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| | number = ML14111A241 | | | number = ML14111A241 |
| | issue date = 04/23/2014 | | | issue date = 04/23/2014 |
| | title = Surry Power Station, Unit Nos. 1 and 2 - Relief from the Requirements of the ASME Code (TAC Nos. MF1809 and MF1810) | | | title = Relief from the Requirements of the ASME Code |
| | author name = Pascarelli R J | | | author name = Pascarelli R |
| | author affiliation = NRC/NRR/DORL/LPLII-1 | | | author affiliation = NRC/NRR/DORL/LPLII-1 |
| | addressee name = Heacock D A | | | addressee name = Heacock D |
| | addressee affiliation = Virginia Electric & Power Co (VEPCO) | | | addressee affiliation = Virginia Electric & Power Co (VEPCO) |
| | docket = 05000280, 05000281 | | | docket = 05000280, 05000281 |
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| | page count = 8 | | | page count = 8 |
| | project = TAC:MF1809, TAC:MF1810 | | | project = TAC:MF1809, TAC:MF1810 |
| | stage = Other | | | stage = Approval |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Blvd. Glenn Allen, VA 23060 April 23, 2014 SUBJECT: SURRY POWER STATION, UNITS 1 AND 2-RELIEF FROM THE REQUIREMENTS OF THE ASME CODE {TAC NOS. MF1809 AND MF1810) . Dear Mr. Heacock: By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13128A 1 04), Virginia Electric and Power Company (Dominion), the licensee, submitted alternative request G-1 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative G-1 is associated with 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 fifth 1 0-year interval 1ST program at Surry, Power Station, Units 1 and 2 (SPS1 and SPS2). Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use ASME OM Code Case OMN-20 alternative on the basis that the ASME OM Code requirements present an undue hardship without compensating increase in the level of quality or safety. The NRC staff reviewed alternative request G-1 and concludes, as set forth in the enclosed safety evaluation, that Dominion adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes alternative request G-1, use of ASME OM Code Case OMN-20, at SPS1 and SPS2 for the fifth 1 0-year 1ST intervals which are both scheduled to begin on May 10, 2014 and end on May 9, 2024 . | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 23, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Blvd. |
| D. Heacock -2-If you have any questions, please contact the Project Manager, Martha Barillas at 301-415-2760 or via e-mail at martha.barillas@nrc.gov. Docket Nos: 50-280 and 50-281 Enclosure: Safety Evaluation cc w/encl: Distribution via ListServ Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. G-1 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FIFTH 10-YEAR INTERVAL VIRGINIA ELECTRIC AND POWER COMPANY 1.0 INTRODUCTION SURRY POWER STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-280 AND 50-281 By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13128A 1 04), Virginia Electric and Power Company (Dominion), the licensee, submitted alternative request G-1 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative G-1 is associated with 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 fifth 1 0-year interval 1ST program at $urry Power Station, Units 1 and 2 (SPS1 and SPS2). Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use ASME OM Code Case OMN-20 alternative on the basis that the ASME OM Code requirements present an undue hardship without compensating increase in the level of quality or safety. 2.0 REGULATORY EVALUATION 10 CFR 50.55a(f), "lnservice Testing Requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda. 10 CFR 50.55a(a)(3), states, in part, that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. * | | Glenn Allen, VA 23060 |
| -2 -The SPS1 and SPS2 fifth 10-year 1ST intervals are both scheduled to begin on May 10, 2014, and end on May 9, 2024. The SPS1 and SPS2 1ST programs will comply with the ASME OM Code, 2004 Edition through 2006 Addenda. Based on the above, the NRC staff finds that it has the regulatory authority to authorize the use of ASME Code Case OMN-20, as requested by Dominion. 3.0 TECHNICAL EVALUATION 3.1 Dominion's Alternative Request G-1 Dominion's alternative request applies to the test frequency specifications of the ASME OM Code. The following frequencies for tests given in the ASME OM Code do not include a tolerance band: Appendix 1, 1-1370 Appendix I, 1-1380 Appendix I, 1-1390 Appendix II, Appendix II, 11-4000 Reason for Request Test Frequencies-Class 2 and 3 Primary Containment Vacuum Relief Valves Test Frequencies-Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Test Frequencies-Class 2 and 3 Pressure Relief Valves that are used for Thermal Relief A ication Performance Improvement Activities Interval Optimization of Condition Monitoring Activities Interval ASME OM Code, Section 1ST, establishes the inservice test frequency for all components within the scope of the ASME OM Code. The frequencies (e.g., quarterly) have always been
