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Category:Letter
MONTHYEARIR 05000333/20230042024-02-0707 February 2024 Integrated Inspection Report 05000333/2023004 and Independent Spent Fuel Storage Installation Inspection Report 07200012/2023001 ML24037A0102024-02-0606 February 2024 Requalification Program Inspection ML24018A0012024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000333/2024010) and Request for Information ML24004A2302024-01-0808 January 2024 Project Manager Reassignment ML23356A0832024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0058 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines JAFP-23-0065, License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications2023-12-14014 December 2023 License Amendment Request to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules, Revision 4, and Administrative Changes to the Technical Specifications IR 05000333/20234012023-12-0808 December 2023 Cybersecurity Inspection Report 05000333/2023401 (Cover Letter Only) RS-23-126, Request for Exemption from 10 CFR 2.109(b)2023-12-0707 December 2023 Request for Exemption from 10 CFR 2.109(b) JAFP-23-0069, Supplemental Response to Part 73 Exemption Request Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements2023-12-0707 December 2023 Supplemental Response to Part 73 Exemption Request Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements JAFP-23-0057, and Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 and Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation JAFP-23-0064, Emergency Plan Document Revision2023-11-15015 November 2023 Emergency Plan Document Revision JAFP-23-0063, Registration of Spent Fuel Cask Use2023-11-13013 November 2023 Registration of Spent Fuel Cask Use IR 05000333/20230032023-11-13013 November 2023 Integrated Inspection Report 05000333/2023003 ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000333/20230102023-10-26026 October 2023 Biennial Problem Identification and Resolution Inspection Report 05000333/2023010 JAFP-23-0059, Registration of Spent Fuel Cask Use2023-10-24024 October 2023 Registration of Spent Fuel Cask Use IR 05000333/20233012023-10-19019 October 2023 Initial Operator Licensing Examination Report 05000333/2023301 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans JAFP-23-0050, Physical Security Plan, Revision 242023-08-31031 August 2023 Physical Security Plan, Revision 24 JAFP-23-0048, Supplemental Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis2023-08-31031 August 2023 Supplemental Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis IR 05000333/20230052023-08-31031 August 2023 Updated Inspection Plan for James A. FitzPatrick Nuclear Power Plant (Report 05000333/2023005) JAFP-23-0047, Correction to the 2022 Annual Radioactive Effluent Release Report2023-08-30030 August 2023 Correction to the 2022 Annual Radioactive Effluent Release Report ML23228A1342023-08-16016 August 2023 Licensed Operator Positive Fitness-For-Duty Test IR 05000333/20230022023-08-0707 August 2023 Integrated Inspection Report 05000333/2023002 RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor JAFP-23-0040, License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis2023-08-0303 August 2023 License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis JAFP-23-0043, 10 CFR 50.46 Annual Report2023-07-31031 July 2023 10 CFR 50.46 Annual Report JAFP-23-0038, License Amendment Request to Modify Technical Specification Surveillance Requirement (SR) 3.4.3.1 Safety Relief Valves (S/Rvs) Setpoint Lower Tolerance2023-07-28028 July 2023 License Amendment Request to Modify Technical Specification Surveillance Requirement (SR) 3.4.3.1 Safety Relief Valves (S/Rvs) Setpoint Lower Tolerance ML23208A1622023-07-27027 July 2023 Operator Licensing Examination Approval IR 05000333/20234022023-07-26026 July 2023 Security Baseline Inspection Report 05000333/2023402 IR 05000333/20230112023-07-25025 July 2023 Post-Approval Site Inspection for License Renewal - Phase 4 Inspection Report 05000333/2023011 IR 05000333/20235012023-07-20020 July 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000333/2023501 JAFP-23-0033, License Amendment Request - Technical Specifications (TS) Section 3.3.1.2, Source Range Monitors (SRM) Instrumentation2023-06-28028 June 2023 License Amendment Request - Technical Specifications (TS) Section 3.3.1.2, Source Range Monitors (SRM) Instrumentation IR 05000333/20234202023-06-26026 June 2023 Security Baseline Inspection Report 05000333 2023420 RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23164A0322023-06-13013 June 2023 Request for Information for a Biennial Problem Identification and Resolution Inspection; Inspection Report 05000333/2023010 ML23152A0042023-06-0101 June 2023 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000333/2023401 RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling JAFP-23-0025, 2022 Annual Radiological Environmental Operating Report2023-05-10010 May 2023 2022 Annual Radiological Environmental Operating Report IR 05000333/20230012023-05-0303 May 2023 Integrated Inspection Report 05000333/2023001 ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI JAFP-23-0023, 2022 Annual Radioactive Effluent Release Report2023-04-27027 April 2023 2022 Annual Radioactive Effluent Release Report IR 05000333/20230122023-04-13013 April 2023 Quadrennial Fire Protection Inspection Report 05000333/2023012 ML23095A3722023-04-0505 April 2023 2023 Updated Final Safety Analysis Report, Technical Specification Bases and Technical Requirements Manual Changes Transmittal RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations IR 05000333/20220042023-03-20020 March 2023 Integrated Inspection Report 05000333/2022004 JAFP-23-0010, 2022 REIRS Transmittal of NRC Form 52023-03-20020 March 2023 2022 REIRS Transmittal of NRC Form 5 ML23061A1632023-03-0303 March 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch 3 2024-02-07
[Table view] Category:Safety Evaluation
MONTHYEARML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI ML22223A1412022-09-0101 September 2022 Issuance of Amendment No. 353 Adoption of TSTF - 505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B ML22196A0612022-08-23023 August 2022 Issuance of Amendment No. 352 Adoption of 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML22166A4302022-07-15015 July 2022 Issuance of Amendment No. 351 Removal of Selected Response Time Testing for Reactor Protection System and Primary Containment Isolation Instrumentation ML22126A1962022-05-27027 May 2022 Issuance of Amendment No. 350 Adoption of TSTF-264, Revision 0 ML22090A0862022-04-29029 April 2022 Amendments to Adopt TSTF-541,Rev.2,Add Exceptions to Surveillance Requirements for Valves,Dampers Locked in Actuated Position ML22094A0012022-04-15015 April 2022 Constellation Energy Generation, LLC - Proposed Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles (Epids L-2021-LLR-0057 and L-2021-LLR-0058) ML21364A0432022-02-28028 February 2022 Issuance of Amendment No. 348 Revising Surveillance Requirement 3.5.1.6 Involving Recirculation Pump Discharge Valves ML21347A0382022-01-13013 January 2022 Issuance of Amendments to Revise Reactor Coolant Leakage Requirements ML21277A2482021-11-16016 November 2021 Letter with Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (Public Version) ML21300A3552021-11-16016 November 2021 Issuance of Amendment No. 345 Adoption of TSTF-582 ML21230A2062021-09-0303 September 2021 Proposed Alternative to Use ASME OM Code Case OMN-28 ML21131A1272021-08-0909 August 2021 Issuance of Amendment No. 343 Modifications to Technical Specification 3.6.1.3, Primary Containment Isolation Valves (Pcivs) ML21216A2202021-08-0505 August 2021 Proposed Alternative to Eliminate Certain Documentation Requirements for Pressure Retaining Bolting ML21166A1682021-06-25025 June 2021 ML21162A0422021-06-14014 June 2021 Issuance of Amendment No. 342, One Time Extension of Completion Times to Support Residual Heat Removal Pump Motor Replacement (Emergency Circumstances) ML21049A3552021-04-28028 April 2021 Issuance of Amendment No. 341 Adoption of TSTF-478, Revision 2, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control ML21033A5302021-04-0101 April 2021 Issuance of Amendments to Adopt Technical Specifications Task Force TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems ML21028A6732021-02-0303 February 2021 Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI (EPID L-2020-LLR-011 ML20287A1302020-11-0505 November 2020 Review of Quality Assurance Program Changes ML20269A2002020-09-30030 September 2020 Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI (EPID L2020-LLR-0117 ML20169A5102020-08-20020 August 