ML17132A005

Alternative Request to Adopt American Society of Mechanical Engineers Code Case OMN-20 (CAC Nos. MF8313 and MF8314)

ML17132A005
Person / Time
Site:	Salem
Issue date:	05/19/2017
From:	James Danna Plant Licensing Branch 1
To:	Sena P Public Service Enterprise Group
Marshall M, NRR/DORL/LPLI, 415-2871
References
CAC MF8313, CAC MF8314
Download: ML17132A005 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 19, 2017 Mr. Peter P. Sena, Ill President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -

ALTERNATIVE REQUEST TO ADOPT AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE CASE OMN-20 (CAC NOS. MF8313 AND MF8314)

Dear Mr. Sena:

By letter dated August 30, 2016 (Agencywide Documents Access and Management System Accession No. ML16243A233), PSEG Nuclear LLC (the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of alternatives to certain inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at the Salem Nuclear Generating Station, Unit Nos. 1 and 2, for the fourth 10-year IST interval.

Specifically, pursuant to Title 1O of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested to use an alternative on the basis that complying with the specified requirement would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety.

The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes the proposed alternative request for the remainder of the fourth 10-year IST interval at the Salem Nuclear Generating Station, Units 1 and 2, which is currently scheduled to end on August 30, 2019.

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

P.Sena If you have any questions, please contact the Project Manager, Rick Ennis, at 301-415-1420 or Rick.Ennis@nrc.gov.

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7 James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosure:

Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST G-01 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE FOURTH 10-YEAR INTERVAL PSEG NUCLEAR LLC EXELON GENERATION COMPANY, LLC SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 311

1.0 INTRODUCTION

By letter dated August 30, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16243A233), PSEG Nuclear LLC (the licensee), submitted Relief Request G-01 to the U.S. Nuclear Regulatory Commission (NRC or the Commission). The licensee proposed alternatives to certain inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the fourth 10-year IST program at the Salem Generating Station (Salem), Unit Nos. 1 and 2.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested to use the proposed alternative in Relief Request G-01, since compliance with the ASME OM Code requirements would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety.

2.0 REGULATORY EVALUATION

The regulations in 10 CFR 50.55a(f), "lnservice testing requirements," require, in part, that IST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized by the NRC pursuant to paragraphs (z)(1) or (z)(2) of 10 CFR 50.55a.

In proposing alternatives, a licensee must demonstrate that the proposed alternative provides an acceptable level of quality and safety (10 CFR 50.55a(z)(1 )) or compliance would result in hardship or unusual difficulty, without a compensating increase in the level of quality and safety (10 CFR 50.55a(z)(2)). Section 50.55a allows the NRC to authorize alternatives to ASME OM Code requirements upon making necessary findings.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request, and the Commission to grant, the relief requested by the licensee.

Enclosure

3.0 TECHNICAL EVALUATION

3.1 Licensee's Relief Request G-01 3.1.1 Applicable Code Requirements The Salem, Unit Nos. 1 and 2, code edition and addenda that are applicable to the program interval are the ASME OM Code-2001 through the ASME OMb Code 2003 Addenda. The current interval for Salem, Unit Nos. 1 and 2, ends on August 30, 2019. This request relates to ASME OM Code Case OMN-20, "lnservice Test Frequency," which specifies the test frequency requirements for pumps and valves applicable to ASME OM Division 1, Section IST 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of the ASME OM Code. This request is applicable to the accelerated test frequencies specified in Code Case OMN-20.

3.1.2 Components for Which Relief is Requested The request applies to pumps and valves specified in ASME OM Division 1, Section IST 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of the ASME OM Code (i.e., all pumps and valves contained within the Salem IST program scope).