| | |
| -3 -interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG-1482, Revision 2) anq owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specification (TS) Surveillance Requirements (SRs). The TSs typically allow for a less than or equal to 25 percent extension of the, surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance. However, regulatory issues have been raised concerning the applicability of the TS grace period to ASME OM Code-required 1ST frequencies. The licensee states the lack of a tolerance band on the ASME OM Code 1ST frequencies restricts operational flexibility. There may be a conflict where 1ST could be required (i.e., the frequency could expire), but where it is not possible or desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation is within its applicability. The NRC *recognized this potential issue in the TSs by allowing a frequency tolerance as described in SPS1 and SPS2 TS 4.0.2. 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. The licensee states 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 ISTs that minimize the conflicts between the need to complete the testing and plant conditions. Proposed Alternative The licensee proposes to adopt ASME OM Code Case OMN-20, lnservice Test Frequency, which was published in conjunction with ASME OM Code, 2012 Edition. The purpose of this code case is to prescribe a methodology for determining acceptable tolerances for pump and valve test frequencies. This proposed alternative will be utilized for the SPS1 and SPS2 fifth 1 0-year 1ST intervals. This alternative will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the 1ST Program scope. The requirements of the ASME Code Case OMN-20 are described below. 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 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 less than 2 years, the period may be extended by up to 25 percent for any given test. 2) For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test. 3) All periods .specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement). 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
| | ==SUBJECT:== |
| -4 -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 less than 2-year 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 except as allowed by ASME OM, Division 1, Section 1ST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code. Table 1 Specified Test Frequencies Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 mo) Semiannually 184 days (or every 6 mo) Annually 366 days (or every year) x years x calendar years where xis a whole number of 2 3.2 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. (Reference NUREG-1482 Revision 1, Section 3.1.3). 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," the NRC determined that programmatic test frequencies can't be extended in accordance with the TS SR 3.0.2. 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 TS-Iike test interval definitions and interval extension criteria. The resultant ASME Code Case OMN-20, as shown above, was approved by the ASME Operation al')d 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 ASME Code Case OMN-20.
| | SURRY POWER STATION, UNITS 1 AND 2- RELIEF FROM THE REQUIREMENTS OF THE ASME CODE {TAC NOS. MF1809 AND MF1810) |
| -5 -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 finds that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. 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. 4.0 CONCLUSION As set forth above, the NRC staff determines that for alternative request G-1, the proposed alternative ASME OM Code Case OMN-20, provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes alternative request G-1 at SPS1 and SPS2 for the fifth 1 0-year 1ST intervals which are both *scheduled to begin on May 10, 2014 and end on May 9, 2024. All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable. Principle Contributor: John Billerbeck, NRR Date: April 23, 2014 D. Heacock -2 -If you have any questions, please contact the Project Manager, Martha Barillas at 301-415-2760 or via e-mail at martha.barillas@nrc.gov. Docket Nos: 50-280 and 50-281 Enclosure: Safety Evaluation Sincerely, /RAJ Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing* Office of Nuclear Reactor Regulation cc w/encl: Distribution via ListServ DISTRIBUTION: PUBLIC LPL2-1 R/F RidsNrrDoriDpr Resource RidsNrrDorllp12-1 Resource RidsEPNB Resource RidsAcrsAcnw_MaiiCTR Resource RidsNrrSFigueroa Resource RidsNrrPMSurry Resource NRR_DE_EPNB_Distribution RidsRgn2MaiiCenter Resource ADAMS Accession No ML14111A241 OFFICE NRR/DORULPL2-1/PM NAME MBarillas DATE 04/21/14 *via email NRR/DORL/LPL2-1/LA NRR/DE/EPNB N R R/DO R LIL P L2-1 /BC SFigueroa Tlupold* RPascarelli 04/23/14 12/20/13 04/23/14 OFFICIAL RECORD COPY