2020 Issuance of Amendment No. 339 Changes to Technical Specifications Related to Primary Containment Hydrodynamic Loads ML20140A0702020-07-21021 July 2020 Issuance of Amendment No. 338 Application of Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences ML20141L6362020-07-10010 July 2020 Issuance of Amendments Based on TSTF-427,Allowance for Nontechnical Specification Barrier Degradation on Supported System Operability,Rev 2 ML20134H9402020-07-0808 July 2020 Issuance of Amendments Revising the High Radiation Area Administrative Controls ML20094G9032020-06-0202 June 2020 Issuance of Amendment No. 335 Adoption of TSTF-372, Addition of LCO 3.0.8, 'Inoperability of Snubbers' ML20021A0702020-04-0606 April 2020 Issuance of Amendments to Delete License Conditions for Decommissioning Trusts ML20024C6612020-03-0202 March 2020 Issuance of Amendment No. 332 Adopt TSTF-568, Revision 2, Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2, Using the Consolidated Line Item Improvement Process ML19295G7832019-12-19019 December 2019 Issuance of Amendment No. 331 Regarding Change to Technical Specifications to Remove Ultimate Heat Sink Bar Rack Heaters ML19269C5342019-09-27027 September 2019 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19175A0422019-09-11011 September 2019 Arkansas Units 1 and 2; Grand Gulf, Unit 1; Indian Point 2 and 3; Palisades; River Bend, Unit 1; Waterford Unit 3 - Issuance of Amendments to Adopt TSTF-529, Clarify Use and Application Rules ML19176A0332019-08-28028 August 2019 Issuance of Amendments to Adopt TSTF-564, Safety Limit MCPR ML19189A0842019-08-19019 August 2019 Issuance of Amendment No. 326 Adoption of TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month ML19192A2442019-07-18018 July 2019 Proposed Alternative to Use ASME Code Cases N-878 and N-880 ML19157A2032019-07-11011 July 2019 Issuance of Amendment No. 325 Reactivity Anomalies Surveillance ML19135A4442019-06-21021 June 2019 Issuance of Relief Request I4R-22 Relief from the Requirements of the ASME Code ML19098A0342019-04-30030 April 2019 Units 1 and 2; Limerick, Units 1 and 2; Peach Bottom, Units 2 and 3, and Quad Cities, Units 1 and 2 - Revision to Approved Alternative to Use BWR Vessel and Internal Proj Guidelins ML18360A6352019-02-25025 February 2019 Safety Evaluation Regarding Implementation of Hardened Containment Vents Capable of Operation Under Severe Accident Conditions Related to Order EA-13-109 (CAC No. MF4464; EPID No. L-2014-JLD-0049) ML18304A3652019-01-16016 January 2019 2. Issuance of Amendments to Revise the Average Power Range Monitor Requirements ML18289A4322018-11-28028 November 2018 Issuance of Amendment No. 323 Revision to the Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6 ML18214A7062018-09-19019 September 2018 Issuance of Amendment No. 322, Revise Technical Specification 2.1.1, Reactor Core Sls, to Change Cycle 24 Safety Limit Minimum Critical Power Ratio Numeric Values ML18206A2822018-08-0202 August 2018 Issuance of Amendments to Relocate the Staff Qualification Requirements ML18180A3722018-07-19019 July 2018 Issuance of Amendment No. 319, Revise Technical Specification Surveillance Requirement 3.6.4.1.3 to Allow Opening of Inner and Outer Secondary Containment Access Openings (CAC MG0239; EPID L-2017-LLA-0298) ML18039A8542018-05-30030 May 2018 Relief Requests I5R-02, I5R-03, I5R-04 from ASME Code Requirements for Reactor Vessel Internals, Ferretic Piping Repair/Replacement, and RPV Flange Welds, 5th 10-Year Inservice Inspection Interval (MG0116-MG0118; L-2017-LLR-0083 to 0085) ML18044A9932018-04-13013 April 2018 Request for Alternatives PRR-01, PRR-02, PRR-04, VRR-02, VRR-03, and VRR-04 from ASME OM Code Requirements for Various Pumps and Valves, Fifth 10-Year Inservice Testing Interval (CAC MG0052-MG0061; EPID L-2017-LLR-0067 to L-2017-LLR-0074) ML17289A1752018-03-26026 March 2018 Issuance of Amendment No. 318, Revise Emergency Plan for Emergency Response Organization Requalification Training Frequency Consistent with Exelon Fleet (CAC MG0026; EPID L-2017-LLA-0273) ML18003B3822018-01-0303 January 2018 Correction to the Safety Evaluation to James A. Fitzpatrick Nuclear Power Plant Issuance of Relief Request for Proposed Alternative to Use ASME Code Case N-789-1 (CAC No. MF9692; EPID L-2017-LLR-0027) (Original Safety Evaluation: ML17289A07 ML17342A0062017-12-18018 December 2017 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 ML17289A0752017-12-12012 December 2017 Issuance of Relief Request for Proposed Alternative to Use ASME Code Case N-789-1 (CAC No. MF9692; EPID L-2017-LLR-0027) Note Correction Safety Evaluation See ML18003B382 2023-05-01
