures, the NRC staff concludes that the testing proposed by the licensee provides an acceptable level of quality and safety. Therefore, the NRC staff concludes that the licensee's proposed alternative to the requirements of Table ISTB-3000-1 and Subsections ISTB-521 0 and ISTB-5220 of the ASME OM Code is acceptable.

3.3 Licensee's Alternative Request RP02, Revision 1 (revised by supplement dated July 21. 2014) 3.3.1 ASME Code Components Affected The licensee requested an alternative to applicable ASME OM Code requirements for SSW pumps SW-P-1A and SW-P-1 B, and SSW, HPCS pump HPCS-P-2. The pumps are classified as ASME Class 3 and ASME OM Code Group A.

3.3.2 Applicable Code Requirement (as stated by the licensee)

Subsection ISTB-5221 (b) and ISTB-5223(b). The resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to the reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value.

Relief is required for Group A and comprehensive tests.

3.3.3 Burden Caused by Compliance (as stated by the licensee)

1. Service Water systems are designed such that the total pump flow cannot be adjusted to one finite value for the purpose of testing without adversely affecting the system flow balance and Technical Specification operability requirements. Thus, these pumps must be tested in a manner that the Service Water loop remains properly flow balanced during and after the testing and each supplied load remains fully operable to maintain the required level of plant safety.

2. The Service Water system loops are not designed with a full flow test line with a single throttle valve. Thus the flow cannot be throttled to a fixed reference value. Total pump flow rate can only be measured using the total system flow indication installed on the common return header.

Although there are valves in the common return line that are used for throttling total system flow during preservice testing, use of these valves is impractical for regular testing due to the potential effect on the flow balance for the safety related loads. Each main loop of service water supplies 17-18 safety related loads, all piped in parallel with each other.

The HPCS-P-2 pump loop supplies four loads, each in parallel. Each pump is independent from the others (i.e., no loads are common between the pumps). Each load is throttled to a calculation and surveillance required flow range which must be satisfied for the loads to be operable.

All loads are aligned in parallel, and all receive service water flow when the associated service water pump is running, regardless of whether the served component itself is in service. During power operation, all loops (subsystems) of service are required to be operable per Technical Specifications. A loop of service water cannot be taken out of service for

testing without entering an Action Statement for a Limiting Condition for Operation (LCO) per Technical Specification 3.7.1.

3. Each loop of Service Water is flow balanced annually to ensure that all loads are adequately supplied. A flow range is specified for each load.

Once properly flow balanced, very little flow adjustment can be made for any one particular load without adversely impacting the operability of the remaining loads (increasing flow for one load reduces flow for all the others). Each time the system is flow balanced, proper individual component flows are produced, but this in turn does not necessarily result in one specific value for total flow. Because each load has an acceptable flow range, overall system full flow (the sum of the individual loads) also has a range. Total system flow can conceivably be in the ranges of approximately 9,200- 10,200 gallons per minute (gpm) for SW-P-1A and SW-P-1 B pumps and approximately 1,112 - 1,203 gpm for the HPCS-P-2 pump. Consequently, the requirement to quarterly adjust service water loop flow to one specific flow value for the performance of in service testing conflicts with system design and component operability requirements (i.e., flow balance) as required by Technical Specification.

3.3.4 Proposed Alternative and Basis for Use (as stated by the licensee)

As stated in NUREG-1482, Rev 2 Section 5.2, some system designs do not allow for testing at a single reference point or a set of reference points. In such cases, it may be necessary to plot pump curves to use as the basis for variable reference points. Code Case OMN-16, "Use of a Pump Curve for Testing," is included in draft Revision 1l11 of Regulatory Guide (RG) 1.192, "Operations and Maintenance Code Case Acceptability, ASME OM Code." Flow rate and discharge pressure are measured during inservice testing and compared to an established reference curve. Discharge pressure instead of differential pressure is used to determine pump operational readiness as described in Relief Request RP01. All requirements specified in Code Case OMN-16 will be followed in developing and implementing the reference pump curves. The following information is provided for existing pump curves developed during the third ten year test interval.

1. SW-P-1A and SW-P-1 B were replaced with new pumps in 2005 and HPCS-P-2 was replaced in 2008. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs. discharge pressure) was established for all three pumps using the preservice test data.

2. Pump curves are based on five or more test points beyond the flat portion of the curve (between 6000 gpm and 10200 gpm for the SW-P-1 A and 1B 1 U.S. Nuclear Regulatory Commission, Draft Regulatory Guide DG-1232 (Proposed Revision 1 to Regulatory 1.192, dated June 2003), "Operation and Maintenance Code Case Acceptability, ASME Code," June 2013 (ADAMS Accession No. ML102600001 ).

pumps and between 650 and 1200 gpm for the HPCS-P-2 pump). The pumps are being tested near full design flow rate.

3. Temporary test gauges (+/- 0.5 percent full scale accuracy) were installed to take discharge pressure test data in addition to plant installed gauges, and the Transient Data Acquisition System (TDAS). TDAS data averages 100 readings with a reading taken each second. All instruments used either met or exceeded the ASME OM Code required accuracy for Group A and comprehensive pump test[s].

4. The reference pump curves are based on flow rate vs. discharge pressure. Acceptance criteria curves are based on differential pressure limits given in Table ISTB-5121-1 for applicable test type. Setting the ASME OM Code Acceptance Criteria on discharge pressure using differential limits is slightly more conservative for these pump installations with suction lift (Relief Request RP01 ). [Figure 2 is a) sample of the SW-P1A pump acceptance criteria sheet for the Group A test.

Area 1-2-5-6 is the acceptable range for pump performance.

Area 3-4-5-6 defines the Alert Range, and the area outside 1-2-3-4 defines the Required Action Range.

5. Similar reference curves are used for comprehensive pump tests using the applicable acceptance criteria and instrument accuracy and range requirements.

6. Only a small portion of the established reference curve is being used to bind the flow rate variance due to flow balancing of various system loads.

[Figure 2 is a) sample of the SW-P-1 A pump Acceptance Criteria sheet for [the] Group A test.

7. A single reference value shall be assigned for each vibration measurement location. The selected reference value shall be at the minimum data over the narrow range of pump curves being used as required by Code Case OMN-16.

8. When the repair, replacement, or routine servicing of a pump may have affected a reference curve, a new reference curve shall be determined, or the existing reference curve reconfirmed, in accordance with para. 16-3310 of Code Case OMN-16.

9. If it is necessary or desirable, for some reason other than that stated in para. 16-3310 of Code Case OMN-16, to extend the current pump curve or establish an additional reference curve, the new curve(s) must be determined in accordance with para. 16-3320 of Code Case OMN-16.

3.3.5 Quality/Safety Impact (as stated by the licensee)

The design of the Columbia Generating Station Service Water system and the Technical Specification requirements make it impractical to adjust system flow to a fixed reference value for inservice testing without adversely affecting the system flow balance and Technical Specification operability requirements. The proposed alternate testing using a reference pump curve for each pump provides adequate assurance and accuracy in monitoring pump condition to assess pump operational readiness and shall adequately detect pump degradation. Alternate testing will have no adverse impact on plant and public safety.

3.3.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.3.7 NRC Staff Evaluation The licensee has requested an alternative to Subsections ISTB-5221 (b) and ISTB-5223(b) of the ASME OM Code, which require establishing a fixed set of reference values for either flow or differential pressure. It is impractical to alter pump flow rates to obtain repeatable reference values for the SSW pumps SW-P-1A and SW-P-1 Band the HPCS pump HPCS-P-2, because these pumps supply cooling water to multiple safety-related loads which are located in several flow-balanced loops without throttle valves. Varying the flow rate of one of the safety loads affects the system flow balance and compliance with the TS operability requirements. Installing valves that can throttle system flow would be a burden because of the numerous design, fabrication, and installation changes that would have to be made to the piping systems. The licensee proposes to use pump curves developed and implemented following the guidance of Code Case OMN-16, instead of reference values. In NUREG-1482, Revision 2, Paragraph 5.2, the NRC staff provided guidance for utilizing pump curves when it is impractical to establish a fixed set of reference values. Based on the information provided above, the licensee has proposed a methodology consistent with the guidance of Paragraph 5.2 and also Code Case OMN-16.

Acceptance criteria and use of the reference curves will be following the guidelines of ASME OM Code Case OMN-16. The NRC staff has reviewed the OMN-16 Code Case referenced above. Although this code case has not yet been incorporated into RG 1.192, OMN-16 is a replacement for Code Case OMN-9. The Code Case OMN-9 is currently an authorized alternative, with conditions as noted in RG 1.192, for setting reference values as required by ISTB-5221 (b) and ISTB-5223(b). Additionally, OMN-16, from the 2006 Addenda of the ASME OM Code, has incorporated the NRC staffs conditions for OMN-9, as listed in RG 1.192.