| | |
| }} | | ==Dear Mr. Heacock:== |
| | |
| | By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), Virginia Electric and Power Company (Dominion), the licensee, submitted alternative request G-1 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative G-1 is associated with 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 fifth 10-year interval 1ST program at Surry, Power Station, Units 1 and 2 (SPS1 and SPS2). |
| | Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use ASME OM Code Case OMN-20 alternative on the basis that the ASME OM Code requirements present an undue hardship without compensating increase in the level of quality or safety. |
| | The NRC staff reviewed alternative request G-1 and concludes, as set forth in the enclosed safety evaluation, that Dominion adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements. |
| | Therefore, the NRC staff authorizes alternative request G-1, use of ASME OM Code Case OMN-20, at SPS1 and SPS2 for the fifth 10-year 1ST intervals which are both scheduled to begin on May 10, 2014 and end on May 9, 2024 . |
| | |
| | D. Heacock If you have any questions, please contact the Project Manager, Martha Barillas at 301-415-2760 or via e-mail at martha.barillas@nrc.gov. |
| | Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos: 50-280 and 50-281 |
| | |
| | ==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 RELIEF REQUEST NO. G-1 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FIFTH 10-YEAR INTERVAL VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-280 AND 50-281 |
| | |
| | ==1.0 INTRODUCTION== |
| | |
| | By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), Virginia Electric and Power Company (Dominion), the licensee, submitted alternative request G-1 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative G-1 is associated with 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 fifth 10-year interval 1ST program at |
| | $urry Power Station, Units 1 and 2 (SPS1 and SPS2). |
| | Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use ASME OM Code Case OMN-20 alternative on the basis that the ASME OM Code requirements present an undue hardship without compensating increase in the level of quality or safety. |
| | |
| | ==2.0 REGULATORY EVALUATION== |
| | |
| | 10 CFR 50.55a(f), "lnservice Testing Requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda. |
| | 10 CFR 50.55a(a)(3), states, in part, that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. |
| | * The SPS1 and SPS2 fifth 10-year 1ST intervals are both scheduled to begin on May 10, 2014, and end on May 9, 2024. The SPS1 and SPS2 1ST programs will comply with the ASME OM Code, 2004 Edition through 2006 Addenda. |
| | Based on the above, the NRC staff finds that it has the regulatory authority to authorize the use of ASME Code Case OMN-20, as requested by Dominion. |
| | |
| | ==3.0 TECHNICAL EVALUATION== |
| | |
| | 3.1 Dominion's Alternative Request G-1 Dominion's alternative request applies to the test frequency specifications of the ASME OM Code. The following frequencies for tests given in the ASME OM Code do not include a tolerance band: |
| | Test Frequencies- Class 2 and 3 Primary Containment Vacuum Relief Appendix 1, 1-1370 Valves Test Frequencies- Class 2 and 3 Vacuum Relief Valves Except for Primary Appendix I, 1-1380 Containment Vacuum Relief Valves Test Frequencies- Class 2 and 3 Pressure Relief Valves that are used for Appendix I, 1-1390 Thermal Relief A ication Appendix II, Performance Improvement Activities Interval Appendix II, Optimization of Condition Monitoring Activities Interval 11-4000 |
| | |
| | ===Reason for Request=== |
| | ASME OM Code, Section 1ST, establishes the inservice test frequency for all components within the scope of the ASME OM Code. The frequencies (e.g., quarterly) have always been |
| | |
| | interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG-1482, Revision 2) anq owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specification (TS) Surveillance Requirements (SRs). |
| | The TSs typically allow for a less than or equal to 25 percent extension of the, surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance. However, regulatory issues have been raised concerning the applicability of the TS grace period to ASME OM Code-required 1ST frequencies. |