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REGUNITED STATES NUCLEAR REGULATORY COMMISSION 0'1',L WASHINGTON, D.C. 20555-0001 C(f:f " 0 'OJ : i:j V"/. Cctober 1, 2(U)1-'} ...0 ****i' Vice President, Entergy Nuclear Operations, James A. FitzPatrick Nuclear Power P.O. Box Lycoming, NY JAMES A. FITZPATRICK NUCLEAR POWER PLANT -RELIEF REQUEST VRR-06, REVISION 1 FROM THE REQUIREMENTS OF THE OM CODE RE: INSERVICE TESTING OF SAFETY RELIEF VALVES (TAC NO. ME1818)
Dear Sir or Madam:
By letter dated July 31, 2009, as revised by letter dated September 4,2009, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a request to the Nuclear Regulatory Commission (NRC) for the use of alternatives to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements at James A. FitzPatrick Nuclear Power Plant (JAFNPP).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i), the licensee requested to use the proposed alternative for inservice testing (1ST) of the safety relief valves (SRVs) on the basis that the alternative provides an acceptable level of quality and safety. Pursuant to 10 CFR 50.55a(f)(4)(iv), the licensee also requested to use later code editions and addenda for 1ST items subject to the limitations and modifications listed in 10 CFR 50.55a(b). As set forth in the enclosed safety evaluation, the NRC staff determines that the proposed alternative described in Relief Request VRR-06, Revision 1, provides an acceptable level of quality and safety and provides reasonable assurance that the SRVs 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)(i) and 10 CFR 50.55a(f)(4)(iv) for the portions of the later ASME OM Code edition and addenda, and is in compliance with the ASME OM Code's requirements.
Therefore, the NRC staff authorizes the proposed alternative in Relief Request VRR-06, Revision 1, on the basis that the alternative provides an acceptable level of quality and safety, and approves the use of ASME OM Code Mandatory Appendix I, Subparagraph 1-341 O(d) of the 2004 Edition of the ASME OM Code for 1ST items, subject to the limitations and modifications listed in 10 CFR 50.55a(b) at JAFNPP for the remainder of the fourth 10-year 1ST interval that began on October 1,2007.
V. P. Operations -2 All other ASME OM Code requirements for which relief was not specifically requested and approved, remain applicable.
Please contact Project Manager, Bhalchandra K. Vaidya at (301-415-3308, if you have any questions.
Sincerely, ancy L. Salgado, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.
Safety cc w/encl:
Distribution via UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. VRR-06 REGARDING PROPOSED ALTERNATIVE AND USE OF A LATER EDITION OF ASME OM CODE FOR INSERVICE TESTING OF SAFETY RELIEF VALVES 02RV-71A. B, C, D, E, F, G, H, J, K, L ENTERGY NUCLEAR OPERATIONS, INC. JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
By letter dated July 31, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092160412), as supplemented by letter dated September 4,2009 (ADAMS Accession No. ML092530249), Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a request to the Nuclear Regulatory Commission (NRC) for the use of alternatives to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements at James A. FitzPatrick Nuclear Power Plant (JAFNPP) for inservice testing (1ST) of safety/relief valves (SRVs) 71A, B,C,D,E,F,G,H,J,K,and LatJames A. FitzPatrick Nuclear Power Plant (JAFNPP). The licensee also requested NRC approval to use a portion of a later edition of the ASME OM Code for the JAFNPP.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (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.
Pursuant to 10 CFR 50.55a(f)(4)(iv), the licensee also requested to use a portion of a later code editions and addenda for 1ST items subject to the limitations and modifications listed in 10 CFR 50.55a(b).
2.0 REGULATORY EVALUATION
10 CFR 50.55a(f), "Inservice testing requirements," requires, in part, that ASME Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) and (a)(3)(ii) of 10 CFR 50.55a.