3.1.3 Reason for Requesting Relief ASME OM Code Section IST establishes the IST frequency for all components within the scope of the code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies, 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 percent extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting a TS surveillance (SR 3.0.2). However, in Regulatory Issue Summary 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests" (ADAMS Accession No. ML12079A393), and Enforcement Guidance Memorandum 12-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests" (ADAMS Accession No. ML11258A243), the NRC staff states that items related to extending the surveillance periods of the TS IST program were inappropriately added to the TSs and may not be applied to non-TS support components tested under 10 CFR 50.55a(f).

The lack of a tolerance band (i.e., extension, grace period) on the ASME OM Code IST frequency restricts operational flexibility. The lack of a tolerance band applied to the ASME OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility. Therefore, just as with TS-required surveillance testing, some tolerance is requested 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 IST that would minimize the conflicts between the need to complete the testing and plant conditions.

The licensee proposed to use ASME OM Code Case OMN-20, for determining acceptable tolerances for pump and valve test frequencies. The proposed alternative will be utilized for the

fourth 10-year interval and will apply to the various frequency specifications of the ASME OM Code for all pumps and valves contained within the IST program scope.

3.1.4 Licensee's Proposed Alternative ASME OM, Division 1, Section IST, and earlier editions and addenda of the ASME OM Code specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2 years, etc.) or on 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 IST with a specified time period between tests as shown in the table below.

Frequency Specified Time Period Between Tests Quarterly 92 days (or everv 3 months)

Semiannually 184 days (or every 6 months)

Annually 366 days (or everv vear) x calendar years x Years where 'x' is a whole number of years :;:: 2 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 used 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 the table above. Period extensions may not be applied to the test frequency requirements specified in ASME OM Code 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 the ASME OM Code.

3.2 NRC Staff Evaluation Historically, licensees have applied, and the NRC staff has accepted, the Standard TS definitions for IST intervals (including allowable interval extensions) to ASME OM Code-required testing (see Section 3.1.3 of NUREG-1482, Revision 2, "Guidelines for lnservice Testing at Nuclear Power Plants: lnservice Testing of Pumps and Valves and lnservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants," October 2013 (ADAMS Accession No. ML13295A020)). Recently, the NRC staff reconsidered the allowance of using TS testing intervals and interval extensions for IST. As noted in Regulatory Issue Summary 2012-10, the NRC determined that programmatic test frequencies cannot be extended to all IST described in the ASME OM Code in accordance with TS SR 3.0.2.

The lack of a tolerance band on the ASME OM Code IST frequency restricts operational flexibility. The NRC staff recognized that, 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. To provide operational flexibility when scheduling IST that minimize the conflicts between the need to complete the testing and plant conditions, the NRC staff sponsored and co-authored an ASME OM Code inquiry and Code Case to modify the ASME OM Code to include TSs like test interval definitions and interval extension criteria. The resultant Code Case OMN-20 was approved by the ASME Operation and Maintenance Standards Committee on February 15, 2012, with the NRC representative voting in the affirmative. Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code, 2012 Edition. The licensee proposes to adopt Code Case OMN-20 as described in Section 3.1.4 above.

Requiring the licensee to meet the ASME OM Code requirements without an allowance for defined frequency and frequency extensions for IST 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 concludes that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. Allowing usage of Code Case OMN-20 provides reasonable assurance of operational readiness of pumps and valves subject to the ASME OM Code IST.

4.0 CONCLUSION

As set forth above, the NRC staff determined that 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)(z)(2). Therefore, the NRC staff authorizes the proposed alternative request for the remainder of the fourth 10-year IST interval at Salem, Unit Nos. 1 and 2, which is currently scheduled to end on August 30, 2019.

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

Principal Contributor: Y. Huang Date: May 19, 2017

ML17132A005 *Safety Evaluation by e-mail OFFICE NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/PM NRR/DORL/LPL 1/LA NRR/DE/EPNB/BC*

NAME MMarshall REnnis LRonewicz DAiiey DATE 05/16/2017 05/16/2017 05/15/2017 03/17/2017 OFFICE DORL/LPL 1/BC DORL/LPL 1/PM NAME JDanna MMarshall DATE 05/19/2017 05/19/2017