| | The licensee states the lack of a tolerance band on the ASME OM Code 1ST frequencies restricts operational flexibility. There may be a conflict where 1ST could be required (i.e., the frequency could expire), but where it is not possible or desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation is within its applicability. |
| | The NRC *recognized this potential issue in the TSs by allowing a frequency tolerance as described in SPS1 and SPS2 TS 4.0.2. 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. |
| | The licensee states 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 ISTs that minimize the conflicts between the need to complete the testing and plant conditions. |
| | Proposed Alternative The licensee proposes to adopt ASME OM Code Case OMN-20, lnservice Test Frequency, which was published in conjunction with ASME OM Code, 2012 Edition. The purpose of this code case is to prescribe a methodology for determining acceptable tolerances for pump and valve test frequencies. This proposed alternative will be utilized for the SPS1 and SPS2 fifth 10-year 1ST intervals. This alternative will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the 1ST Program scope. The requirements of the ASME Code Case OMN-20 are described below. |
| | 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 ar~ 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 less than 2 years, the period may be extended by up to 25 percent for any given test. |
| | : 2) For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test. |
| | : 3) All periods .specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement). |
| | 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 less than 2-year 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 except as allowed by ASME OM, Division 1, Section 1ST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code. |
| | Table 1 Specified Test Frequencies Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 mo) |
| | Semiannually 184 days (or every 6 mo) |
| | Annually 366 days (or every year) x years x calendar years where xis a whole number of years~ 2 3.2 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. (Reference NUREG-1482 Revision 1, Section 3.1.3). 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," the NRC determined that programmatic test frequencies can't be extended in accordance with the TS SR 3.0.2. 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 TS-Iike test interval definitions and interval extension criteria. The resultant ASME Code Case OMN-20, as shown above, was approved by the ASME Operation al')d 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 ASME Code Case OMN-20. |
| | |
| | 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 finds that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. 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. |
| | |
| | ==4.0 CONCLUSION== |
| | |
| | As set forth above, the NRC staff determines that for alternative request G-1, the proposed alternative ASME OM Code Case OMN-20, provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), |
| | and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes alternative request G-1 at SPS1 and SPS2 for the fifth 10-year 1ST intervals which are both *scheduled to begin on May 10, 2014 and end on May 9, 2024. |
| | All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable. |
| | Principle Contributor: John Billerbeck, NRR Date: April 23, 2014 |
| | |
| | ML14111A241 *via email OFFICE NRR/DORULPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DE/EPNB NR R/DO RLIL PL2-1 /BC NAME MBarillas SFigueroa Tlupold* RPascarelli DATE 04/21/14 04/23/14 12/20/13 04/23/14}} |
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ML24141A2862024-05-22022 May 2024
Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000280/2024403 and 05000281- 2024403
ML24141A2512024-05-20020 May 2024
Proposed License Amendment Request - Reclassification of Low Head Safety Injection Flow Indication Regulatory Guide 1.97 Variable - Supplemental Information
ML24141A0482024-05-17017 May 2024
EN 56958_1 Ametek Solidstate Controls, Inc
ML24136A2302024-05-13013 May 2024
Core 1 Cycle 33 Pattern Mdr Revision 0
ML24130A2492024-05-0909 May 2024
Submittal of Information in Support of Surry Power Station Unit 1 Thermal Shield Flexure Replacement Campaign
ML24130A2032024-05-0909 May 2024
Proposed License Amendment Request Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections Supplemental Information
ML24130A1192024-05-0707 May 2024
Inservice Test Program for Pumps and Valves Sixth Interval Update and Associated Relief and Alternative Requests - Response to Request for Additional Information Regarding Alternative Request V-1
ML24142A3852024-04-30030 April 2024
2023 Annual Radioactive Effluent Release Report
IR 05000280/20240012024-04-30030 April 2024
