ML13301A767

Relief Request (RR-4-01, RR-4-02, RR-4-03) for Third and Fourth Ten- Year Inservice Inspection Interval (TAC Nos. MF1900, 1901, 1902)

ML13301A767
Person / Time
Site:	Summer
Issue date:	11/05/2013
From:	Pascarelli R J Plant Licensing Branch II
To:	Gatlin T D South Carolina Electric & Gas Co
References
TAC MF1900, TAC MF1901, TAC MF1902
Download: ML13301A767 (14)

Text

REG Ut UNITED STATES .;;,0 ",.Ii!', ... NUCLEAR REGULATORY

/:! WASHINGTON, D.C. 20555-0001

<< 0 ,.. is: <II November 5, 2013 1-., ...

Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Post Office Box 88, Mail Code Jenkinsville, SC 29065 VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 -RELIEF REQUEST (RR-4-01, RR-4-02, RR-4-03) FOR THIRD AND FOURTH TEN-YEAR INSERVICE INSPECTION INTERVAL (TAC NOS. MF1900, MF1901, MF1902)

Dear Mr. Gatlin:

By letter dated May 16, 2013, as supplemented by letters dated September 18 and Oct. 24, 2013, South Carolina Electric & Gas Company (SCE&G), the licensee, submitted alternative requests RR-4-01 and RR-4-02 and a relief request RR-4-03 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives to and relief from 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 Virgil C. Summer Nuclear Station Unit 1 (VCSNS) for the fourth 10-year 1ST program interval.

By letter dated October 24, 2013, the licensee further requested that applicability for alternative request RR-4-01 be extended to include the remainder of the third 10-year 1ST program interval (in addition to the fourth interval).

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR): 10 CFR 50.55a(a)(3)(ii), the licensee requested to use an alternative on the basis that complying with the specified requirement would result in hardship or unusual difficulty. 10 CFR 50.55a(a)(3)(i), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety. 10 CFR 50.55a(f)(6)(i), the licensee requested relief and to use alternative requirements (if necessary), for inservice inspection items on the basis that the code requirement is impractical.

The NRC has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that for alternative request RR-4-01, the proposed alternative provides reasonable assurance that the affected components are operationally ready and concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii).

The NRC finds that the proposed alternative described RR-4-02 provides an acceptable level of quality and safety for the affected pumps and concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i).

Use of the ASME OM Code Cases are authorized until such time as the ASME OM Code Cases are published in a future version of RG 1.192 and incorporated by reference in 10 CFR 50.55a(b).

T. Gatlin -2 The NRC concludes that granting the licensee's request for relief RR-4-03 pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the ASME OM Code requirements is impractical 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.

NRC staff authorizes alternative requests RR-4-01 and RR-4-02 and grants relief request 03 at VCSNS for the fourth ten-year 1ST interval which is scheduled to begin on January 1, 2014, and is scheduled to end on December 31, 2023. The NRC further authorizes alternative request RR-4-01 at VCSNS for the remainder of the third ten-year 1ST interval which began on April 1, 2004 and is scheduled to end on December 31, 2013. All other ASME OM Code requirements for which alternatives or relief was not specifically requested and approved in the subject request remain applicable.

If you have any questions, please contact the Project Manager, Shawn Williams, at 301-415-1009 or via e-mail at Shawn.Wiliiams@nrc.gov.

Sincerely, Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ALTERNATIVES TO ASME CODE REQUIREMENTS THIRD AND FOURTH TEN-YEAR INSERVICE INSPECTION PROGRAM INTERVAL SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By letter dated May 16, 2013 (Agencywide Document Access and Management System (ADAMS) Accession No. ML 13140A008), South Carolina Electric & Gas Company (SCE&G), the licensee, submitted alternative requests RR-4-01 and RR-4-02 and relief request RR-4-03 to the U.S. Nuclear Regulatory Commission (NRC). The licensee proposed alternatives to and relief from 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 inservice testing (1ST) program at Virgil C. Summer Nuclear Station, Unit 1 (VCSNS) for the fourth 10-year 1ST program interval.