Based on the information provided by the licensee and the above evaluation, the NRC staff concludes it is impractical for the licensee to comply with the specified requirement. The licensee's proposed alternative provides reasonable assurance of the operational readiness of the Columbia SSW pumps SW-P-1A and SW-P-1 B, and HPCS pump HPCS-P-2. The NRC staff further concludes that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise

in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.4 Licensee's Alternative Request RP03. Revision 1 (revised by supplement dated July 21. 2014) 3.4.1 ASME Code Components Affected The licensee requested to use an alternative to the applicable ASME OM Code requirements for the following pumps: LPCS-P-1, RHR-P-2A, RHR-P-28, RHR-P-2C, HPCS-P-1, and RCIC-P-1.

The pumps are classified as ASME Class 2 and 3 and ASME OM Code Groups A and B.

3.4.2 Applicable Code Requirement ISTB-5122, "Group 8 Test Procedure," (a), (b), and (c), state that "The pump shall be operated at (nominal motor] speed [for constant speed drives or at a speed] adjusted to the reference point (+/- 1%) for variable speed drives. The differential pressure or flow rate shall [then] be determined and compared to its reference value. System resistance may be varied as necessary to achieve the reference point."

ISTB-5123, "Comprehensive Test Procedure," (a) and (b), state that "The pump shall be operated at [nominal motor] speed (for constant speed drives or at a speed] adjusted to the reference point (+/- 1%) for variable speed drives. [For centrifugal and vertical line shaft pumps, the] resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure or flow rate shall then be determined and compared to its reference value.

Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value."

ISTB-5221, "Group A Test Procedure," (b), states that "The resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value."

ISTB-5222, "Group 8 Test Procedure," (b), and (c) state that "The differential pressure or flow rate shall be determined and compared to its reference value. System resistance may be varied as necessary to achieve the reference point."

ISTB-5223, "Comprehensive Test Procedure," (b), states that 'The resistance of the system shall be varied until the flow rate equals the reference point. The differential pressure shall then be determined and compared to its reference value. Alternatively, the flow rate shall be varied until the differential pressure equals the reference point and the flow rate determined and compared to the reference flow rate value."

3.4.3 Reason for Request (as stated by the licensee)

Reference values are defined as one or more fixed sets [or] values of quantities as measured or observed when the equipment is known to be operating

acceptably. All subsequent test results are to be compared to these reference values. Based on operating experience, flow rate (independent variable during inservice testing) for these pumps cannot be readily duplicated with the existing flow control systems. Flow control for these systems can only be accomplished through the operation of relatively large motor operated globe valves as throttling valves. Because these valves are not equipped with position indicators which reflect percent open, the operator must repeatedly jog the motor operator to try to make even minor adjustments in flow rate. These efforts, to exactly duplicate the reference value, would require excessive valve manipulation which could ultimately result in damage to valves or motor operators.

3.4.4 Proposed Alternative and Basis for Use (as stated by the licensee)

As discussed above, it is impractical to return to a specific value of flow rate, or differential pressure for testing of these pumps. As stated in NUREG-1482, Rev. 2, Section 5.2, some system designs do not allow for testing at a single reference point or a set of reference points. In such cases, it may be necessary to plot pump curves to use as the basis for variable reference points. [ASME]

OM Code Case OMN-16 is included in draft Revision 1 of RG 1.192, "Operations and Maintenance Code Case Acceptability, ASME OM Code."

Since the independent reference variable (flow rate) for these pumps is impractical to adjust to a fixed reference value and requires excessive valve manipulation, the maximum variance shall be limited to +/- 2% of the reference value. Thus, flow rate shall be adjusted to be within +/- 2% of the reference flow rate and the corresponding differential pressure shall be measured and compared to the reference differential pressure value determined from the pump reference curve established for this narrow range of flow rate. Slope of the pump reference curve is not flat even over this narrow range of flow rates. Assuming the flow rate to be fixed over this narrow range can result in additional error in calculating the deviation between the measured and reference differential pressure and at times this deviation can be non-conservative. Since the dependent variable (differential pressure) can be assumed to vary linearly with flow rate in this narrow range, establishing multiple reference points in this narrow range is similar to establishing a reference pump curve representing multiple reference points. This assumption of linearity between differential pressure and flow rate is supported by the manufacturer's pump curves in the stable design flow rate region.

The following elements are used in developing and implementing the reference pump curves. These elements follow the guidance of ASME OM Code Case OMN-16.

1. RHR-P-28 was replaced with a new pump in 2013. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs. differential pressure) was established for this pump using the preservice test data. A similar reference pump curve (flow rate vs differential pressure) has been established for RHR-P-2A and

RHR-P-2C pumps from data taken on these pumps when they were known to be operating acceptably. These pump curves represent pump performance almost identical to manufacturer's test data.

2. For RCIC-P-1, a variable speed drive pump, flow rate is set within+/- 2% of the reference flow rate and the reference curve is based on speed with acceptance criteria based on differential pressure. This is done because of the impracticality of setting speed to a specific reference value to achieve the desired flow rate and pump discharge pressure. See the sample RCIC-P-1 pump Acceptance Criteria sheet for Group 8 test [on page 20 of 40 of the application dated April 2, 2014]. Additionally, evaluation of the manufacturer pump data, preoperational and special test data used to establish the pump reference curve indicates insignificant change in differential pressure with small variation in flow rate.

3. HPCS-P-1 was replaced with a new pump in 2007. A preservice test as required by the ASME OM Code was performed and a reference pump curve (flow rate vs. differential pressure) was established for this pump using the preservice test data.

4. For the LPCS-P-1 pump, the reference pump curve is based on the manufacturer's pump curve that was validated during preoperational testing using 5 or more test points beyond the flat portion of the curve.

5. Residual Heat Removal (RHR), HPCS and Reactor Core Isolation Cooling (RCIC) pump curves are based on five or more test points beyond the flat portion of the curve. These ECCS [Emergency Core Cooling System] pumps have minimum flow rate requirements specified in Technical Specifications and are being tested near these flow rates.

6. Temporary test gauges (+/- 0.5% full scale accuracy) were installed to take suction and discharge pressure test data in addition to plant installed gauges and Transient Data Acquisition System (TDAS). TDAS data averages 100 readings with a reading taken at one second intervals. All instruments used either met or exceeded the [ASME OM] Code required accuracy for applicable Group A, Group 8 and comprehensive pump test.

7. Review of the pump hydraulic data trend plots indicates close correlation with the established pump reference curves, thus further validating the accuracy and adequacy of the pump curves to assess pumps operational readiness.

8. Acceptance criteria curves are based on differential pressure limits given in applicable Table IST8-5121-1 or Table IST8-5221-1. See the attached sample RHR-P-2A pump Acceptance Criteria sheet for [the] Group A test

[shown on page 19 of 40 of the application dated April 2, 2014]. Area 1-2-5-6 is the acceptable range for pump performance. Area 3-4-5-6 defines the Alert Range and the area outside 1-2-3-4 defines the required

Action Range. A similar sample RCIC-P-1 pump Acceptance Criteria sheet for Group 8 test [is shown on page 20 of 40 of the application dated April 2, 2014].

9. Similar reference curves will be used for comprehensive pump tests using the applicable acceptance criteria and instrument accuracy and range requirements.

10. Only a small portion of the established reference curve is being used to accommodate flow rate variance. See the attached sample pump Acceptance Criteria sheets [on pages 19 and 20 of 40 of the application dated April 2, 2014].

11. A single reference value shall be assigned for each vibration measurement location. The selected reference value shall be at the minimum data over the narrow range of pump curves being used as required by [ASME OM] Code Case OMN-16.

12. When the repair, replacement, or routine servicing of a pump may have affected a reference curve, a new reference curve shall be determined, or the existing reference curve reconfirmed, in accordance with para. 16-3310 of [ASME OM] Code Case OMN-16.

13. If it is necessary or desirable, for some reason other than that stated in paragraph 16-3310 of ASME OM Code Case OMN-16, to extend the current pump curve or establish an additional reference curve, the new curve(s) must be determined in accordance with para. 16-3320 of [ASME OM] Code Case OMN-16.

3.4.6 Quality/Safety Impact (as stated by the licensee)

Due to impracticality of adjusting independent variables (flow rate, and speed for the variable drive RCIC pump) to a fixed reference value for inservice testing without system modifications, alternate testing to vary the variables over a very narrow range (up to+/- 2% of reference values) and using pump reference curves for this narrow range is proposed. Alternate testing using a reference pump curve for each pump provides adequate assurance and accuracy in monitoring pump condition to assess pump operational readiness and will adequately detect pump degradation. Alternate testing will have no adverse impact on plant and public safety.

3.4.7 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.4.8 NRC Staff Evaluation The licensee has requested an alternative to Subsections ISTB-5122(a), (b), and (c),

ISTB-5123(a) and (b), ISTB-5221 (b), ISTB-5222(b) and (c), and ISTB-5223(b) of the ASME OM Code, which require establishing a fixed set of reference values for either flow or differential pressure.