Integrated Inspection Report 05000280-2024001 and 05000281-2024001
ML24122C6522024-04-30030 April 2024
Annual Radiological Environmental Operating Report
ML24122B3032024-04-29029 April 2024
Associated Independent Spent Fuel Storage Installation, Revision to Emergency Plan Report of Change
IR 05000280/20244022024-04-29029 April 2024
Security Baseline Inspection Report 05000280/2024402 and 05000281/2024402
ML24115A1952024-04-24024 April 2024
Notification of Surry Power Station Comprehensive Engineering Team Inspection - U.S. NRC Inspection Report 05000280/2024011 and 05000281/2024011
ML24054A0142024-04-22022 April 2024
Issuance of Amendment Nos. 297 and 280, and Surry Power Station Unit Nos. 1 and 2, Issuance of Amendment Nos. 317 and 317, to Change Emergency Plan Staff Augmentation Times
ML24108A1812024-04-15015 April 2024
Proposed License Amendment Request - Reclassification of Low Head Safety Injection Flow Indication Regulatory Guide 1.97 Variable Supplemental Information
ML24095A2172024-04-12012 April 2024
– Review of the Spring 2023 Steam Generator Tube Inspection Report
ML24088A2482024-03-26026 March 2024
Inservice Testing Program for Pumps and Valves Sixth Interval Update and Associated Relief and Alternative Requests- Response to Request for Additional Information
ML24087A2082024-03-22022 March 2024
Proposed License Amendment Request Addition of Containment Limiting Condition for Operation and Surveillance Requirements
ML24078A2642024-03-21021 March 2024
– Regulatory Audit in Support of License Amendment Request to Proposed Reclassification of Regulatory Guide 1.97 Variable for Low Head Safety Injection Flow Instrumentation
ML24087A1522024-03-18018 March 2024
Annual Changes, Tests, and Experiments Report Regulatory Commitment Evaluation Report
ML24023A5762024-03-0808 March 2024
Correction to Issuance of Amendment Nos. 315 and 315, Regarding Revised Emergency Plan for Relocation of the Technical Support Center
IR 05000280/20230062024-02-28028 February 2024
Annual Assessment Letter for Surry Power Station, Units 1 and 2 - NRC Inspection Reports 05000280/2023006 and 05000281/2023006
ML24032A4712024-02-20020 February 2024
Exemption from Select Requirements of 10 CFR Part 73 - Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting
ML24051A1782024-02-19019 February 2024
Proposed License Amendment Request - Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections
ML24057A0612024-02-19019 February 2024
and Virgil C. Summer Power Nuclear Stations - Nuclear Property Insurance Coverage
IR 05000280/20230042024-02-0909 February 2024
Integrated Inspection Report 05000280/2023004 and 05000281/2023004
IR 05000280/20244012024-02-0606 February 2024
Security Baseline Inspection Report 05000280/2024401, 05000281/2024401 and 07200002/2024401
IR 05000280/20230102024-01-18018 January 2024
– Age Related Degradation Inspection Report 05000280-2023010 and 05000281-2023010
2024-09-03
[Table view]
Category:Safety Evaluation
MONTHYEARML24219A2372024-08-23023 August 2024
Issuance of Amendment Nos. 319 and 319, Adoption of TSTF-577, Rev. 1, Revised Frequencies for Steam Generator Tube Inspection,
ML24164A0012024-08-12012 August 2024
Proposed Alternative Relief Request V-1 Inservice Testing of Pressure Isolation Valves (EPID l-2023-LLR-0060)
ML24165A1232024-07-17017 July 2024
Proposed Alternative Relief Request P-1, P-2 Inservice Testing of Residual Heat and Containment Spray Pumps (EPID l-2023-LLR-0058)
ML24165A2782024-07-17017 July 2024
Issuance of Amendment Nos. 318 and 318, Reclassification of Regulatory Guide 1.97 Variable for Low Head Safety Injection
ML24166A0622024-06-18018 June 2024
– Proposed Alternative Relief Request P-3, P-4 Inservice Testing of Boric Acid, Component Cooling Water Pumps
ML24054A0142024-04-22022 April 2024
Issuance of Amendment Nos. 297 and 280, and Surry Power Station Unit Nos. 1 and 2, Issuance of Amendment Nos. 317 and 317, to Change Emergency Plan Staff Augmentation Times
ML23312A1922024-01-18018 January 2024
Issuance of Amendment Nos. 316 & 316 Regarding a Risk Informed Approach for Tornado Classification of the Fuel Handling Trolley Support Structure
ML23283A3052023-12-20020 December 2023
Review of Appendix F to DOM-NAF2, Qualification of the Framatome ORFEO-GAIA and ORFEO-NMGRID CHF Correlations in the Dominion Energy VIPRE-D Computer Code (EPID L-2022-LLT-0003) (Nonproprietary)
ML23242A2292023-11-0707 November 2023
Issuance of Amendment Nos. 315 and 315, Regarding Emergency Procedure Relocation of the Technical Support Center
ML23200A2622023-11-0202 November 2023
Issuance of Amendment Nos. 314 and 314, Regarding Technical Specification and Spent Fuel Pool Criticality Change
ML23230A0502023-10-0202 October 2023