By letter dated October 24, 2013 (ADAMS Accession No. ML 13301A006), the licensee further requested that applicability for alternative request 4-01 be extended to include the remainder of the third 10-year 1ST program interval (in addition to the fourth interval).

Specifically, pursuant to Title 10 of the Code of Federal Regulations 10 CFR Part 50, Section 50.55a(a)(3)(ii), the licensee requested to use the proposed alternative in RR-4-01 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety. Pursuant to Title 10 of the Code of Federal Regulations 10 CFR Part 50, Section 50.55a(a)(3)(i), the licensee requested to use the proposed alternative in RR-4-02 on the basis that the alternative provides an acceptable level of quality and safety. Pursuant to Title 10 of the Code of Federal Regulations 10 CFR Part 50, Section 50.55a(f)(5)(iii), the licensee requested relief in RR-4-03 from certain ASME OM Code requirements on the basis that the code requirements are impractical.

Enclosure

-2

2.0 REGULATORY EVALUATION

10 CFR 50.55a(f), "Inservice 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 !\IRC 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. 10 CFR 50.55a(f)(6), states, in part, that the NRC will evaluate determinations under paragraph (f)(5) that code requirements are impractical and may grant relief and may impose such alternative requirements as it determines 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.

The VCSNS third ten-year 1ST interval began on April 1,2004, and is scheduled to end on December 31,2013. The third interval 1ST program complies with the ASME OM Code, 1998 Edition through 2000 Addenda. The VCSNS fourth ten-year 1ST interval is scheduled to begin on January 1, 2014, and is scheduled to end on December 31,2023. The fourth interval 1ST program will comply with the ASME OM Code, 2004 Edition through 2006 Addenda. Based on the above and subject to the !\JRC's findings with respect to authorizing the proposed alternatives to and granting relief from the ASME OM Code given below, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the alternatives and relief requested by the licensee.

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3 3.0 TECHNICAL EVALUATION

3.1 Licensee's

Alternative Request RR-4-01 This request applies to the test frequency specifications of the ASME OM Code. The frequencies for tests given in the ASME OM Code include the following, but do not include a tolerance band: ! , Code Paragraph Description "The frequency for the in service testing shall be in accordance with the ; ISTA-3120{a) -_.i Frequency of Inservice Tests I ISTB-3400 , Exercising

"!"est Frequency ISTC-3510

-ISTC-3540 Manual Frequency , .. ** ! ISTC-3700 Position Verification Testing I j "At least one valve from each group shall be disassembled and examined at each refueling outage; aU valves in a group shall be disassembled and I'STC-S221 examined at least once every 8 Appendix Test 1 Pressure Relief Valves r 1,1-1330 Test Freg.uencies, Class 1 Nonreclosing Pressure Relief Devices Test Frequencies

-Class 1 Pressure Relief Valves that are used for I. 1-1340 Thermal Relie! : Appendix I, 1-1350 Test Frequencies

-

2 and 3 Pressure Relief l Appendix 1,1-1360 Test Frequencies

-Class 2 and 3 Nonreclosing Pressure Relief Devices I Test Frequencies

-Class 2 and 3 Primary Containment Vacuum Relief I Appendix 1. 1-1370 Valves .

Test Frequencies

-Class 2 and 3 Vacuum Relief Valves Except for Primary i Appendix I. 1-1380 Containment Vacuum Relief Valves Test Frequencies

-Class 2 and 3 Pressure Relief Valves that are used for i Appendix I. 1-1390 Thermal Relief AEpJication

'"_." Appendix II, Perfonnance Improvement Activities Interval 11-4000(a)(1 ) -I , Appendix II, Optimization of Condition Monitoring Activities Interval i 11-4000(b)(1)(e) j.,,,.... 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 1) and 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% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance.

-4 However, regulatory issues have been raised concerning the applicability of the TS grace period to ASME OM Code-required 1ST frequencies.

