RBG-47737, Relief Requests for 10-year Updates to the 120-Month Inservice Testing Intervals

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Relief Requests for 10-year Updates to the 120-Month Inservice Testing Intervals
ML17065A091
Person / Time
Site: River Bend Entergy icon.png
Issue date: 02/27/2017
From: Schenk T
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-47737
Download: ML17065A091 (18)
v • d • e


Text

-=-Entergy

\

Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775 Tel 225-381-4177 Timothy A. Schenk Manager, Licensing February 27, 2017 U. $. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RBG- 47737

Subject:

Relief Requests for 10-year updates to the 120-Month lnservice Testing Intervals River Bend Station - Unit 1 Docket No. 50-458

  • License No. NPF-47 Pursuant to 10 CFR 50.55a, River Bend Station - Entergy .Operations, Inc~ (Entergy) requests alternatives for the lnservice Testing Program. These requests are needed to support the 120-month updates for the upcoming intervals. These requests*are similar to requests approved for use in the current interval. The details of the 10 CFR so.55a requests are provided in the attachment.

Entergy requests approval as soon as practical. The new intervals start on 12-2-201.7.

If you have any questions or require additional information, please contact Tim Schenk at (225) 381- 4177.

This letter contains no new commitments.

s~~

Timothy A. Schenk Manager - Licensing RBF1-17-0020

RBG-47737 Page 2 of 2 Attachments:

Attachment 1: RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2) Hardship Without a Compensating Increase in Quality and Safety Attachment 2: RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-2 Proposed Alternat_ive In Accordance with 10 CFR 50.55a(z)(1) AcceptablC3 Level of Quality and Safety

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Attachment 3: RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1) Acceptable Level of Quality and Safety -

cc: Regional Administrator ,

U.S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.

Arlington, TX 76011-4511 NRG Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U. S. Nuclear Regulatory Commission Attn: Ms. Lisa Regner MS 08H04 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Louisiana Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section

  • Ji Young Wiley P. 0. Box 4312 _

Baton Rouge, LA 70821-4312 Public Utility Commission of Texas -

Attn: PUC Filing Clerk 1701 N. Congress Avenue P. 0. Box 13326 Austin, TX 78711 ~3326

Attachment 1 RBG-47737 RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2)

Hardship Without a Compensating Increase in Quality and Safety

RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2)

Hardship Without a Compensating Increase in Quality and Safety

1. American Society of Mechanical Engineers (ASMEl Code Component{s) Affected Pumo ID Function Cateciorv Class SWP-P2A STANDBY SERVICE WATER PUMP A Group B *3 SWP-P2B STANDBY SERVICE WATER PUMP B Group B 3 SWP-P2C STANDBY SERVICE WATER PUMP C Group B 3 SWP-P2D STANDBY SERVICE WATER PUMP D Group B 3
2. Applicable ASME Code Edition and Addenda ASME OM Code-2004 Edition, with Addenda through and including ASME OMb Code-2006.
3. Applicable Code Reguirement(s)

ASME OM Code 2004 Edition with addenda through OMb Code 2006 Addenda ISTB-3540(b) requires that vibration measurements on vertical line shaft pumps be taken on the upper motor-bearing hqusing in three orthogonal di.rections, one of which is in the*

axial direction.

4. Reason for Request Pursuant to 10 CFR 50.55a, "Codes and Standards", paragraph (z)(2), an alternative is requested when using the requirements of ASME OM Code-2004 Edition with addenda through OMb Code-2006 Addenda ISTB (as listed above).

This alternative is a re-submittal of NRG approved 2nd Interval PRR-006 that was based on the ASME OM Code 1987 Edition with addenda through OMa-1988. The 3rd*

Interval alternative request PRR-RBS-2007-1 was based on the ASME OM Code-2001 Edition with addenda through OMb Code-2003 Addenda. This re..:submittal is an alternative based on the ASME OM Code-2004 Edition with addenda through OMb Code-2006 Addenda. There have been no substantive changes to this alternative, to the OM Code requirements or to the basis for use, which would alter the previous NRG Safety Evaluation conclusions.