For the pumps listed in Section 3.4.1 of this safety evaluation (SE), the licensee has stated that it is impractical to alter the pump flow rate to obtain a repeatable reference value. The flow-control valves used in these systems are large motor-operated globe valves which do not have any position indication that would facilitate achieving a repeatable reference value. Requiring the licensee to install flow-control valves with more accurate flow adjustment capability would be a burden because of the design, fabrication, and installation changes that would have to be made. In addition, efforts to duplicate reference values may require extensive manipulation and result in damage to either the valves or motor operators.

The licensee has proposed to limit the variance in the flow rate of these pumps to+/- 2 percent of the reference flow rate. This is different from the requirements of the ASME OM Code, which requires that the flow rate be within +/- 1 percent of the reference-flow rate. The licensee proposes this higher range to obtain the+/- 1 percent variance of the value. The licensee proposes to use pump curves developed and implemented following the guidance of Code Case OMN-16, instead of reference values. In NUREG-1482, Revision 2, Section 5.2, the NRC staff provided guidance for utilizing pump curves when it is impractical to establish a fixed set of reference values. Based on the information provided above, the licensee has proposed a methodology consistent with the guidance of Section 5.2 and also Code Case OMN-16.

Acceptance criteria and use of the reference curves will be following the guidelines of ASME OM Code Case OMN-16. The NRC staff has reviewed the OMN-16 Code Case referenced above. Although this code case has not yet been incorporated into RG 1.192, OMN-16 is a replacement for Code Case OMN-9. The Code Case OMN-9 is currently an authorized alternative, with conditions as noted in RG 1.192, for setting reference values as required by ISTB-5221 (b) and ISTB-5223(b). Additionally, OMN-16, from the 2006 Addenda of the ASME OM Code, has incorporated the NRC staffs conditions for OMN-9, as listed in RG 1.192.

Based on the information provided by the licensee and the above evaluation, the NRC staff concludes it is impractical for the licensee to comply with the specified requirement. The licensee's proposed alternative provides reasonable assurance of the operational readiness of the pumps listed in Section 3.4.1 of this SE. The NRC staff further concludes that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.5 Licensee's Alternative Request RP04 3.5.1 ASME Code Components Affected The licensee requested to use an alternative to the applicable ASME OM Code requirements for the following pumps: RHR-P-2A, RHR-P-2B, RHR-P-2C, and HPCS-P-1. The pumps are classified as ASME Class 2 and ASME OM Code Groups A and B.

3.5.2 Applicable Code Requirement (as stated by the licensee)

ISTB-351 0(b)(1 ). Range. The full- scale range of each analog instrument shall be not greater than three times the reference value.

3.5.3 Reason for Request In its application, the licensee stated, in part, that "installed test gauges used to measure the pump discharge pressure, which is used to determine differential pressure, do not meet the

[ASME OM] Code range requirements. Residual Heat Removal (RHR) and High Pressure Core Spray (HPCS) Pumps discharge pressure instruments (RHR-PT-37A, RHR-PT-37B, RHR-PT-37C, and HPCS-PT-4), exceed or may exceed (dependent upon measured parameters), the Code allowable range limit of three times the reference value." In its supplement dated October 13, 2014 (ADAMS Accession No. ML14296A385), the licensee stated that relief is required for Group A and Group B inservice tests only, and that temporary test gauges meeting the ASME OM Code requirements shall be used for the comprehensive and preservice tests.

3.5.4 Proposed Alternative and Basis for Use (as stated by the licensee)

During Group A or Group B pump inservice testing, pump discharge pressure, which is used to determine differential pressure, shall be measured by respective Transient Data Acquisition System (TDAS) points listed below for each pump.

TDAS data averages 100 readings with a reading taken each second.

1. ISTB-351 O(a) and ISTB-351 O(b)(1) specify both accuracy and range requirements for each instrument used in measuring pump performance parameters. The purpose of instrument requirements is to ensure that pump test measurements are sufficiently accurate and repeatable to permit evaluation of pump condition and detection of degradation.

Instrument accuracy limits the inaccuracy associated with the measured test data. Thus, higher instrument accuracy lowers the uncertainty associated with the measured data. The purpose of the [ASME OM]

Code range requirement is to ensure reading accuracy and repeatability of test data.

2. Since the TDAS data is being obtained to an accuracy of+/- 1% of full scale, it consistently yields measurements more accurate than would be provided by instruments meeting the [ASME OM] Code instrument accuracy requirement of+/- 2% of full scale and range requirement of three

times the reference value. Equivalent [ASME OM] Code accuracy being obtained by TDAS measurements is calculated in the table below.

[Table 2: Instruments Affected by Alternative Request RP04]

'Ret Instrument Test lostrument Range Value Loop Eqvivalent Code Pump Parameter 1.0. (PSIG) (PSlG) Accuracy Accuracy RHR-P-2A Di&eharge RHR-PT-37A 0-600 136 +/-1%. l61(3x136}]x100 RHR-P-2B Pressure Di&eharge

---TDAS PT 155 RHR*PT-37B 0-600 148

+/- 6 psig

t1%.

"'1.47%

161(3x148}Jx100 PllHISUre TDAS PT076 :t 6 psig "1.3!5%

RHR-P-2C Discharge RHR-PT-37C 0-600 143 +/- 1%. [61(3x143))x100 Pressure TDASPT091 :t 6 p$1g =1.40%

HPCS*P*1 Discharge HPCS-PT-4 0-1500 465 :tf%, l15/(3x465 ))x1 00 Pte$$ute TDASPT 107 :t 15 psig *1.08%

Thus, the range and accuracy of TDAS instruments being used to measure pump discharge pressure result in data measurements of higher accuracy than that required by the [ASME OM] Code and thus will provide reasonable assurance of pump operational readiness. It should also be noted that the TDAS system averages many readings, therefore giving a significantly more accurate reading than would be obtained by using the averaging technique as allowed by ISTB-351 O(d) on visual observation of a fluctuating test gauge.

3. The range of the pressure transmitters (PTs) used for these applications were selected to bound the expected pump discharge pressure range during all normal and emergency operating conditions (the maximum expected discharge pressure for the RHR and HPCS pumps is approximately 450 psig and 1400 psig respectively). However, during inservice testing the pumps are tested at full flow, resulting in lower discharge pressures than the elevated discharge pressure that can occur during some operating conditions. For this reason the pump reference value is significantly below the maximum expected operational discharge pressure. A reduction of the range of the PTs to three times the reference value would, in these cases, no longer bound the expected discharge pressure range for these pumps, and therefore is not practicable. If a PT were to fail, a like replacement would have to be used due to the above identified reasons of replacing a PT with one not suited for all pump flow conditions. However, this is not a concern because the existing instrumentation provides pump discharge pressure indication of higher accuracy and better resolution than that required by the [ASME OM] Code for evaluating pump condition and detecting degradation.

4. NUREG-1482, Revision 2 Section 5.5.1 states that when the range of a permanently installed analog instrument is greater than three times the reference value, but the accuracy of the instrument is more conservative than that required by the [ASME OM] Code, the NRC staff may grant relief when the combination of the range and accuracy yields a reading that is at least equivalent to that achieved using instruments that meet the [ASME OM] Code requirements (i.e. up to +/- 6 percent for Group A and 8 tests, and +/- 1.5 percent for pressure and differential pressure instruments for Preservice and Comprehensive tests).

3.5.5 Quality/Safety Impact (as stated by the licensee)

TDAS data will consistently provide acceptable accuracy to ensure that the pumps are performing at the flow and pressure conditions to fulfill their design function. TDAS data is sufficiently accurate for evaluating pump condition and in detecting pump degradation. The effect of granting this alternative request will have no adverse impact on plant and public safety. Test quality will be enhanced by obtaining slightly better, more repeatable data.

3.5.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.5.7 NRC Staff Evaluation The licensee has requested an alternative to the ASME OM Code instrument range requirements for the instruments listed in Table 2 which are used for Group A, Group 8 testing of the pumps listed in Section 3.5.1 of this SE. The ASME OM Code requires that the full-scale range of each instrument shall be three times the reference value or less. The licensee has proposed to use the installed instrumentation to measure pump discharge pressure.

The installed instruments are calibrated to an accuracy of+/- 1 percent of full scale. The licensee's calculations provided in Table 2 above show that the actual variance has a value which is less than the maximum variance allowed by the ASME OM Code. The installed instrumentation provides an acceptable level of quality and safety because the variance in the actual test results is more conservative than that allowed by the ASME OM Code for analog instruments.

The use of the existing instruments listed in Table 2 is supported by NUREG-1482, Revision 2, Paragraph 5.5.1, when the combination of range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the ASME OM Code requirements. For the pumps listed in Table 2, the installed instruments (pressure gauges) listed in Table 2 yield readings at least equivalent to the readings achieved from instruments that meet ASME OM Code requirements. Therefore, the NRC staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety because the installed instrumentation provides a measurement accuracy that equals the resulting measurement accuracy of+/- 6 percent for Group A and Group 8 tests if ASME OM Code requirements were met.