Enclosure
-2In proposing alternatives, a licensee must demonstrate that the proposed alternative provides an acceptable level of quality and safety or compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Section 50.55a authorizes the NRC to approve alternatives to ASME OM Code requirements upon making necessary findings. NRC guidance contained in NUREG-1482 Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants," provides alternatives to ASME Code requirements which are acceptable. 10 CFR 50.55a(f)(4)(iv) states that 1ST of pumps and valves may meet the requirements set forth in later editions and addenda of the ASME OM Code provided that they are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed in 10 CFR 50.55a(b), and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. Currently, 10 CFR 50.55a(b )(3) incorporates by reference the 1995 through the 2004 Edition of the ASME OM Code. 3.0 TECHNICAL EVALUATION 3.1 The Licensee's Relief Request and Alternative 3.1.1 The Licensee's Request for Alternative ASME OM Code Mandatory Appendix I, Subparagraph 1-1320(a), "Test Frequencies, Class 1 Pressure Relief Valves," 2001 Edition through 2003 Addenda, requires that Class 1 pressure relief valves be tested at least once every 5 years. The licensee proposed an alternative test interval for JAF SRVs 02RV-071A, B, C, 0, E, F, G, H, J, K, and L. In Revision 1 to Request VRR-06, the licensee proposes to test each SRV on a 72-month (with a 6-month grace period) interval. According to the licensee, each SRV will be given a dimensional inspection followed by refurbishment if required prior to the start of each 72-month test interval.
3.1.2 The Licensee's Request for the use of a Later Edition of the ASME OM Code The Code of record for the JAF 1ST program is the 2001 Edition through 2003 Addenda of the ASME OM Code. ASME OM Code Mandatory Appendix I, Subparagraph 1-3410(d)of the 2001 Edition through 2003 Addenda of the ASME OM Code requires that Class 1 SRVs with auxiliary actuating devices that have been maintained or refurbished in place, removed for maintenance and testing, or both, and reinstalled be remotely actuated at reduced or normal system pressure to verify open and close capability of the valve before resumption of electric power generation.
Subparagraph 1-341 O(d) was revised in the 2004 Edition of the ASME OM Code to not require that SRVs be opened and closed at reduced or normal system pressure following maintenance.
SUbparagraph 1-341 O(d) in the 2004 Edition of the ASME OM Code requires that each SRV that has been removed for maintenance or testing and reinstalled shall have the electrical and pneumatic connections verified either through mechanical/electrical inspection or test prior to the resumption of electric power generation. The licensee is requesting NRC approval to use Subparagraph 1-341 O(d) of the 2004 Edition of the ASME OM Code to test JAF SRVs 071A, B, C, 0, E, F, G, H, J, K, and L in place of Subparagraph 1-3410(d)of the 2001 Edition through 2003 Addenda of the ASME OM Code. The licensee stated that although changes were issued to other paragraphs in the 2004 Edition of the ASME OM Code, review of these
-3changes identified no changes related to the requirements for ASME OM Code 2004 Edition, Mandatory Appendix I, Subparagraph 1-3410(d). The licensee also stated that opening and closing SRVs 02RV-071A, B, C, D, E, F, G, H, J, K, and L at reduced or normal system pressure when installed in the plant can cause seat leakage. Past history indicates that the main disks may not reseat properly, resulting in steam leakage into the suppression pool. This leakage results in a decrease in plant performance and the potential for increased suppression pool temperature which could force a plant shutdown to repair a leaking SRV.
3.2 NRC Staff Evaluation 3.2.1 Technical Evaluation of the Licensee's Alternative The ASME developed Code Case OMN-17, "Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves." The ASME has approved Code Case OMN-17 and plans to publish Code Case OMN-17 in the upcoming edition/addenda of the ASME OM Code. Code Case OMN-17 allows extension of the test frequency for SRVs from 60 months to 72 months plus a 6-month grace period. The code case imposes a special maintenance requirement to disassemble and inspect each valve to verify that parts are free from defects resulting from the time-related degradation or maintenance-induced wear prior to the start of the extended test frequency. Although the ASME OM Code does not require that SRVs be routinely refurbished, refurbishment provides reasonable assurance that the SRVs are operationally ready during the extended test interval.