The Code-required vibration measurements on the upper motor bearing housing on these vertical line shaft pumps are impractical because the standby service water pump motors are totally enclosed, weather-proof induction motors that are equipped with housing covers which completely enshroud the upper motor bearing housing. The housing cover precludes vibration measurements from being taken directly on the upper bearing housing. \

RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RB~-2017-1 Proposed Alternative In Accordance with. 10 CFR 50.55a(z)(2)

Hardship Without a Compensating Increase in Quality and Safety .

5. Proposed Alternative and Basis for Use Vibration measurements will be taken in three orthogonai directions in a location f

that provides valid indication of motor vibratory motion in close proximity_ of the upper motor bearing housing.

On the standby service water pumps the upper bearing measurements will be taken at the lifting lug that is integral to the motor stator housing. The lifting lug is structurally rigid and provides transmissibility of the motor vibratory motion. The vibration measurements will be taken in three. orthogonal directions on the lifting lug. This location has demonstrated the ability to provide repeatable vibration data and will provide readings that are at least as_ repr~sentative of pump mechanical condition as tnose required by the ASME OM Code-2004 Edition with addenda through OMb Code-2006' Addenda. Therefore, application of the ASME OM ~ode-2004 Edition with addenda through OMb Code-2006 Addenda hydraulic testing criteria along with radial

'and axial vibration monitoring on the lifting lug should provide adequate da~a for assessing the condition of the subject pumps and for monitoring for degradation.

The above proposed alternative provides reasonable assurance of the operational read_iness since vibration measurements will be taken in three orthogonal directions on the lifting lug. These readings will provide information as to the mechanical integrity of the pumps.

Based on the determination that compliance with the ASME OM Cod~..:2004 Edition with addenda through OMb Code-2006 Addenda requirements .results in a hardship I without a compensating increase in the level of quality or safety, this proposed alternative should be granted pursuant to 10 CFR 50.55a(z)(2).

6. Duration of proposed Alternative This relief is requested for the fourth ten year IST interval, which begins December 2, 2017 and is scheduled to end on December 1, 2027.
7. Precedent Use of an alternative for similar requirements was previously granted as PRR-006 for River Bend's 2nd 120-month lnservice Testing Interval (TAC-No. M97705).

Use of an alternative was also granted as PRR-RBS-2007-1 for River Bend's 3rd 120-month lnservice Testing Interval (RBC-50599)

Attachment 2 RBG-47737 RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-2 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety

RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-2 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

  • Acceptable Level of Quality and Safety *
1. American Society of Mechanical Engineers CASME} Code Component(s} Affected Pumo ID *Function Cateaorv Class E12-PC002A RESIDUAL HEAT REMOVAL PUMP 2A Group A 2 E12-PC002B RESIDUAL HEAT REMOVAL PUMP 2B Group A 2 E12-PC002C RESIDUAL HEAT REMOVAL PUMP 2C Group B 2 SFC-P1A FUEL POOL COOLING PUMP A Group A 3 SFC-P1B FUEL POOL COOLING PUMP B Group A 3 HVK-P1A CONTROL BLDG CHILLED WATER PUMP 1A Group A 3 HVK-P1B CONTROL BLDG CHILLED WATER PUMP 1B .Group A 3 HVK-P1C CONTROL BLDG CHILLED WATER PUMP 1C Group A 3 HVK-P1D CONTROL BLDG CHILLED WATER PUMP 1D Group A 3 SWP-P3A CNTRL BLDG CHILLED WATER RECIRC PUMP A Group A 3 SWP-P3B CNTRL BLDG CHILLED' WATER RECIRC PUMP B Group A 3 SWP-P3C CNTRL BLDG CHILLED WATER RECIRC PUMP C Group A 3 SWP-P3D CNTRL BLDG CHILLED WATER RECIRC PUMP D Group A 3 E12-PC003 RESIDUAL HEAT REMOVAL PUMP DISCHARGE
  • Group A 2 LINE FILL PUMP E21-PC002 LOW PRESSURE CORE SPRAY PUMP Group A 2 DISCHARGE LINE FILL PUMP E22-PC003 HPCS PUMP DISCHARGE LINE FILL PUMP Group A 2 E51-PC003 REACTOR CORE ISGL COOLING SUB SYSTEM Group A 2 FILL PUMP E51-PC001
  • REACTOR CORE ISOL COOLING PUMP Group B 2 E21-PC001 LOW PRESSURE CORE SPRAY PUMP Group B 2 r