3.6 Licensee's Alternative Request RP05 3.6.1 ASME Code Components Affected The licensee requested to use an alternative to the applicable ASME OM Code requirements for Group B, comprehensive, and preservice testing of the pumps as stated in Table 3 below.

Table 3: Pumps Affected by Alternative Request RP05 Pump Code Class Pump Group P&ID Dwg. No. System(s)

SLC*P*1A 2 B M522 Standby Liquid Control SLC-P*1B 2 B M522 3.6.2 Applicable Code Requirement ISTB-3550, "Flow Rate," states, in part, that: "when measuring flow rate, a rate or quantity meter shall be installed in the pump test circuit. If a meter does not indicate the flow rate directly, the record shall include the method used to reduce the data."

Subsection ISTB-5300, "Positive Displacement Pumps," (a), "Duration of Tests," (1) states that "For the Group A test and the comprehensive test, after pump conditions are as stable as the system permits, each pump shall be run at least 2 min. At the end of this time at least one measurement or determination of each of the quantities required by Table ISTB-3000-1 shall be made and recorded."

Subsection ISTB-5300, "Positive Displacement Pumps," (a), "Duration of Tests," (2) states that "For the Group B test, after the pump conditions are stable, at least one measurement or determination of the quantity required by Table ISTB-3000-1 shall be made and recorded."

The licensee requested relief for Group B and comprehensive and preservice tests.

3.6.3 Reason for Request (as stated by the licensee)

A rate or quantity meter is not installed in the test circuit. To have one installed would be costly and time consuming with few compensating benefits.

As a result of a rate or quantity meter not being installed in the test circuit, it is impractical to directly measure the flow rate for the Standby Liquid Control pumps. Therefore, the requirement for allowing a 2 minute "hold" time for Pump tests is an unnecessary burden which would provide no additional assurance of determining pump operational readiness.

3.6.4 Proposed Alternative and Basis for Use (as stated by the licensee)

NUREG-1482, Revision 2 Section 5.5.2 states, "requiring licensees to install a flow meter to measure the flow rate and to guarantee the test tank size, such that the pump flow rate will stabilize in 2 minutes before recording the data would be

a burden because of the design and installation changes to be made to the existing system. Therefore, compliance with the [ASME OM] Code requirements would be a hardship."

Pump flow rate will be determined by measuring the volume of fluid pumped and dividing corresponding pump run time. The volume of fluid pumped will be determined by the difference in fluid level in the test tank at the beginning and end of the pump run (test tank fluid level corresponds to volume of fluid in the tank). The pump flow rate calculation methodology meets the accuracy requirements of [ASME OM] Code, Table ISTB-351 0-1. The pump flow rate calculation is identified on the record of test and ensures that the method for the flow rate calculation yields an acceptable means for the detection and monitoring of potential degradation of the Standby Liquid Control Pumps and therefore, satisfies the intent of the [ASME] OM Code Subsection ISTB.

In this type of testing, the requirement to maintain a 2 minute hold time after stabilization of the system is unnecessary and provides no additional increase of the ability of determining pump condition.

3.6.5 Quality/Safety Impact (as stated by the licensee)

The test tank fluid volume is approximately 236 gallons. The measured flow rate is approximately 43 gpm. The accuracy of the level reading is+/- 1/8 inch. The accuracy of volume or level change is +/-1/4 inch (1/8 inch at initial level and 1/8 inch at final level). The pump is required to be run for a minimum time to ensure that an 18 inch change of test tank level has occurred. This is to ensure that the [ASME OM] Code required accuracy for flow rate measurement of

+/-2 percent is satisfied. A 2% error over 18 inches corresponds to 0.36 inches, which is greater than 0.25 inches. The test methodology used to calculate pump flow rate will provide results consistent with [ASME OM] Code requirements.

This will provide adequate assurance of acceptable pump performance.

Calculation methods are specified in the surveillance procedures for the Standby Liquid Control Pumps, and meet the quality assurance requirements for the Columbia Generating Station.

3.6.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.6.7 NRC Staff Evaluation Section ISTB-3550 requires that when measuring flow rate, a rate or quantity meter shall be installed in the test circuit. Additionally, ISTB-5200(a) requires that for the Group A test and comprehensive test, after pump conditions are as stable as the system permits, each pump shall be run at least 2 minutes.

The licensee stated that to install a flow meter to measure the flow rate and to guarantee the test tank size, such that the pump flow rate will stabilize in 2 minutes before recording the data, would be a burden because of the design and installation changes to be made to the existing system. In the NRC staff guidance in NUREG-1482, Revision 2, Section 5.5.2, the NRC staff agreed, and noted that requiring licensees to install a flow meter to measure the flow rate and to guarantee the test tank size, such that the pump flow rate will stabilize in 2 minutes before recording the data, would be a burden because of the design and installation changes to be made to the existing system, and that compliance with the ASME OM Code requirements would be a hardship.

The licensee's proposed alternative for measuring the flow rate for these pumps is to use a test tank and determine the pump flow rate by measuring the volume of fluid pumped and dividing the volume by the corresponding pump run time. The volume of fluid pumped will be determined by the difference in fluid level in the test tank at the beginning and end of the pump run. The test methodology used to calculate pump flow rate will provide results consistent with ASME OM Code requirements and will provide adequate assurance of acceptable pump performance.

The pump flow rate calculation methodology meets the accuracy requirements of Table ISTB-351 0-1 of the ASME OM Code. The pump flow rate calculation from the surveillance test performed as part of the 1ST Program is identified on the record of the surveillance test and ensures that the method for the flow rate calculation yields an acceptable means for the detection and monitoring of potential degradation of the pumps. In this type of testing, the requirement to maintain a 2-minute hold time after stabilization of the system is unnecessary and provides no additional increase of the ability to determine pump condition. The NRC staff concludes that complying with ISTB-3550 and ISTB-5200(a) would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The testing proposed by the licensee provides reasonable assurance that the pumps listed in Table 3 are operationally ready. Therefore, the NRC staff concludes that the licensee's proposed alternative to the requirements of ISTB-3550 and ISTB-5200(a) and (b) of the ASME OM Code is acceptable.

3. 7 Licensee's Alternative Request RP06

3. 7.1 ASME Code Components Affected The licensee has requested an alternative to the comprehensive pump testing requirements of ISTB-5123(e), ISTB-5223(e), and ISTB-5323(e). The components affected by this alternative request, as stated by the licensee, are provided in Table 4 below.

[Table 4: Pumps Affected by Alternative Request RP06]

Design Basis Pump Code Class Pump Group Accident Flow Test Flow Rate {GPM) rate (GPM)

FPC*P*1A 3 A "575 595 to 605 FPC-P-18 3 A *575 595 tO 605 HPCS-P-1 2 B 6250@ 0 psid 6500 to 6690 HPC$-P-2 3 A *1022 1030 to 1180 LPCS-P-1 2 B 5625@ 122 psid 6435 to 6630 RCJC-P-1 2 B 600 610 to 628 RHR-P-2A 2 A 7034@ 0 psid 7493 to 7550 RHR*P-28 2 A 7034 @0 psid 7493 to 7550 RHR-P-2C 2 A 7034@ 0 psid 7493 to 7650 SLC-P-1A 2 B 41.2 ~ 4149 SLC-P-18 2 B 41.2 ~ 41.49 SW-P-1A 3 A *8928 9350 to 10270 SW-P*1B 3 A *8880 9350 to 10270

• These values are des1gn flow rates rather than des1gn bas1s acCident flow rates.

3.7.2 Applicable Code Requirement ISTB-5123, "Comprehensive Test Procedure," (e), refers to Table ISTB-5121-1 which requires an upper required action limit of 1.030, and 1.03!-.P,, where 0, is the reference flow rate and t-.P, is the reference differential pressure.

ISTB-5223, "Comprehensive Test Procedure," (e), refers to Table ISTB-5221-1 which requires an upper required action limit of 1.030r and 1.03!-.Pr, where Or is the reference flow rate and l-.Pr is the reference differential pressure.

ISTB-5323, "Comprehensive Test Procedure," (e), refers to Table ISTB-5321-2 which requires an upper required action limit of 1.030r and 1.03!-.Pr, where Or is the reference flow rate and l-.Pr is the reference differential pressure.

ASME OM Code Case, OMN-19, "Alternative Upper Limit for the Comprehensive Pump Test,"

states, in part, that "a multiplier of 1.06 times the reference value may be used in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in the ISTB test acceptance criteria tables.

The licensee has requested an alternative to the comprehensive pump testing requirements of ISTB-5123(e), ISTB-5223(e), and ISTB-5323(e). The components affected by this alternative request are listed in Table 4 above.

3.7.3 Reason for Request (as stated by the licensee)

For some comprehensive pump tests, Energy Northwest had difficulty in implementing the high required action range limit of 1.03% above the established hydraulic parameter reference value due to normal data scatter. Energy Northwest had to develop contingency plans in the pump operability surveillance procedures in the event the pump enters the action high range and is declared inoperable and applicable Technical Specification LCO entered for reasons other than a pump degradation issue.