5 of the Quality Assurance Topical Report - Review of Program Changes
ML23244A2352023-09-18018 September 2023
Request to Use a Subsequent Edition of the ASME Code, Section XI
ML23230A0012023-09-15015 September 2023
Request to Use a Provision of a Previous Edition of the ASME Boiler and Pressure Vessel Code, Section XI, for Non-Destructive Examinations
ML23136B1392023-06-29029 June 2023
Issuance of Amendment No. 313 Administrative Changes to Subsequent Renewed Operating Licenses and Technical Specifications
ML23061A0122023-05-0909 May 2023
Issuance of Amendment Nos. 312 and 312, Regarding Technical Specifications Task Force (TSTF) Traveler 547, Revision 1
ML23072A0892023-05-0101 May 2023
(Amendments 346 & 286), North Anna 1 & 2 (Amnds 294 & 277), Surry 1 & 2 (Amnds 311 & 311), and Summer 1 (Amd 225) - Issuance of Amendments to Revise TSs to Adopt TSTF-554 Revise Reactor Coolant Leakage Requirements
ML23100A0652023-04-25025 April 2023
Issuance of Amendment Nos. 310 and 310, Regarding Turbine Building Tornado Classification
ML23102A2832023-04-25025 April 2023
ASME OM Code Inservice Testing Program Request for Approval of Alternative Request V-01 Use of Mechanical Agitation Process for Pressure Isolation Valve 1-SI-241 Seat Leakage Testing
ML23030B8472023-03-10010 March 2023
Issuance of Amendment Nos. 309 and 309, License Amendment Request Regarding a 10-Day Allowed Outage Time for Opposite Unit Auxiliary Feedwater Cross-Connect Capability
ML21320A0072022-09-0707 September 2022
Review of Appendix E to DOM-NAF-2, Qualification of the Framatome BWU-I CHF Correlation in the Dominion Energy VIPRE-D Computer Code (EPID L-2021-LLT-0000) (Non-Proprietary)
ML22193A2952022-08-26026 August 2022
Issuance of Amendment Nos. 308 and 308 License Amendment Request for Removal of the Refueling Water Chemical Addition Tank and Containment Sump, Ph Buffer Change and Safety Evaluation
ML22095A1072022-07-11011 July 2022
Issuance of Amendment Nos. 120, 344, & 284, 293 & 276, & 307 & 307 to Relocate Requirements to the QAPD
ML21253A0632021-11-19019 November 2021
Issuance of Amendment Nos. 306 and 306 to Update of the Loss of Coolant Accident Alternate Source Term Dose Analysis
ML21188A1742021-10-26026 October 2021
Issuance of Amendment Nos. 305 and 305 Revised Reactor Core Safety Limit to Reflect Topical Report WCAP-177642-P-A, Revision 1
ML21175A1852021-08-20020 August 2021
Issuance of Amendment Nos. 304 and 304 Leak-Before-Break for Pressurizer Surge, Residual Heat Removal, Safety Injection Accumulator, Reactor Coolant System Bypass and Safety Injection Lines
ML21201A1172021-08-0606 August 2021
Proposed Alternative Requests S1-I5-ISI-05 and S2-I5-ISI-06 to Eliminate Examination of Threads in Reactor Pressure Vessel Flange
ML21075A0452021-03-26026 March 2021
Request to Utilize Code Case N-885
ML20293A1602020-12-0808 December 2020
Issuance of Amendment Nos. 301 and 301 to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors
ML20148M3592020-12-0808 December 2020
Issuance of Amendment Nos. 302 and 302 to Revise Technical Specifications Figure 3.1 1, Surry Units 1 and 2 Reactor Coolant System Heatup Limitations, and Figure 3.1-2, Surry Units 1 and 2 Reactor Coolant System
ML20321A2322020-11-20020 November 2020
Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI
ML20301A4522020-10-28028 October 2020
Non-Proprietary, Issuance of Amendment Nos. 300 and 300 to Revise Technical Specifications 6.2.C, Core Operating Limits Report
ML20252A0072020-09-15015 September 2020
Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI
ML20085G9642020-05-19019 May 2020
Issuance of Amendments Nos. 298 and 298 to Revise Technical Specifications Table 3.7-1, Reactor Trip Instrument Operating Conditions, for an Addition of 24-Hour Completion Time for an Inoperable Rector Trip Breaker
ML20115E3522020-05-12012 May 2020
Alternative Request S2-I5-ISI-05 ASME Section XI Inservice Inspection Program Proposed Alternative Request to Use a Mechanical Clamping Device for a One-Inch Main Steam Line Repair
ML20115E2372020-05-0707 May 2020
Issuance of Exigent Amendments Nos. 299 and 299, to Revise TS 6.4.Q, Steam Generator (SG) Program, to Allow a One-Time Deferral of the Inspection of Surry Unit 2 Sg B Spring 2020 Refueling Outage
ML20058F9662020-03-16016 March 2020
Issuance of Amendment Nos. 297 and 297 to Revise Technical Specifications 3.16, Emergency Power System, to Allow a One Time 14-Day Allowed Outage Time for Replacement of 5-KV Cables Associated with Reserve Station
ML19305D2482019-12-31031 December 2019
Issuance of Amendments Adoption of Emergency Action Level Schemes Per NEI 99-01, Rev. 6
ML19028A3842019-06-12012 June 2019
Issuance of Amendment Nos. 295 and 295 to Adopt TSTF-490, Revision 0, and Update Alternative Source Term Analyses (EPID-L-2018-LLA-0068)