E22:.pcoo1 HIGH PRESSURE CORE SPRAY PUMP Groups ' 2

2. Applicable ASME Code Edition and Addenda ASME OM Code-2004 Edition, with Addenda through and including ASME OMb Code-2006.
3. Applicable Code Reguirement(s)

Table ISTB-3000-1, "lnservice Test Parameters" Table ISTB-3400-1, "lnservice Test Frequency

Table ISTB-3510-1, "Require Instrument Accuracy" Table ISTB-5121-1, "Centrifugal Pump Test Acceptance Criteria" ISTB-5123, "Comprehensive Test Procedure". Comprehensive tests shall be conducted with the pump operating at a specified reference point. The test parameters shown in Table ISTB-3000-1 shall be determined and recorded as required by this paragraph.

RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-2 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety

4. Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and Standards", paragraph (z)(1), an alternative is requested when using the requirements of ASME OM Code-2004 Edition with addenda .

through OMb Code-2006 Addenda ISTB (as listed above).

The ASME OM Code Committee has approved Code Case OMN-18, "Alternative Testing Requirements for Pumps Tested Quarterly with +/- 20% of Design Flow," which allows owners to perform a Group A test in lieu of the Comprehensive Pump Test (CPT) if the Group A test is conducted at +/- 20% of the design flow rate and uses ..

pressure instruments that meet the CPT accuracy requirements(+/- 1/2%). This Code Case was not reviewed for approval in* Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code", 'Revision 1, August 2014.

However, the OM Code Case OMN-18 is listed in Draft Regulatory Guide DG-1297

,(Proposed Revision *2 to Regulatory Guide 1.192, dated March 2016), "Operation arid Maintenance Code Case Applicability, ASME OM Code". River Bend Station is scheduled to enter their 4th 10 Year Interval on December 2, 2017, at which time Revision 2 of Regulatory Guide 1.192 will be approved through Rulemaking (scheduled for March 1, 2017) and River Bend Station will apply the-condition for use of OMN-18 as currently listed in DG-1297.

The basis for this change is that a quarterly Group A pump test, performed at the CPT flow rate provides more consistent data for trending than a Group A test in conjunction _.

with a biennial CPT. The increased requirements imposed by the proposed. alternative

  • on the parameters to be monitored during every quarterly pump test and the more accurate instruments allow River Bend Station to perform better trending of pump performance data due to the more consistent requirements for each of the quarterly tests. Also, combined with more trending information since the pump is tested quarterly, the overall performance is monitored more consistently.
5. Proposed Alternative and Basis for Use River Bend Station proposes that in lieu of the CPT requirements of Table ISTB-3400-1, Group A tests will be performed quarterly within +/- 20 percent of the pump design flow rate, with pressure* measuring instrumentation meeting the (+/- 1/2%) instrument accuracy requirements of Table ISTB-3510-1 specified for the .biennial Comprehensive Test. In addition, River Bend Station has elected to restrict the upper limit for differential pressure to 6%, in accordance with the proposed Condition imposed within proposed Revision 2 of Regulatory Guide 1.192. The upper end values of the Group A Test Acceptance Ranges for flow and differential pressure (or discharge pressure) will be 1.06Qr and 1.06f1Pr, respectively, as applicable to the pump type. The high values of the Required Action Ranges for flow and differential pressure (or discharge pressure) will be

>1.06Qr and 1.06f1Pr, respectively, as applicable to the pump type. This condition

RBS, River Bend Station 10 CFR 50.55a Relief Request Number PRR-RBS-2017-2 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety would continue once Revision 2 of Regulatory Guide 1.192 is issued in 2017. River Bend Station will use OMN-18, as published in the 2012 Edition, which is also based.on the listing within proposed Revision 2 of Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code".

Vibration testing will continue to be performed under the proposed modified Group A test and the acceptance criteria for vibration will be the same as required for the Group A .

tests as shown in Table ISTB-5100-1.

Using the provisions of this relief request as an alternative to those specified in ISTB-5123 will provide a~equate indication of pump performance, permit consistent detection of component degradation, and continue to provide an acceptable level of quality and safety.

('

Therefore, pursuant to 10 CFR 50.55a(z)(1 ), River Bend Station requests relief from the specific ISTB requirements identified in this request.