Based on the similar difficulties experienced by other Owners, ASME OM Code Case OMN-19 was developed and has been published in the ASME OM-2012 edition. The white paper for this code case, Standards Committee Ballot 09-610, record 09-657, discussed the impact of instrument inaccuracies, human factors involved with setting and measuring test parameters, readability of gauges and other miscellaneous factors on the ability to meet the 1.03% acceptance criteria.

Industry operating experience is also discussed in the white paper.

Code Case OMN-19 has not been approved for use in RG 1.192, "Operational and Maintenance Code Case Acceptability, ASME OM Code."

3.7.5 Proposed Alternative and Basis for Use (as stated by the licensee)

Columbia Generating Station proposes to use the ASME OM Code Case OMN-19 as published in ASME OM-2012 edition for the fourth ten year interval of the 1ST Program. The 2012 edition of Operation and Maintenance of Nuclear Power Plants was approved by the ASME Board on Nuclear Codes and Standards on December 21, 2012. ASME OMN-19 code case allows the use of a multiplier of 1.06 times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in the applicable ISTB test acceptance criteria tables ISTB-5121-1, ISTB-5221-1 , and ISTB-5321-2.

As stated in the Standards Committee Ballot white paper, this issue was also discussed at the ASME/NRC special meeting on June 4th, 2007. The NRC questioned the basis for the upper required action limits. The inaccuracies that are the basis for the change as discussed in the white paper are summarized below.

1. Instrument inaccuracies of measured hydraulic value.

2. Instrument inaccuracies of set value and its effect on measured value.

3. Instrument inaccuracies and allowed tolerance for speed.

4. Human factors involved with setting and measuring flow, D/P

[differential pressure], and speed.

5. Readability of Gauges based on the smallest gauge increment.

6. Miscellaneous factors.

The above discussed inaccuracies associated with obtaining the comprehensive pump test hydraulic data may easily cause the measured value to exceed the existing [ASME OM Code] allowed upper required action limit of 3% percent.

The new upper limit of 6% as approved in the [ASME OM Code Case] OMN-19 will eliminate declaring the pump inoperable and entering unplanned TS LCO.

The mandatory Appendix V pump periodic verification test program has been published in ASME OM-2012 Edition. This mandatory appendix contains requirements to augment the rules of subsection ISTB for inservice testing of pumps. It also states that the Owner is not required to perform a pump periodic verification test if the design basis accident flow rate in the Owner's safety analysis is bounded by the comprehensive pump test or Group A test. As specified in the pump table above, the quarterly Group A and biennial comprehensive tests bound the verification of pump design basis flow rate and associated differential pressure or discharge pressure for positive displacement pumps.

3.7.6 Quality/Safety Impact (as stated by the licensee)

Using the upper limit of 1.06 times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in the applicable ISTB test acceptance criteria tables will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety. Each pump performance is also monitored by subsection ISTB-required quarterly applicable Group A or Group B test that verifies operational readiness of the pump. The quarterly Group A or B pump test and biennial comprehensive pump test bounds the verification of pump design basis flow rate and associated differential or discharge pressure as applicable.

3.7.7 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.7.8 NRC Staff Evaluation The ASME Committee on OM developed ASME OM Code Case OMN-19 and published it in the 2011 Addenda of the ASME OM Code. OMN-19 allows the use of a multiplier of 1.06 times the reference value in lieu of the 1.03 multiplier for the comprehensive pump test's upper "Acceptable Range" criteria and "Required Action Range, High" criteria referenced in Table ISTB-5121-1 and Table ISTB-5221-1.

ASME OM Code Case OMN-19 has not been added to Regulatory Guide 1.192, and the 2011 Addenda of the ASME OM Code has not been incorporated by reference into 10 CFR 50.55a.

The NRC staff has reviewed OMN-19, and currently has no concerns with its use, provided that a condition is met. The NRC staff has determined that licensees choosing to implement OMN-19 must implement a pump periodic verification (PPV) test program to verify that a pump can meet the required differential (or discharge) pressure as applicable, at its highest design basis accident flow rate, as discussed in Mandatory Appendix V, which was published in the 2012 Edition of the ASME OM Code.

The NRC staff notes that the licensee is not required to perform a PPV test if the design basis accident flow rate in the licensee's safety analysis is bounded by the comprehensive pump test or Group A test. The licensee stated that the design basis accident flow rate in the licensee's safety analysis is bounded by the comprehensive pump test or Group A test for the pumps listed in Table 4. The NRC staff also notes that pumps FPC-P-1A, FPC-P-1 8, HPCS-P-2, SW-P-1A, and SW-P-1 8 do not have design basis accident flow rates, so a PPV test is not required.

Since the licensee's design basis accident flow rates for the pumps are bounded, the licensee is not required to perform the PPV test to support use of ASME OM Code Case OMN-19 for the pumps listed in Table 4. Therefore, the NRC staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety to the specific ASME OM Code requirements of IST8-5123, IST8-5223, and IST8-5323.

3.8 Licensee's Alternative Request RV01 3.8.1 ASME Code Components Affected The components affected by this alternative request are provided in Table 5 below.

[Table 5: Valves Affected by Alternative Request RV01]

Valve 10 Function Cat. Class CV8-V-1A8 To break vacuum on the drywell to suppression chamber AC 2 CV8-V-1CD downcomers and to limit steam leakage from the CV8-V-1 EF downcomer to the wetwell gas space.

CVB-V-1GH CV8-V-1JK CV8-V-1 LM CV8-V-1 NP CV8-V-1QR CV8-V-1ST 3.8.2 Applicable Code Requirement (as stated by the licensee)

OM Subsection ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves.

3.8.3 Impracticality and Burden Caused by Code Requirement Compliance (as stated by the licensee)

These check valves cannot be tested individually therefore, assigning a limiting leakage rate for each valve or valve combination is not practical.

Subsection ISTC-3630 requires Category A valves, other than containment isolation valves, to be individually leak tested at least once every two years.

Each vacuum relief valve assembly consists of two independent testable check valves in series with no instrument located between them to allow testing of each of the two check valves. Therefore, leak testing in accordance with the Code is impractical. Modifications to allow individual testing of these valves would require a major system redesign and be burdensome.

3.8.4 Proposed Alternative and Basis for Use (as stated by the licensee)

These valves will be leak tested in accordance with Columbia Generating Station Technical Specifications (TS) SR 3.6.1.1.2, SR 3.6.1.1.3, and SR 3.6.1.1.4 during refueling outages.

Technical Specifications SR 3.6.1.1.2 drywell-to-suppression chamber bypass leakage test monitors the combined leakage of three types of pathways: (1) the drywell floor and downcomers, (2) piping externally connected to both the drywell and suppression chamber air space, and (3) the suppression chamber-to-drywell vacuum breakers. The test frequency is 120 months and 48 months following one test failure and 24 months if two consecutive tests fail until two consecutive tests are less than or equal to the bypass leakage limit.

Technical Specifications SR 3.6.1.1.3 establishes a leak rate test frequency of 24 months for each suppression chamber-to-drywell vacuum breaker pathway, except when the leakage test of SR 3.6.1.1.2 has been performed (Note to SR 3.6.1.1.3). Thus, each suppression chamber-to-drywall vacuum breaker pathway will have a leak test frequency of 24 months by either SR 3.6.1.1.2 or SR 3.6.1.1.3.

Technical Specifications SR 3.6.1.1.4 establishes a leakage test frequency of 24 months to determine the suppression chamber-to-drywell vacuum breaker total bypass leakage, except when the bypass leakage test of SR 3.6.1.1.2 has been performed (Note to SR 3.6.1.1.4). Thus, the determination of suppression chamber-to-drywell vacuum breaker total leakage will have a leak test frequency of 24 months by either SR 3.6.1.1.2 or SR 3.6.1.1.4.

These valves are also verified-closed by position indicators, exercised, and tested in the open direction using a torque wrench per Technical Specification SR 3.6.1.7.1, SR 3.6.1.7.2, and SR 3.6.1.7.3. In accordance with a separate commitment, the valves are visually inspected each refueling outage.

3.8.5 Quality/Safety Impact (as stated by the licensee)

The leakage criteria and corrective actions specified in the Columbia Generating Station Technical Specifications SR 3.6.1.1.2, SR 3.6.1.1.3, and SR 3.6.1.1.4 combined with visual examination of valve seats every refuel outage provides adequate assurance of the relief valve assembly's ability to remain leak tight and to prevent a suppression pool bypass. Thus, proposed alternative provides adequate assurance of material quality and public safety.

3.8.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.8.7 NRC Staff Evaluation ASME OM Code Section ISTC-3630, "Leakage Rate for Other Than Containment Isolation Valves," states, in part, that "Category A valves with a leakage requirement not based on an Owner's 10 CFR 50 Appendix J program, shall be tested to verify their seat leakages within acceptable limits." Section ISTC-3630(a), "Frequency," states that "Tests shall be conducted at least once every 2 years."