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 not 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 TS SR 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.

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 ISTs, minimizing 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, Inservice 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.

The text of Code Case OMI\I-20 is shown below. This proposed alternative will be utilized for the remainder of the VCSNS third ten-year 1ST interval which began on April 1, 2004, and is scheduled to end on December "31 ,2013. This alternative will also be utilized for the fourth ten-year 1ST interval which is scheduled to begin on January 1, 2014, and end on December 31,2023. The third interval 1ST program complies with the ASME OM Code, 1998 Edition through 2000 Addenda. The fourth interval 1ST program will comply with the ASME OM Code, 2004 Edition through 2006 Addenda. 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. Code Case OMN-20 -Inservice Test Frequencv 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 yr, 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.

-5 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 Inservice 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. Table 1 Specified Test Frequencies Frequency Specified Time Period Between Tests Quarterly 92 days (or every 3 mol Semiannually 184 days (or every 6 mol Annually 366 days (or every year) x years x calendar years where x is a whole number of years 2': 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.

-6 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-like test interval definitions and interval extension criteria.

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 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 staff finds that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMI\I-20 is acceptable.

Allowing usage of ASIVIE 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 RR-4-02 ISTB-3300, "Reference Values," states, in part, that "Reference values shall be established within +/-20 percent of pump design flow rate for the comprehensive test," and "Reference values shall be established within +/-20 percent of pump design flow for the Group A and Group B tests, if practicable." ISTB-3400, "Frequency of Inservice Tests," states that "An inservice test shall be run on each pump as specified in Table ISTB-3400-1." Table ISTB-3400-1, "Inservice Test Frequency," specifies that Group A and Group B tests be performed quarterly and a comprehensive test be performed biennially for Group A and Group B pumps. Table ISTB-351 0-1, "Required Instrument Accuracy," specifies the instrument accuracies for Group A, Group B, comprehensive, and preservice tests. Table ISTB-5121-1, "Centrifugal Pump Test Acceptance Criteria," defines the required acceptance criteria for Group A, Group B, and comprehensive tests for centrifugal pumps. Table ISTB-5221-1, "Vertical Line Shaft and Centrifugal Pumps Test Acceptance Criteria," defines the required acceptance criteria for Group A, Group B, and comprehensive tests for Vertical Line Shaft centrifugal pumps. ASME OM Code Case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly within +/-20% of Design Flow" states, in part, that "the Group A test maybe performed quarterly within +/-20% of pump design flow rate, with instrumentation meeting the requirements of Table ISTB-3510-1 for the comprehensive and preservice tests, and no comprehensive test is required."

-7 Reason for Request The ASME OM Code committees have approved ASME Code Case OMN-18, Alternate Testing Requirements for Pumps Tested Quarterly within +/- 20 percent of Design Flow. This code case has not been approved for use in Regulatory Guide (RG) 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," June 2003. This code case allows the owner to not perform the Comprehensive Pump Test (CPT) with the associated acceptance criteria, if the quarterly test is performed at +/- 20 percent of design flow and the instrumentation meets the accuracy requirements of Table ISTS-351 0-1 for the comprehensive and preservice tests. The basis for the testing strategy in this code case is that a quarterly Group A pump test, performed at the CPT 'flow rate with more accurate instrumentation, is more effective in assessing a pump's operational readiness than a standard Group A test in conjunction with a biennial CPT. Additionally, ISTS allows the owner to categorize the pumps in their program. As such, an owner could categorize a pump that otherwise meets the requirements of Group S, as a Group A (or AS) pump, and test according to the provisions of ASME Code Case OMN-18. In doing this, the owner is obtaining additional data (vibration and flow or differential pressure) quarterly, rather than once every two years. As a result of the increased requirements on the parameters imposed by the proposed alternative during applicable quarterly tests, there is no added value in performing the biennial comprehensive test on the subject pumps. Proposed Alternative VCSNS is proposing to utilize the provisions of ASME Code Case OMN-18 and perform a modified Group A test in lieu of performing the ASME OM Code-required CPT. The modified Group A test will be run at +/- 20 percent of the pump's design flow rate using +/- 0.5 percent accurate digital gauges or better to determine the pump differential pressure.