6. Duration of pr~posed Alternative This relief is requested for the fourth ten year IST interval, which begins December 2, 2017 and is scheduled to end on December 1, 2027.
7. Precedent Use of an alternative was granted to Perry Nuclear Power Plant, Unit 1, Relief Request PR-3 for the 3rd 10-Year Interval Pump and Valve lnservice Testing Program (TAC No.

ME0820) (ML092640690)

Use of an alternative was granted to St. Lucie Unit Nos. 1 and 2, Relief From the Requirements of the ASME Code, Relief Request No .. 9 {TAC No. ME5190 and ME5191) (ML11143A077)

Use of an alternative was granted to South Texas Project, Units 1 and 2, Relief Requests No. VRR-01, PRR-01, PRR-02 and PRR-03 for the Third 10-Year lnservice Testing Program Interval (TAC No. ME3515, ME3516, ME3517, ME3518, ME3519, ME3520, ME3521, and ME3522) (ML 10215077)

Use of an alternative was granted to PSEG Salem Nuclear Generating Station/.._, (Salem),

Unit Nos. 1 and 2, (TAC NOS. ME7938 and ME7939) (ML12185A162) July 11, 2012

Attachment 3 RBG-47737 RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(~)

Acceptable Level of Quality and Safety

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RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z}(1)

Acceptable Level of Quality and Safety

1. American Society of Mechanical Engineers (ASME) Code Component(s} Affected Valve ID Function Cateaorv Class B21.,RVF041 A MAIN STEAM LINE A PRESSURE RELIEF B/C 1 VALVE .

B21-RVF041 B MAIN STEAM LINE B AUTO DEPRESSURIZATION B/C 1 SYSTEM PRESSURE RELIEF VALVE B21-RVF041C MAIN STEAM LINE C AUTO DEPRESSURIZATION B/C .... 1 SYSTEM PRESSURE RELIEF VALVE B21-RVF041 D MAIN STEAM LINED AUTO DEPRESSURIZATION B/C 1 SYSTEM PRESSURE RELIEF VALVE B21-RVF041 F MAIN STEAM LINE B AUTO DEPRESSURIZATION B/C 1 SYSTEM PRESSURE RELIEF VALVE B21-RVF041 G MAIN STEAM LINE C PRESSURE RELIEF VALVE B/C 1 B21-RVF041 L MAIN STEAM LINE C PRESSURE RELIEF VALVE B/C' 1 B21-RVF047A MAIN STEAM LINE A AUTO DEPRESSURIZATION B/C 1 SYSTEM PRESSURE RELIEF VALVE B21-RVF047B MAIN STEAM LINE B PRESSURE RELIEF VALVE B/C. 1 B21-RVF047C MAIN STEAM LINE C AUTO DEPRESSURIZATION B/C 1 SYSTEM PRESSURE RELIEF VALVE B21-RVF047D MAIN STEAM LINED PRESSURE RELIEF VALVE B/C 1 B21-RVF047F MAIN STEAM LINE B PRESSURE RELIEF VALVE B/C 1 B21-RVF051 B MAIN STEAM LINE B PRESSURE RELIEF VALVE B/C 1 B21-RVF051 C MAIN STEAM LINE C PRESSURE RELIEF VALVE B/C 1 B21-RVF051 D MAIN STEAM LINED PRESSURE RELIEF VALVE B/C 1 B21-RVF051G MAIN STEAM LINE C AUTO DEPRESSURIZATION B/C 1 SYSTEM PRESSURE RELIEF VALVE

Description:

River Bend Station (RBS), SRVs, Crosby Model HB-65-DF.

Component/System Function:

The Main Steam Safety/Relief (MSSR) System provides Reactor Pressure Vessel (RPV) overpressure protection and automatic depressurization of the Nuclear System by opening the Safety/Relief Valves (SRVs). RBS USAR Section 5.2.2 describes the three main protection functions of the SRVs:

Overpressure r.elief operation - The valves open automatically to limit a vessel pressu_re excursion during a postulated pressurization transient event.

Overpressure safety function - The valves function as safety valves and open to prevent reactor vessel overpressurization.

Depressurization operation - The Automatic Depressurization System

RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety (ADS) valves open automatically as part of the emergency core cooling system (ECCS), or can be operated manually for events involving small breaks in the nuclear system process barrier.

The valves must open in order to prevent over-pressurization of the* reactor coolant system thereby preventing failure of the reactor system due to overpressure. The overpressure relief operation is self-actuated (Safety Mode). The val~es will open automatically on receipt of a signal to limit a pressure rise (Relief Mode).