The nine components listed in Table 5 are vacuum breaker relief valves that have a requirement to be leak tight during a design basis accident. Each vacuum breaker relief valve unit consists of two independent testable check valves in series with no instrumentation located between them to allow individual leak testing. Based on the information provided by the licensee, the NRC staff concludes that leak testing in accordance with the Code is impractical and that modifications to allow individual testing of these valves would require a major system change and would be burdensome for the licensee.

The licensee has proposed to leak test each vacuum breaker relief valve unit in accordance with TS SRs 3.6.1.1.2, 3.6.1.1.3, and 3.6.1.1.4. These surveillance requirements were developed to maintain and verify the pressure suppression function of primary containment.

SR 3.6.1.1.2 requires verification that drywell-to-suppression chamber bypass leakage is s 10 percent of the acceptable A!..JK design value of 0.050 ff at an initial differential pressure of;:: 1.5 pounds per square inch differential (psid) every 120 months, and 48 months following a test with bypass leakage greater than the bypass leakage limit, and 24 months following two consecutive tests with bypass leakage greater than the bypass leakage limit until two consecutive tests are less than or equal to the bypass leakage limit. SR 3.6.1.1.2 monitors the combined leakage of three types of pathways: (1) the drywell floor and downcomers, (2) piping externally connected between the drywell and suppression chamber airspace, and (3) the suppression chamber-to-drywell vacuum breakers.

SR 3.6.1.1.3 requires verification that each individual vacuum breaker relief valve unit leakage is s; 1.2 percent of the acceptable AI..JK design value of 0.050 fe at an initial differential pressure of;:: 1.5 psid every 24 months. The SR is modified by a note stating that performance of SR 3.6.1.1.2 satisfies this surveillance requirement. The NRC staff concludes that this proposed alternative is acceptable since drywell to suppression chamber vacuum breaker relief

valve leakage is included in the measurement of the drywell to suppression chamber bypass leakage required in SR 3.6.1.1.2.

SR 3.6.1.1.4 requires verification that the total leakage of all nine vacuum breaker relief valves is :s; 3.0 percent of the acceptable AJ.../K design value of 0.050 ff at an initial differential pressure of<:: 1.5 psid every 24 months. The SR is modified by a note stating that performance of SR 3.6.1.1.2 satisfies this surveillance requirement. The NRC staff concludes that this proposed alternative is acceptable since drywell to suppression chamber vacuum breaker relief valve leakage is included in the measurement of the drywell to suppression chamber bypass leakage required in SR 3.6.1.1.2.

Based on information provided by the licensee and the evaluation above, the NRC staff concludes that the proposed alternative, comprised of performance of the TS SRs 3.6.1.1.2, 3.6.1.1.3, and 3.6.1.1.4, combined with the position indication test and visual examination performed each refueling outage, provides reasonable assurance that the components listed in Table 5 are operationally ready. The NRC staff further concludes that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.9 Licensee's Alternative Request RV02 3.9.1 ASME Code Components Affected (as stated by the licensee)

The components affected by this alternative request are provided in Table 6 below.

[Table 6: Valves Affected by Alternative Request RV02]

Valve ID Function Cat. Class PSR-V-X73-1 Containment Isolation A 2 PSR-V-X80-1 A 2 PSR-V-X83-1 A 2 PSR-V-X77A1 A 1 PSR-V-X82-1 A 2 PSR-V-X84-1 A 2 PSR-V-X77 A3 A 1 PSR-V-X82-7 A 2 PSR-V-X88-1 A 2 3.9.2 Applicable Code Requirement (as stated by the licensee)

OM Subsection ISTC-5150, Solenoid-Operated Valves, Stroke Testing 3.9.3 Reason for Request (as stated by the licensee)

Subsection ISTC-5151 (c) requires the stroke time of all solenoid-operated valves to be measured to at least the nearest second. These nine [Post Accident Sampling (PSR)] solenoid valves are the inboard Containment Isolation Valve for

nine different penetrations and are operated from a single key lock control switch.

It is impractical to measure the individual valve stroke times. To do so would require repetitive cycling of the control switch causing unnecessary wear on the valves and control switch with little compensating benefit.

3.9.4 Proposed Alternative and Basis for Use (as stated by the licensee)

All of these solenoid valves stroke in less than 2 seconds and are considered Fast-Acting valves. Their safety function is to close to provide containment isolation. The stroke time of the slowest valve will be measured by terminating the stroke time measurement when the last of the nine indicating lights becomes illuminated. If the stroke time of the slowest valve is in the acceptance range (less than or equal to 2 seconds), then the stroke times of all valves will be considered acceptable. However, if the stroke time of the slowest valve exceeds the acceptance criteria (2 seconds), all 9 valves will be declared inoperable and corrective actions in accordance with Subsection ISTC-5153 taken. After corrective actions, the required reference values shall be established in accordance with ISTC-3300. Also any abnormality or erratic action shall be recorded and an evaluation shall be made regarding need for corrective action as required by ISTC-5151 (d).

3.9.5 Quality/Safety Impact (as stated by the licensee)

The proposed alternate testing will verify that the valves respond in a timely manner and provide information for monitoring signs of material degradation.

This provides adequate assurance of material quality and public safety.

3.9.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.9.7 NRC Staff Evaluation ASME OM Code ISTC-5151 (c) requires the stroke time of all solenoid operated valves to be measured to at least the nearest second. The nine solenoid valves listed in Table 5 are all operated from a single key switch. To reduce wear and tear of the components, the licensee has proposed an alternative test method. The licensee's test plan is to operate all nine solenoid valves from the single key switch and obtain the stroke time measurement from only the slowest valve in the group. If the stroke time is within the acceptance criteria, then the stroke times of the other eight solenoid valves would be acceptable. However, if the stroke time of the slowest valve exceeds the acceptance criteria, all nine valves will be declared inoperable and corrective actions will be taken in accordance with ISTC-5153. The licensee also stated that it shall record any abnormality or erratic action and will perform an evaluation regarding the need for corrective action as required by ISTC-5151 (d).

Based on the information provided by the licensee, the NRC staff concludes that the proposed alternative to measure the slowest solenoid stroke time and apply its results to the group provides an acceptable level of quality and safety.

3.10 Licensee's Alternative Request RV03 3.1 0.1 ASME Code Components Affected (as stated by the licensee)

The components affected by this alternative request are provided in Table 7 below.

[Table 7: Valves Affected by Alternative Request RV03]

Valve ID Function Cat. Class MS-RV-1A, 8, C, D Overpressure Protection MS-RV-2A, 8, C, D c 1 MS-RV-3A, 8, C MS-RV-3D Overpressure Protection and Auto Depressurization MS-RV-4A, 8, C, D System (ADS) to lower reactor pressure sufficient to MS-RV-58, C allow initiation of Low Pressure Coolant Injection c 1 (RHR, LPCI mode) 3.1 0.2 Applicable Code Requirement (as stated by the licensee)

Mandatory Appendix I, Paragraph 1-3310, states that tests before maintenance or set-pressure adjustment, or both, shall be performed for l-3310(a), (b), (c) in sequence. The remaining shall be performed after maintenance or set-pressure adjustments:

(a) visual examination; (b) seat tightness determination, if practicable; (c) set-pressure determination; (d) determination of electrical characteristics and pressure integrity of solenoid valve(s);

(e) determination of pressure integrity and stroke capability of air actuator; (f) determination of operation and electrical characteristics of position indicators; (g) determination of operation and electrical characteristics of bellows alarm switch; (h) determination of actuating pressure of auxiliary actuating device sensing element, where applicable, and electrical continuity; and (i) determination of compliance with the Owner's seat tightness criteria.

3.1 0.3 Reason for Request (as stated by the licensee)

Relief is requested from requirements for sequence of periodic testing of Class 1 Main Steam pressure relief valves with auxiliary actuating devices.

1. Remote set pressure verification devices (SPVDs) have been permanently installed on all eighteen Main Steam Relief Valves (MSRVs) to allow set pressure testing at low power operation, typically during shutdown for refueling outage and on startup if necessary. These SPVDs

incorporate nitrogen powered metal bellows assembly that adds a quantified lifting force on the valve stem until the MSRV's popping pressure is reached. During normal power operation, these SPVDs remain de-energized and do not interfere with normal safety or relief valve functions. Removal and replacement of the MSRVs is normally performed only for valve maintenance and not for the purpose of As-Found set pressure determination. MSRVs are removed and replaced for maintenance purposes (e.g., seat leakage, refurbishment) nominally each refueling outage. The valves which are required to be as-found set pressure tested, as part of the Code required periodic testing, do not necessarily correspond to those required to be replaced for maintenance.

Actuators and solenoids are separated from the valve and remain in place when MSRVs are removed and replaced for maintenance.

As found visual examinations cannot be performed per the Code required sequence while the drywell is inerted. Visual examinations are performed after reactor shutdown but prior to valve maintenance or set-pressure adjustments.