Vibration tests will be performed with the same vibration acceptance criteria as the standard Group A pump test. Additionally, VCSI\JS will utilize an Acceptable Range High limit of 106 percent or lower for quarterly testing, which is also consistent with the planned ASME OM Code change applicable to CPT. The use of more accurate pressure gauges and a more limiting Acceptable Range during every modified quarterly Group A test compensates for the elimination of the CPT. The CPT has a more limiting Acceptable Range upper bound for differential pressure of 103 percent. Regular testing with more accurate instrumentation and tighter acceptance criteria will provide for better trending of pump performance.

Instead of performing seven tests with pressure instruments with +/- 2 percent accuracy and then performing the eighth test with pressure instruments with a minimum of +/- 0.5 percent accuracy, all eight tests will be performed with the same +/- 0.5 percent accurate digital instruments or better. Due to the improved accuracy, consistent testing methodology, and the addition of quarterly vibration monitoring on Group AS pumps, deviations in actual pump performance indicative of impending degradation are more easily recognized during quarterly performance trending activities.

-8 The provisions of this request as an alternative to the requirements of ISTB-3400 and Tables ISTB-3400-1, ISTB-S121-1, & ISTB-S221-1 provides a reasonable alternative to the ASME OM Code requirements based on the determination that the proposed alternative will provide adequate indication of pump performance, permit detection of component degradation, and continue to provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR SO.SSa(a)(3)(i), VCSNS requests approval of this alternative to the specific ISTB requirements identified in this request for the following pumps:

• XPP001 3A & B, Boric Acid Transfer Pumps (Centrifugal!

Group A I Class 3)

• XPP0038A & B, Reactor Building Spray Pumps, (Centrifugal!

Group AB I Class 2)

• XPP0039A, B & C, Service Water Pumps, (Vertical Line Shaft I Group A! Class 3)

• XPP004SA & B, Service Water Booster Pumps, (Centrifugal!

Group AB I Class 3)

• XPP0048A & B, HVAC Chilled Water Pumps, (Centrifugal!

Group A! Class 3) NRC Staff Evaluation The licensee is proposing to perform a quarterly 1ST for the pumps listed above in accordance with a modified Group A test procedure, in lieu of quarterly Group A tests and a CPT every two years. The ASME OM Code requires that for Group A pumps, a Group A test be performed every quarter, and a CPT be performed biennially.

The Group A test is performed within +/-20% of the pump design flow rate and the pressure instrument accuracy is +/-2%. The upper limit for the "Acceptable Range" for How rate and differential pressure is 110% of the reference values, and the high value for the "Required Action Range" for flow rate and differential pressure is greater than 110% of the reference values. The CPT is performed within +/-20% of the pump design flow rate, the pressure instrument accuracy is +/-1/2%, and the high value of "Required Action Range" is greater than 103% of the respective reference values. Vibration monitoring is performed during both the Group A tests and the CPTs. The licensee proposes that for the pumps listed above, a modified Group A quarterly test will be performed using ASME OM Code Case OMN-18, with modified "Required Action" ranges, and the biennial comprehensive test will not be performed.

The modified Group A quarterly test would be performed within +/-20% of the pump design flow rate, using more accurate pressure instrumentation (i.e. instrument accuracy required for a CPT (+/-1/2% instead of +/-2%)). The licensee will use a more limiting high value of 1 06% for the "Required Action Range" in lieu of 110% that is normally required by the ASME OM Code for Group A tests. However, the high value 106% is greater than the high value of 103% for the biennial CPT. Using more accurate pressure gauges and a more limiting "Required Action Range" (compared to the Group A test "Required Action Range") during every modified quarterly Group A test compensates for the elimination of the CPT with its more limiting "Required Action Range" high value of 103%.