Seven (7) of, the sixteen (16) SRVs are a d~signated part of the ADS Emergency Core Cooling System (ECCS) and must open to provide automatic reactor depressurization as a result of a small break .in the nuclear system for which the high pressure injection system cannot maintain reactor water level (ADS function).

I In additio~ to the above, five (5) of the sixteen (16) SRVs are designated as part of the SRV Low-Low Set System. This system logic is called the Low-

. Low Set Relief logic.

  • Each protection function of the SRVs is to limit Reactor Coolant Pressure Boundary (RCPB) pressurization during upset conditions, with the exception of ADS. ADS functions to rapidly depressurize the reactor vessel to enable injection by the low pressure ECCS systems. The relief mode setpoints are lower than the safety mode set pressures to ensure sufficient margin between anticipated relief mode closing pressures and valve spring forces of the safety mode for proper seating ~f the valves ~pon receiving a close signal.

USAR Chapter 15.2 discusses the events which are expected to activate the SRVs.

2. Applicable ASME Code Edition and Addenda ASME OM Code-2004 Edition, with Addenda through and including ASME OMb Code-2006.
3. Applicable Code Reguirement(s)

Appendix I,. Paragn;1ph l-1320(a), 5-Year Test Interval, specifies that Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each interval; a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval.

This 20% shall consist of valves that have not been tested during the current

RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptabl_e Level of Quality and Safety 5-year interval, if they exist. The test interval for any individual valve shall not exceed 5 years.

4. Reason for Request

The Crosby Model HB-65-DF SRVs have*shown 13xemplary test history at RBS, as described in Table 2. Ho\l\fever, given the current 24-month operating cycle for RBS, Entergy Operations Incorporated (EOI) is required to remove and test fifty percent of the SRVs every refueling outage (i.e. eig~t of 16), so that all valves are removed and rtested every two refueling outages. This ensures compliance with the ASME OM Code requirements for testing Class 1 pressure relief valves within a 5-year interval. Approval of extending the test interval to 6 years with a grace period of 6 months would reduce the minimum number of SRVs tested at RBS over three refueling outages by eight.

The ASME Code' committees have developed Code Case OMN-17, "Alternative R~les for Testing ASME Class 1 Pressure Relief/Safety Valves" which was published via ASME OM Code-2009 Edition. This

  • Code Case has not been approved fpr use in US NRC Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 1, dated August 2014. The Code Case allows the Owner to extend the test frequencies for Class 1 pressure relief valves to a 72-month (6-year) test interval providing all the requirements of the Code Case are satisfied. The .

Code applicability specified in the Code Case is, 'in part; ASME OM Code 2001 Edition through the 2006 Addenda of Appendix I, Section 1-1320. This*

is consistent with the Interval Code of record for RBS. RBS currently meets or exceeds all the requirements specified in Code Case OMN-17. The Code Case OMN-17, is listed in the Draft Regulatory Guide DG-1297 (Proposed Revision 2 to Regulatory Guide 1.192, dated March 2016), and is listed in Table 1, Acceptable OM Code Cases, and as per 10 CFR 50.55a llcensees or applicants are to implement the most recent version of a Code Case. River Bend is using OMN-17, as published in the 2012 Edition of the ASME OM Code.

All SRVs are located in the upper elevations1 of the RBS Drywell. The major contributors to radiation exposure ar_e the Main Steam Lines, including the SRVs, and the High Pressure/Low Pressure Core Spray lines passing through the area. Removal of an *installed SRV and installation of a replacement SRV requires installation of scaffolding, removal of insulation and various appurtenances on the SRV, and unbolting the- SRV. Once

" unbolted, the SRV is maneuvered from its location and lowered to the grade

RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety , 1 elevation and transported through the drywall and containment equipment hatches. Each SRV weighs approximately 3000 pounds, and due to its size, a crew of five to seven personnel is necessary to safely move each valve:

Entergy has evaluated the historical cumulative radiation exposure at RBS for removal and replacement of SRVs from the last five RBS refueling outages. The work evolutions necessary to remove and replace these valves each refueling outage, which includes the removal and replacement of eight SRVs, are conducted under equivalent radiological conditions and with the

'Same personnel requirements. This historical cumulative radiation exposure data is provided in Table 1.