If due to a reactor scram, MSRV periodic set pressure testing could not be performed at power during shutdown for refueling outage, it will be required to be performed during power ascension from refueling outage or by removing the valves and sending them to the vendor for as-found set pressure testing. This would require Paragraphs l-3310(a), (d), (e),

(f), and (h) tests to be performed during outage prior to Paragraphs l-3310(b), (c) and (i) tests. Paragraph l-3310(g) is not applicable to these valve designs.

2. "Valves" and "accessories" (actuators, solenoids, etc.) have different maintenance and test cycles due to the methods used for maintenance and testing at Columbia Generating Station as discussed in item 1, and should be considered separately for the purposes of meeting the required test frequency and testing requirements. Valve testing (i.e., visual examination, seat tightness, set pressure determination and compliance with Owner's seat tightness criteria, in accordance with Paragraphs l-3310(a), (b), (c) and (i)) are independent of and can be separate from testing of "accessories" (i.e., solenoids, actuator, position indicators and pressure sensing element, in accordance with Paragraphs l-3310(d), (e), (f), and (h)). Paragraph 1-3310 states that tests before maintenance or set-pressure adjustment, or both, shall be performed for l-3310(a), (b), and (c) in sequence. The remaining shall be performed after maintenance or set pressure adjustments. Valve maintenance or set pressure adjustment does not affect "accessories" testing; likewise, maintenance on "accessories" does not affect valve set pressure or seat leakage. Therefore, the MSRVs and the "accessories" may be tracked separately for the purpose of satisfying the Paragraph 1-1320 test frequency requirements.

3. Paragraph 1-331 O(f) requires determination of operation and electrical characteristics of position indicators, and Paragraph 1-331 O(h) requires determination of actuating pressure of auxiliary actuating device sensing element and electrical continuity. These tests are required to be performed at the same frequency as the valve set pressure and auxiliary actuating device testing.

The position indicators are all calibrated and functional tested during outages; the sensing elements (pressure switches) are all checked and calibrated at least once per 24 months. Although the existing tests do not have a one-to-one correlation to the valve or actuator tests, these calibrations and functional tests meet all testing requirements of this Subsection, and far exceed the required test frequency and testing requirements.

3.1 0.4 Proposed Alternative and Basis for Use (as stated by the licensee)

1. "Valves" and "accessories" (actuators, solenoids, etc.) shall be tested separately and meet Paragraph 1-1320 test frequency requirements.

Since the valve and actuator test and maintenance cycles are different, the plant positions of the actuators selected, or due, for periodic testing may not match the plant positions of the MSRVs selected, or due, for As-Found set pressure testing.

MSRV periodic set pressure testing will normally be performed at power during shutdown for refueling outage. As-found visual examination will be performed after set-pressure testing, which is out of the specified Code required sequence.

If MSRV periodic set pressure testing could not be performed at power during shutdown for refueling outage due to reactor scram it will be required to be performed during power ascension from refueling outage or by removing the valves and sending them to the vendor for as-found set pressure testing. This will require Paragraphs l-3310(a), (d) and (e) tests to be performed during outage prior to Paragraphs 1-331 O(b), (c) and (i) tests.

The actuators and solenoids will be tested at the end of the outage after other maintenance is complete, and the tests will be credited as satisfying the Code periodic test requirements provided that no actuator or solenoid maintenance (other than actuator assembly reinstallation on a replaced valve) is performed that would affect their As-Found status prior to testing or that could affect the valve's future set pressure determination.

2. All MSRV position indicators will continue to be tested in accordance with existing surveillance procedures for monthly channel checks, and for channel calibration and channel functional testing at least once per 24 months during shutdowns. These tests will be credited for satisfying the requirements of Paragraph 1-331 O(f).

3. All auxiliary actuating device sensing elements (pressure switches) will continue to be tested and calibrated on a 24 month frequency. These tests will be credited for satisfying the requirements of paragraph 1-331 O(h).

3.1 0.5 Quality/Safety Impact (as stated by the licensee)

Due to different maintenance and test cycles of valves and accessories and also due to methods used for testing and maintenance, it is impractical to meet the Code required testing requirements without subjecting the valves to unnecessary challenges and increased risk of seat degradation. The requirement for testing actuators and accessories in a specific sequence does not enhance system or component operability, or in any way improve nuclear safety. The proposed alternate testing adequately evaluates the operational readiness of these valves commensurate with their safety function. This will help reduce the number of challenges and failures of safety relief valves and still provide timely information regarding operability and degradation. This will provide adequate assurance of material quality and public safety.

3.1 0.6 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.1 0. 7 NRC Staff Evaluation Mandatory Appendix I, Paragraph 1-3310 states, in part, that "Tests before maintenance or set pressure adjustment, or both, shall be performed for l-3310(a) visual examination, l-3310(b) seat tightness determination, if practicable, and 1-331 O(c) set-pressure determination." These steps are to be performed in sequence with the exception noted in Paragraph 1-3300 which states, in part, that "When on-line testing is performed, visual examination may be performed out of sequence." The remaining requirements, l-3310(d), l-3310(e), l-3310(f), l-3310(g),

1-331 O(h), and 1-331 O(i), verify auxiliary actuating devices and compliance with the Owner's seat tightness criteria. These shall be performed after maintenance or set-pressure adjustments.

Note that requirement 1-331 O(g) does not apply.

The licensee has proposed to meet the requirements of Paragraph 1-3310 by set-pressure testing the MSRVs in the proper sequential order during a plant shutdown for a refueling outage.

Auxiliary actuating devices' electrical and operating properties will be tested and verified via existing monthly surveillance procedures and channel calibrations. Channel functional testing, sensing element calibrations, and electrical verifications will be performed on a nominal 24-month frequency during unit shutdowns. However, if MSRV testing cannot be performed at power during a plant shutdown due to a reactor scram, the licensee has proposed that

set-pressure testing would be performed during power ascension. This would cause the testing to be out of sequence. Because of this, the licensee has proposed to treat the valve testing requirements 1-3310 (a), (b), (c), and (i) separately from the accessory testing requirements 1-3310 (d), (e), {f), and (h). Valve set-pressure adjustment or maintenance does not affect the testing of accessories. Likewise, maintenance on accessories does not affect valve set-pressure or seat leakage. Therefore, the MSRVs and the accessories may be tracked separately for the purpose of satisfying the requirements of Paragraph 1-1320 "Test Frequencies, Class 1 Pressure Relief Valves." As a result, the requirements of 1-3310 would be satisfied during normal shutdown conditions or scram shutdown conditions and the operability and electrical characteristics of the MSRVs would be sufficiently determined.

Based on the information provided by the licensee and the above analysis, the NRC staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety.

3.11 Licensee's Alternative Request RV04 3.11.1 ASME Code Components Affected The components affected by this alternative request are provided in Table 8 below.

[Table 8: Valves Affected by Alternative Request RV04]

Valve ID Function Cat Class PI-EFC-X37E, PI-EFC-X37F Process Instrumentation c 1 Excess Flow Check Valves PI-EFC-X38A, PI-EFC-X38B, PI-EFC-X38C, c 1 PI-EFC-X38D PI-EFC-X38E, PI-EFC-X38F I

PI-EFC-X39A, PI-EFC-X39B, PI-EFC-X39D, c 1 PI-EFC-X39E PI-EFC-X40C, PI-EFC-X40D c 1 PI-EFC-X41 E, PI-EFC-X41 F c 2 PI-EFC-X42A, PI-EFC-X42B c 1 PI-EFC-X44AA, PI-EFC-X44AB, PI-EFC-X44AC, c 1 PI-EFC-X44AD, PI-EFC-X44AE, PI-EFC-X44AF, PI-EFC-X44AG, PI-EFC-X44AH, PI-EFC-X44AJ, PI-EFC-X44AK, PI-EFC-X44AL, PI-EFC-X44AM PI-EFC-X44BA, PI-EFC-X44BB, PI-EFC-X44BC, c 1 PI-EFC-X44BD, PI-EFC-X44BE, PI-EFC-X44BF, PI-EFC-X44BG, PI-EFC-X44BH, PI-EFC-X44BJ, PI-EFC-X44BK, PI-EFC-X44BL, PI-EFC-X44BM PI-EFC-X61A, PI-EFC-X61 B c 1 PI-EFC-X62C, PI-EFC-X62D c 1 PI-EFC-X69A, PI-EFC-X69B, PI-EFC-X69E c 1

Valve ID Function Cat Class PI-EFC-X70A, PI-EFC-X70B, PI-EFC-X70C, c 1 PI-EFC-X70D, PI-EFC-X70E, PI-EFC-X70F PI-EFC-X71A, PI-EFC-X71 B, PI-EFC-X71 C, c 1 PI-EFC-X71 D, PI-EFC-X71 E, PI-EFC-X71 F PI-EFC-X72A c 1 PI-EFC-X73A c 1 PI-EFC-X7 4A, PI-EFC-X7 48, PI-EFC-X7 4E, c 1 PI-EFC-X7 4F PI-EFC-X75A, PI-EFC-X75B, PI-EFC-X75C, c 1 PI-EFC-X75D, PI-EFC-X75E, PI-EFC-X75F PI-EFC-X78B, PI-EFC-X78C, PI-EFC-X78F c 1 PI-EFC-X79A, PI-EFC-X79B c 1 PI-EFC-X106 c 1 PI-EFC-X 107 c 1 PI-EFC-X 108 c 1 PI-EFC-X 109 c 1 PI-EFC-X110 c 1 PI-EFC-X111 c 1 PI-EFC-X112 c 1 PI-EFC-X113 c 1 PI-EFC-X114 c 1 PI-EFC-X115 c 1 3.11.2 Applicable Code Requirement OM Subsection ISTC-3522(c), "Category C Check Valves," states that "if exercising is not practicable during operation at power and cold shutdowns, it shall be performed during refueling outages."