ML19043A8242019-03-15015 March 2019
Relief Requests Examination Coverage for Pressurizer Nozzle Inner Radius Sections and Certain Stainless Steel Piping Welds (S2-15-LMT-CO1 and S2-15-LMT-P01)
ML18331A0602019-02-28028 February 2019
Relief Requests Regarding Examination Coverage for Pressurizer Nozzle Inner Radius Section and Certain Stainless Steel Piping Welds (S1-I5-LMT-C01 and S1-I5-LMT-P01)
ML19031B2272019-02-27027 February 2019
Issuance of Amendment Nos. 281, 264, 294, and 294 to Consolidate Emergency Operations Facilities and Associated Emergency Plan Changes
ML18318A0622018-12-10010 December 2018
Review of Reactor Vessel Material Surveillance Capsule Withdrawal Schedules (CAC Nos. MG0098 and MG0099; EPID L-2017-LLL-0021)
ML18261A0992018-10-0505 October 2018
Issuance of Amendments. Request to Revise Technical Specifications Section 3.16 Emergency Power System Regarding a Temporary 21 Day Allowed Outage Time
ML18236A2362018-09-26026 September 2018
Relief from the Requirements of the ASME Code - Proposed Alternatives S1-I5-ISI-04 and S2-I5-ISI-04
ML18225A0202018-08-29029 August 2018
ISFSI; North Anna 1 & 2 Isfsls, and Unit 3; Surry Power 1 & 2, and Isfsls); Dominion Energy Kewaunee, Inc. (Kewaunee Power Station and Isfsi): Request for Threshold Determination Under 10 CFR 50.80
ML18166A3292018-06-29029 June 2018
Revised License Renewal Commitment Pressurizer Surge Line Weld Inspection Frequency
ML18106A0072018-05-0303 May 2018
Issuance of Amendments Regarding Open Phase Protection Per NRC Bulletin 2012 01 (CAC Nos. MF9805, MF9806; EPID L-2017-LLA-0238)
ML17326A2252018-02-0909 February 2018
Issuance of Amendments Regarding License Amendment Request to Revise Residual Heat Removal and Component Cooling System Technical Specifications Requirements (CAC Nos. MF9124 and MF9125; EPID L-2017-LLA-0166)
ML18019A1952018-01-24024 January 2018
Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination (CAC Nos. MF9923, MF9924, MF9925, MF9926, MF9927, and MF9928; EPID L-2017-LLR-0060)
ML17303A0682017-12-20020 December 2017
Nonproprietary Relief from the Requirements of the ASME Code (CAC Nos. MF8987 and MF8988; EPID L-2016-LLR-0019)
2024-08-23
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 23, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Blvd.
Glenn Allen, VA 23060
SUBJECT:
SURRY POWER STATION, UNITS 1 AND 2- RELIEF FROM THE REQUIREMENTS OF THE ASME CODE {TAC NOS. MF1809 AND MF1810)
Dear Mr. Heacock:
By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), Virginia Electric and Power Company (Dominion), the licensee, submitted alternative request G-1 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative G-1 is associated with 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 fifth 10-year interval 1ST program at Surry, Power Station, Units 1 and 2 (SPS1 and SPS2).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use ASME OM Code Case OMN-20 alternative on the basis that the ASME OM Code requirements present an undue hardship without compensating increase in the level of quality or safety.
The NRC staff reviewed alternative request G-1 and concludes, as set forth in the enclosed safety evaluation, that Dominion adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii) and is in compliance with the ASME OM Code requirements.
Therefore, the NRC staff authorizes alternative request G-1, use of ASME OM Code Case OMN-20, at SPS1 and SPS2 for the fifth 10-year 1ST intervals which are both scheduled to begin on May 10, 2014 and end on May 9, 2024 .
D. Heacock If you have any questions, please contact the Project Manager, Martha Barillas at 301-415-2760 or via e-mail at martha.barillas@nrc.gov.
Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 2-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos: 50-280 and 50-281
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 RELIEF REQUEST NO. G-1 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FIFTH 10-YEAR INTERVAL VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-280 AND 50-281
1.0 INTRODUCTION
By letter dated May 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A104), Virginia Electric and Power Company (Dominion), the licensee, submitted alternative request G-1 to the Nuclear Regulatory Commission (NRC) for review and approval. The proposed alternative G-1 is associated with 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 fifth 10-year interval 1ST program at
$urry Power Station, Units 1 and 2 (SPS1 and SPS2).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use ASME OM Code Case OMN-20 alternative on the basis that the ASME OM Code requirements present an undue hardship without compensating increase in the level of quality or safety.