Table 1 Cumulative Radiation Exposure Outage RF-17 RF-16 RF-15 RF-14 RF-13

  1. SRV's 8 8 8 8 8 Replaced.

Person-Rem 4.178 3.192 6.494 4.026 5.872 Based on this data, Entergy has concluded. that the expected cumulative radiation exposure to remove and replace a single SRV would be approximately 0.594 person-rem. The outage -specific variability of cumulative radiation exposure is attributed to the location of a particular valve relative to higher radiation fields, the physical configuration of surrounding equipment for a particular valve, and the impact of outage..;specific plant configurations.

Therefore, absent the requested relief, replacement of eight incremental SRVs would result in approximately 4. 752 additional person-rem over three refueling outages.

5. Proposed Alternative and Basis for.Use As an alternative to the Code required 5-year test interval per Appendix I, paragraph l-1320(a), RBS proposes that the.Class 1 pressure reli~f valves be tested at least once every three. refueling cycles (approximately 6 years/72 months) With a minimum Of 20% of the valves tested within any 24-month interval. This 20% would consist of valves that have not been tested during the current 72-month interval, if they exist. The test interval for any individual valve would not exceed 72 months .except that a 6-month grace period is allowed to coincide with refueling outages to accommodate extended shutdown periods.

After as-found set pressure testing, the valves shall be disassembled and inspected to verify that parts are free of defects resulting from time-related degradation or service induced wear. As-left set pressure testing shall be

RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordancewith 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety performed following maintenance and prior to returning the valve to service.

Each valve shall have been disassembled and inspected prior to the start of the 72 month interval. Disassembly and inspection performed prior to the implementation of Code Case OMN-17 may be used.

The relief valve testing and maintenance cycle at RBS consists of removal of the SRV, complement requiring testing and transportation to an off-site test facility. Upon receipt at the off-site facility the valves are subject to an as-tound inspection, seat leakage and set pressure testing. Prior to the return of a complement of SRVs for installation in the plant, the valves are disassembled and inspected to verify that internal surfaces and parts are free from defects or service induced wear prior to the start of the next test interval. During this process, anomalies or damage are identified and resolved. Damaged or worn parts, springs, gaskets and seals are replaced as necessary. The valve seats are lapped, if necessary. Following reassembly, the valve's set pressure is recertified with an acceptance criterion of +/-1 %. This existing process is in accordance with ASME OM Code Case OMN-17, Paragraphs (d) and (e).

RBS has reviewed the as-found set pressure test results for all of the SRVs tested since 2008 as detailed in Table 2. RBS has had only one as-found test failure since 2008 that exceeded the as-found acceptance criteria (+3%, -5% ).

The one as-found failure was in the negative (or conservative) direction.

TABLE 2 Summary of As-Found Test Re.suits of SRV's Valve ID Set As-Found As-Found Test Results N63800-02-0046 1210 2-8-2008 1157 -4.4 N63800-02-0045 1205 2-8-2008 1167 -3.2 N63800-02-0117 1210 2-8-2008 1138 -6.0 N63800-02-0037 1195 2-9-2008 1208 +1.1 N63800-02-0044 1205 2-9-2008 1199 -0.5 N63800-02-0100 1205 2-9-2008' 1202 -0.2 N63800-02-0036 1195 2-10-2008 1201 +0.5 N63800-02-0034 1195 2-10-2008 1211 +1.3 N63800-02-0098 1205 10-1-2009 1203 -0.2 N63800-02-0109 1195 10-1-2009 1170 -2.1 N63800-02-0121 1210 10-2-2009 1198 -1.0 N63800-02-0120 1210 10-2-2009 1164 -3.8 N63800-02-0097 1205 10-3-2009 1162 -3.6 N63800-02-0112 1195 10-3-2009 1183 -1.0 N63800-02-0111 1195 10-4-2009 1188 -0.6 N63800-02-0040 1195 10-4-2009 1154 -3.4 N63800-02-0035 -1195 1-25-2011 1189 -0.5 N63800-02-0033 1195 1-25-2011 1193 -0.2 N63800-02-0038 1195 1-26-2011 1205 +0.8

RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

- Acceptable Level of Quality and Safety TABLE 2 Summary of As-Found Test Results of SRV's (continued)