OM Subsection ISTC-3700, "Position Verification Testing," states that "valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flowmeters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not possible, other indications shall be used for verification of valve operation."

3.11.3 Reason for Request and Quality/Safety Impact (as stated by the licensee)

ASME OM Code Subsection ISTC requires testing of active or passive valves that are required to perform a specific function in shutting down a reactor to the cold shutdown condition, in maintaining the cold shutdown condition, or in mitigating the consequences of an accident. The [Excess Flow Check Valves

(EFCVs)] are not required to perform a specific function for shutting down or maintaining the reactor in a cold shutdown condition. Additionally, the reactor instrument lines are assumed to maintain integrity for all accidents except for the Instrument Line Break Accident (ILBA) as described In Final Safety Analysis Report (FSAR) Subsection 15.6.2. The reactor instrument lines at Columbia Generating Station have a flow-restricting orifice upstream of the EFCV to limit reactor coolant leakage in the event of an instrument line rupture. Isolation of the instrument line by the EFCV is not credited for mitigating the ILBA. Thus, a failure of an EFCV is bounded by the Columbia Generating Station safety analysis. These EFCVs close to limit the flow of reactor coolant to the secondary containment in the event of an instrument line break and as such are included in the 1ST program at the Owner's discretion and are tested in accordance with the amended Technical Specification SR 3.6.1.3.8.

The GE (General Electric) Licensing Topical Report NED0-32977-A dated [June 2000 (Reference 2 of the licensee's letter dated April 2, 2014], and associated NRC safety evaluation, dated March 14, 2000 [available in ADAMS at Accession No. ML003691722], provides the basis for this relief. The report provides justification for relaxation of the testing frequency as described in the amended Technical Specification SR 3.6.1.3.8. The report demonstrates the high degree of EFCV reliability and the low consequences of an EFCV failure. Excess flow check valves have been extremely reliable throughout the industry. Based on 15 years of testing (up to year 2000) with only one (1) failure, the Columbia Generating Station revised Best Estimate Failure Rate Is 7.9E-8 per hour; less than the industry average of 1.01 E-7 per hour. There have been no failures since year 2000. Technical Specification amendment request for SR 3.6.1.3.8 was reviewed [and approved] by the NRC staff in safety evaluation (SE) dated February 20, 2001 [available in ADAMS at Accession No. ML010590279].

Failure of an EFCV, though not expected as a result of the amended [TS]

change, is bounded by the Columbia Generating Station safety analysis. Based on the GE Topical report and the analysis contained in the FSAR, the proposed alternative to the required exercise frequency and valve Indication verification frequency for EFCVs provide an acceptable level of quality and safety. In [the SE dated February 20, 2001 ], the NRC staff concluded that the increase in risk associated with the relaxation of EFCV testing is sufficiently low and acceptable.

3.11.4 Proposed Alternative and Basis for Use (as stated by the licensee)

Energy Northwest requests relief pursuant to 10 CFR 50.55a(a)(3)(i) to test reactor instrument line excess flow check valves in accordance with the amended Technical Specification SR 3.6.1.3.8. This SR requires verification every 24 months that a representative sample of reactor instrument line EFCVs actuate to the isolation position on an actual or simulated Instrument line break signal. The representative sample consists of an approximately equal number of EFCVs such that each EFCV is tested at least once every 10 years (nominal).

Valve position indication verification of the representative sample will also

be performed during valve testing. Any EFCV failure will be evaluated per the Columbia Generating Station Corrective Action Program.

3.11.5 Duration of Proposed Alternative (as stated by the licensee)

Fourth 10 year interval.

3.11.6 NRC Staff Evaluation EFCVs are installed on instrument lines to limit the release of fluid in the event of an instrument line break. Examples of EFCV installations include: reactor pressure vessel level and pressure instrumentation, main steam line flow instrumentation, recirculation pump suction pressure, and RCIC steam line flow instrumentation. EFCVs are not required to close in response to a containment isolation signal and are not required to operate under post loss-of*coolant accident (LOCA) conditions.

EFCVs are required to be tested in accordance ASME OM Code ISTC-351 0, which states, in part, that "active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months." The ASME OM Code recognizes that some valves cannot be tested at this frequency. Deferral of this requirement is allowed by ISTC-3522(c), which states, "if exercising is not practical during operation at power and cold shutdowns, it shall be performed during refueling outages." The EFCVs listed in Table 8 cannot be exercised during normal operation because closing these valves would isolate instrumentation required for power operation. These valves can only be tested during a refueling outage. The licensee has proposed an alternative to the required test interval. The proposed change revises the surveillance frequency by allowing a "representative sample" of EFCVs to be tested every refueling outage. The "representative sample" is based on approximately equal number of EFCVs being tested each refueling outage such that each valve is tested at least once every 10 years.

The licensee's justification for the relief request is based on GE Topical Report NED0-32977-A, "Excess Flow Check Valve Testing Relaxation," dated June 2000. The topical report provided:

(1) an estimate of steam release frequency (into the reactor building) due to a break in an instrument line concurrent with an EFCV failure to close, and (2) an assessment of the radiological consequences of such a release. The NRC staff reviewed the GE topical report and issued its SE on March 14, 2000. In its evaluation, the NRC staff found that the test interval could be extended up to a maximum of 10 years. In conjunction with this finding, the NRC staff noted that each licensee that adopts the relaxed test interval program for EFCVs must have a failure feedback mechanism and corrective action program (CAP) to ensure EFCV performance continues to be bounded by the topical report results. Also, each licensee is required to perform a plant specific radiological dose assessment, EFCV failure analysis, and release frequency analysis to confirm that they are bounded by the generic analyses of the topical report.

The proposed alternative described in this relief request is identical to the licensee's relief request for the third 10-year 1ST interval. The NRC staff issued an SE for this request on March 23, 2007 (ADAMS Accession No. ML070600111 ). In its SE, the NRC staff concluded that the EFCV CAP and performance evaluation criterion were in conformance with the NRC staff approved guidance and GE Topical Report NED0-32977-A. Based on the above

evaluation, and since the licensee has provided information to assure continuing conformance with the NRC staff approved guidance and GE Topical Report NED0-32977-A, the NRC staff concludes that the licensee's proposed alternative provides an acceptable level of quality and safety.

4.0 CONCLUSION

As set forth above, regarding relief requests RP02, Revision 1, RP03, Revision 1, and RV01, the NRC concludes that it is impractical for the licensee to comply with the specified requirement and that the proposed testing provides reasonable assurance that the subject components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(f)(6)(i), and that granting relief is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed upon the facility. Therefore, the NRC staff grants relief requested in RP02, Revision 1, RP03, Revision 1, and RV01 for CGS for the fourth 10-year 1ST program interval, which begins on December 13, 2014, and is scheduled to end on December 12, 2024.

As set forth above, the NRC staff concludes that the proposed alternatives in RP01, RP04, RP06, RV02, RV03, and RV04 provide an acceptable level of quality and safety. Accordingly, the NRC staff concludes that, for these items, the licensee has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(a)(3)(i). Therefore, the NRC staff authorizes proposed alternatives RP01, RP04, RP06, RV02, RV03, and RV04 for CGS for the fourth 10-year 1ST program interval, which begins on December 13, 2014, and is scheduled to end on December 12, 2024.

As set forth above, the NRC staff concludes that proposed alternatives RG01 and RP05 provide reasonable assurance that the affected components are operationally ready and that complying with the specified ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(a)(3)(ii). Therefore, the NRC staff authorizes proposed alternatives RG01 and RP05 for CGS for the fourth 10-year 1ST program interval, which begins on December 13, 2014, and is scheduled to end on December 12, 2024.

All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

Principal Contributors: M. Farnam, NRR R. Wolfgang, NRR J. Carneal, NRR J. Billerbeck, NRR Date: December 9, 2014

ML14337A449 *via email dated OFFICE NRR/DORL/LPL4-1/PM NRR/DORL/LPL4-1/PM NRRIDORL/LPL4-1/LA NRR/DE/EPNB/BC NRRIDORLILPL4-1/BC(A)

NAME MWatford A George* JBurkhardt* DAlley* EOesterle DATE 12/5/14 12/4/14 12/4/14 10/14/14 12/9/14