-9 OMN-18 was published in the 2009 Edition of the ASME OM Code. This Edition of the ASME OM Code has not been incorporated by reference into 10 CFR SO.SSa, and OMN-18 has not been incorporated into RG 1.192. However, the NRC staff has reviewed OMN-18, and currently has no concerns with its usage, providing that the high values of the Group A test "Required Action Range" for 'flow (Q) and differential pressure are greater than 106% of the respective reference values. The NRC staff considers the proposed alternative acceptable because all of the tests will be performed with pressure gauges with +/-1/2% accuracy.

The elimination of the CPT, with its more limiting "Required Action Range" of upper bound of 103% of the reference value, is compensated for by using more accurate pressure gauges on every quarterly test. Regular testing with more accurate instrumentation and tighter acceptance criteria will provide for better trending of pump performance.

Therefore, the NRC staff finds that the proposed alternative provides an acceptable level of quality and safety. 3.3 Licensee's Alternative Request RR-4-03 The licensee requested relief from the following ASME OM Code requirements which require that check valve exercise tests include open and closed tests: "Category C Check Valves," specifies check valve exercising requirements and sub-paragraph (a) states that " ... each check valve shall be exercised or examined in a manner that verifies obturator travel by using the methods in ISTC-S221.

Each check valve exercise test shall include open and close tests." "Valve Obturator Movement," sub-paragraph (a) specifies that "The necessary valve obturator movement shall be demonstrated by performing both an open and close test." Sub-paragraph (a)(2) also states "Check valves that have a safety function in only the open direction shall be exercised by initiating flow and observing that the obturator has traveled either the full open position or to the position required to perform its intended function(s) (see ISTA-1 100), and verify closure." Relief was requested for the following valves: XVC03130A and XVC03130B Reason for Request The normally open Service Water (SW) system discharge check valves perform an active safety function in the open position to allow SW return flow to the SW pond. Unimpaired return flow is required for the SW system to provide maximum cooling of essential heat loads during accident conditions.

The valves perform no safety function in the closed position.

Pursuant to 10 CFR SO.SSa(f)(S)(iii), relief is requested from the listed requirements of the ASME OM Code. The majority of the SW return piping is underground including these SW system discharge check valves. The system configuration does not provide a means to employ non-intrusive test methods or disassembly to confirm valve closure. The valves are buried without direct access, making these alternate techniques impractical.

-To comply with the ASME OM Code bi-directional testing requirements, either routine excavations or a system modification would be required.

Since the valves are buried without direct access, excavation would be required every outage to allow access to the valves to facilitate valve disassembly and inspection or to employ non-intrusive test methods. Alternatively, a design modification of the SW system would be required to allow routine access to the valves to allow testing the valves in the closed direction using non-intrusive test methods or system operation.

Proposed Alternative VCSNS will perform full stroke exercise testing to the safety-related open position during refueling outages without performing bi-directional exercise testing to the nonsafety-related closed position.

The design close function of these check valves is to prevent Siphoning of the pond in the event of a postulated crack of a large diameter pipe in the SW system piping and to prevent inadvertent flooding during SW system maintenance from an incorrect valve lineup. The SW piping is moderate energy piping. Therefore, the design rules require that cracks, not breaks, must be postulated.

Calculations for the postulated crack project a leak flow range less than the capacities of the sump pumps in the affected areas. Due to the relatively small size of the resulting crack, the existing plant can easily handle a leak without requiring the valves to shut. Therefore, the back-seat function has been determined to not be required, since the SW system and the Auxiliary and Intermediate buildings are designed to accommodate all postulated cracks. Also, due to the design of the valve (duo-disc), related degradation of the valve would not affect the valve's ability to perform its safety-related function.

Based on the absence of a safety function in the closed position, elimination of the bi-directional reverse flow closure testing for these valves has no safety impact. Therefore, pursuant to 10 CFR SO.SSa(f)(S)(iii), VCSNS requests approval of relief from the specific ISTC requirements identified in this request. NRC Staff Evaluation The ASME OM Code requires that safety-related check valves be exercise tested in both the open and closed direction quarterly (bi-directional testing).