Consistent with the special maintenance requirement in Code Case OMN-17, the licensee stated that critical dimensions will be measured during the inspection of each SRV and the SRV will be refurbished if required prior to the start of each 72-month test interval. The NRC staff finds that the proposed alternative test frequency of 72 months plus a 6-month grace period for the JAF SRVs in Revision 1 to Request VRR-06 is acceptable. Inspection of each SRV to verify that parts are free from defects resulting from the time-related degradation or maintenance-induced wear prior to the start of the extended test frequency provides reasonable assurance that the SRVs are operationally ready during the extended test interval.
3.2.2 NRC Staff Evaluation of the Use of a Later Edition of the ASME OM Code The licensee has determined that opening and closing the JAF SRVs can contribute to undesirable seat leakage during subsequent plant operation. This is consistent with the NRC staff position in Section 4.3.2.1, "Boiling Water Reactor Safety/Alternative Valve Stoke Testing," of NUREG-1482, Revision 1, which states that the NRC staff has authorized alternatives related to testing requirements for main steam SRVs following maintenance activities because testing contributes to undesirable seat leakage. Furthermore, Subparagraph 1-3410(d)of Mandatory Appendix I of the ASME OM Code was revised in 2004 in order to eliminate the potential for undesirable seat leakage during subsequent plant operation. The 2004 Edition of the ASME OM Code was incorporated by reference into 10 CFR 50.55a(b) on September 10, 2008 (73 FR 52730) as corrected on October 2, 2008 (73 FR 57235), and became effective on October 10, 2008, subject to certain limitations and modifications.
The regulations in 10 CFR 50.55a(f)( 4)(iv) state that 1ST of pumps and valves may meet the
-4 requirements set forth in later editions and addenda of the ASME OM Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed in 10 CFR 50.55a(b), and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The NRC staff has identified no related requirements that would also need to be met to implement Subparagraph 1-341 O( d) of Mandatory Appendix I of the 2004 Edition of the ASME OM Code for the conduct of SRV testing. Use of the 2004 Edition of the ASME OM Code for the conduct of SRV testing was approved for use by the NRC staff in the September 10, 2008, Final Rule and is therefore acceptable for use at JAFNPP.
4.0 CONCLUSION
As set forth in the enclosed safety evaluation, the NRC staff determines that the proposed alternative described in Relief Request VRR-06, Revision 1, provides an acceptable level of quality and safety and provides reasonable assurance that the SRVs 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)(i) and 10 CFR 50.55a(f)(4)(iv) for the portions of the later ASME OM Code edition and addenda, and is in compliance with the ASME OM Code's requirements.
Therefore, the NRC staff authorizes the proposed alternative in Relief Request VRR-06, Revision 1, on the basis that the alternative provides an acceptable level of quality and safety, and approves the use of ASME OM Code Mandatory Appendix I, Subparagraph 1-3410(d) of the 2004 Edition of the ASME OM Code for 1ST items, subject to the limitations and modifications listed in 10 CFR 50.55a(b) at JAFNPP for the remainder of the fourth 10-year 1ST interval that began on October 1, 2007. All other ASME OM Code requirements for which relief was not specifically requested and approved, remain applicable.
Principal Contributor: S. Tingen Date: CCtd::er 1, 2[fJ)
V. P. Operations -2All other ASME OM Code requirements for which relief was not specifically requested and approved, remain applicable. Please contact Project Manager, Bhalchandra K. Vaidya at (301-415-3308, if you have any questions.
Sincerely, Boska IRA! for Nancy L. Salgado, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. Safety cc w/encl: Distribution via PUBLIC LPL1-1 R/F RidsNrrDorlLPL 1-1 RidsNrrDirsltsb RidsAcrsAcnwMailCenter S. Tingen, NRR/CPTB RidsNrrLASLittle (paper copy) LTrocine, EDO MGray. RI ADAMS A ccessron N 0.: M L092730032
(*) No su b S t an tl ia I c h ange from SE Input Memo OFFICE LPL1-1\PM LPL 1-1\LA NRR/CPTB/BC(A)(*) LPL1-1\BC NAME BVaidya SLittle RWolfganq NSalgado DATE 10101/09 10101/09 09/29/09 10/01/09 OFFICIAL RECORD