2.0 REGULATORY EVALUATION
10 CFR 50.55a(f), "lnservice Testing Requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda.
10 CFR 50.55a(a)(3), states, in part, that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
- The SPS1 and SPS2 fifth 10-year 1ST intervals are both scheduled to begin on May 10, 2014, and end on May 9, 2024. The SPS1 and SPS2 1ST programs will comply with the ASME OM Code, 2004 Edition through 2006 Addenda.
Based on the above, the NRC staff finds that it has the regulatory authority to authorize the use of ASME Code Case OMN-20, as requested by Dominion.
3.0 TECHNICAL EVALUATION
3.1 Dominion's Alternative Request G-1 Dominion's alternative request applies to the test frequency specifications of the ASME OM Code. The following frequencies for tests given in the ASME OM Code do not include a tolerance band:
Test Frequencies- Class 2 and 3 Primary Containment Vacuum Relief Appendix 1, 1-1370 Valves Test Frequencies- Class 2 and 3 Vacuum Relief Valves Except for Primary Appendix I, 1-1380 Containment Vacuum Relief Valves Test Frequencies- Class 2 and 3 Pressure Relief Valves that are used for Appendix I, 1-1390 Thermal Relief A ication Appendix II, Performance Improvement Activities Interval Appendix II, Optimization of Condition Monitoring Activities Interval 11-4000
Reason for Request
ASME OM Code, Section 1ST, establishes the inservice test frequency for all components within the scope of the ASME OM Code. The frequencies (e.g., quarterly) have always been
interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG-1482, Revision 2) anq owners routinely applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specification (TS) Surveillance Requirements (SRs).
The TSs typically allow for a less than or equal to 25 percent extension of the, surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance. However, regulatory issues have been raised concerning the applicability of the TS grace period to ASME OM Code-required 1ST frequencies.
The licensee states the lack of a tolerance band on the ASME OM Code 1ST frequencies restricts operational flexibility. There may be a conflict where 1ST could be required (i.e., the frequency could expire), but where it is not possible or desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation is within its applicability.
The NRC *recognized this potential issue in the TSs by allowing a frequency tolerance as described in SPS1 and SPS2 TS 4.0.2. 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.
The licensee states 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 ISTs that minimize the conflicts between the need to complete the testing and plant conditions.
Proposed Alternative The licensee proposes to adopt ASME OM Code Case OMN-20, lnservice Test Frequency, which was published in conjunction with ASME OM Code, 2012 Edition. The purpose of this code case is to prescribe a methodology for determining acceptable tolerances for pump and valve test frequencies. This proposed alternative will be utilized for the SPS1 and SPS2 fifth 10-year 1ST intervals. This alternative will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the 1ST Program scope. The requirements of the ASME Code Case OMN-20 are described below.
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 ar~ 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 less than 2 years, the period may be extended by up to 25 percent for any given test.
- 2) For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test.
- 3) All periods .specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement).
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 less than 2-year 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 except as allowed by ASME OM, Division 1, Section 1ST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code.
Table 1 Specified Test Frequencies Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 mo)
Semiannually 184 days (or every 6 mo)
Annually 366 days (or every year) x years x calendar years where xis a whole number of years~ 2 3.2 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. (Reference NUREG-1482 Revision 1, Section 3.1.3). 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," the NRC determined that programmatic test frequencies can't be extended in accordance with the TS SR 3.0.2. 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 TS-Iike test interval definitions and interval extension criteria. The resultant ASME Code Case OMN-20, as shown above, was approved by the ASME Operation al')d 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 ASME Code Case OMN-20.
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 finds that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. 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.
4.0 CONCLUSION
As set forth above, the NRC staff determines that for alternative request G-1, the proposed alternative ASME OM Code Case OMN-20, provides reasonable assurance that the affected components are operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii),
and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff authorizes alternative request G-1 at SPS1 and SPS2 for the fifth 10-year 1ST intervals which are both *scheduled to begin on May 10, 2014 and end on May 9, 2024.
All other ASME OM Code requirements for which relief was not specifically requested and approved in the subject request remain applicable.
Principle Contributor: John Billerbeck, NRR Date: April 23, 2014
ML14111A241 *via email OFFICE NRR/DORULPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DE/EPNB NR R/DO RLIL PL2-1 /BC NAME MBarillas SFigueroa Tlupold* RPascarelli DATE 04/21/14 04/23/14 12/20/13 04/23/14