If exercising is not practical during plant operation, it shall be performed during cold shutdown.

If exercising is not practical during plant operation or cold shutdowns, it shall be performed during refueling outages. The licensee requests relief from the bi-directional exercise testing requirements specified in ISTC-3S22(a) and ISTC-S221 (a) for the SW system discharge check valves. The SW system discharge check valves are buried underground without direct access. The valves do not perform a safety function in the closed position and during the previous 10-year 1ST intervals testing was not required in the closed direction by the applicable ASME OM Code. It is impractical for the licensee to test the SW system discharge check valves in the closed direction due to the design of the SW system which does not provide direct access to the valves or the capability to test the valves in the closed direction using non-intrusive test methods or system operation.

The licensee's alternative to full stroke exercise test the valves to the

-11 related open position without performing bi-directional exercise testing to the nonsafety-related closed position provides reasonable assurance of the operational readiness of the SW system discharge check valves.

4.0 CONCLUSION

As set forth above, the NRC staff determines that for alternative request RR-4-01, the proposed alternative 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).

The !'JRC staff further finds that the proposed alternative described RR-4-02 provides an acceptable level of quality and safety for the affected pumps. 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)(i).

Use of the ASME OM Code Cases are authorized until such time as the ASME OM Code Cases are published in a future version of RG 1.192 and incorporated by reference in 10 CFR 50.55a(b).

At that time, if the licensee intends to continue implementing these ASME OM Code Cases, it must follow all provisions of ASME OM Code Case OMN-18 and OMN-20 with conditions as specified in RG 1.192 and limitations as specified in 10 CFR 50.55a(b)(6), if any. The NRC staff also concludes that granting the licensee's request for relief RR-4-03 pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the ASME OM Code requirements is impractical 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.

Therefore, the NRC staff authorizes alternative requests RR-4-01 and RR-4-02 and grants relief request RR-4-03 at VCSNS for the fourth ten-year 1ST interval which is scheduled to begin on January 1,2014, and is scheduled to end on December 31,2023. The NRC further authorizes alternative request RR-4-01 at VCSNS for the remainder of the third ten-year 1ST interval which began on April 1 ,2004, and is scheduled to end on December 31,2013. All other ASME OM Code requirements for which alternatives or relief was not specifically requested and approved in the subject request remain applicable.

Principle Contributor:

John Billerbeck, NRR T. Gatlin -2 The NRC concludes that granting the licensee's request for relief RR-4-03 pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the ASME OM Code requirements is impractical 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.

NRC staff authorizes alternative requests RR-4-01 and RR-4-02 and grants relief request 03 at VCSNS for the fourth ten-year 1ST interval which is scheduled to begin on January 1, 2014, and is scheduled to end on December 31,2023. The NRC further authorizes alternative request RR-4-01 at VCSNS for the remainder of the third ten-year 1ST interval which began on April 1, 2004 and is scheduled to end on December 31, 2013. All other ASME OM Code requirements for which alternatives or relief was not specifically requested and approved in the subject request remain applicable.

If you have any questions, please contact the Project Manager, Shawn Williams, at 301-415-1009 or via e-mail at Shawn.Williams@nrc.gov.

Sincerely, IRA! Robert Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION:

Public LPL2-1 R/F RidsAcrs_AcnwMailCTR Resource RidsNrrLASFigueroa Resource RidsNrrDorlDpr Resource RidsRgn2MailCenter Resource RidsNrrPMSummer Resource RidsNrrDeEpnb Resource ADAMS Accession No.: ML13301A767

• By E-mail LPUI-1/PM LPUI-1/LA DElDD* LPUI-1/BC OFFICE JTsao (Acting RPascarelli SWilliams SFigueroa NAME SWilliams for T. Lupoid) ** 10/28/13 11/5/13 11/5/13 11/1/13 10/31/13 DATE OFFICIAL RECORD COPY