Valve ID Set As-Found As-Found Test Results N63800-02-0118 1210 1-26-2011 1156 -4.5 N63800-02-0115 1210 1-27-2011 1221 /-

+0.9 N63800-02-0041 -1205 1-27-2011 1203 -0.2 N63800-02-0043 1205 1-28-2011 1217 +1.0 N63800-02-0042 1205 1-28-2011 1211 +0.5 N63800-02-0110 1195 2-28-2013 1194 -0.1 N63800"'.02-0107 1195 2-28-2013 1181 -1.2 N63800-02-0095 1205 3-1-2013 1177 -2.3 N63800-02-0106 1195 3-1-2013 1193 -0.2 N63800-02-0081 - 1205 3-2-2013 1190 . -1.2 N63800-02.:0039 1195 3-2-2013 1185 -0.8 N63800-:02-0117 1210 3-3-2013 1205 -0.4 N63800-02-0046 1210 3-3-2013 1219 t0.7 RBS submits that the proposed alternative of increasing the test interval for the Class 1 pressure relief valves from 5 years to 3 fuel cycles (approximately 6 years/72 months) would continue to provide an acceptable level of quality and .safety while re!?toring the operational and maintenance flexibility that was lost when the 24-morith fuel cycle created the unintended consequences of more frequent testing. This proposed alternative will continue to provide assurance of the valves' operational readiness and provides an acceptable .

level of quality and safety pursuant to 10 CFR 50.55a(z)( 1).

6. Duration of proposed Alternative This relief is requested for the fourth ten-year IST interval, which begins December 2, 2017 and is scheduled to end on December 1, 2027.
7. Precedent

( .

In Reference 2, the NRC reviewed and approved relief -requests for both Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2 to extend their main steam safety valve (MSSV) test interval duration to 6.5 years for the remainder of the fourth 10-year lnservice Testing interval.

In Reference 3, the NRC reviewed and approved a relief request for Susquehanna Steam Electric Station (SSES), Units 1 and 2 to extend the MSSV test interval duration to six years for the entire third 10-year lnservice Testing interval.

\

In Reference 4, the NRC reviewed and approved a relief request for Nine Mile Point Nuclear Power Station, Unit 2 (NMP2) to extend the MSSV test interval

\

RBS, River Bend Station 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

' Acceptable Level of Quality and Safety

. duration to three refueling outages or* approximately six years for the entire third 10-year lnservice Testing interval.

In Reference 5, the NRC 'reviewed and approved a relief request for Clinton Power Station to extend the SRV test interval duration to three refueling outages or approximately 6.5 years for the remainder of the second 10-year lnservice Testing interval. '

  • In Reference 6, the NRC reviewed and approved a relief request for Monticello Nuclear Generating Station to extend the SRV test interval duration to three refueling outages or approximately 6 years, with a 6 month grace period, for the duration of the Fifth 10-year lnservice Testing interval.

This proposed relief request is consistent with the precedents, ir:i that it will establish a test interval that would enable EOI to maintain a Crosby Model.

HB-65-DF SRV in service for three operating cycles, while also allowing adequate time to transport, test, and refurbish SRVs, at an external facility prior to reinstallation. This relief was granted by the NRC in 2015 for the 3rd lnservice Test Plan Interval at River Bend Station.

8. References
1. Code Case OMN-17, Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves, as_published in the 2012 Edition of the ASME OM Code.
2. Letter from U. S. NRC to Mr. Charles G. Pardee (Exelon Generation Company, UC), "Dresden Nuclear Power Station Units 2 and 3 - Relief Request No. RV-02C from 5-year Test lntervar for Main Steam Safety Valves TAC Nos. MD8150 and MD8151) and Quad Cities Nuclear Power Station, Units 1 and 2 - Relief Requests No. RV-30E and RV-30F from 5-year test interval for Main Steam Safety Valves {TAC Nos. MD6682, MD6683, MD8241, and MD8242}," dated June 27, 2008.
3. Letter from U. S. NRC to Mr. B. L. Shriver (PPL Susquehanna, LLC},

"Susquehanna Steam Electric Station Units 1 and 2 ..:Third ,10-year Interval lnservice Testing (IST) Program Plans (TAC Nos. MC3382, MC3383, MC3384, MC3385, MC3386, MC3387, MC3388, MC3389, MC4421, MC4422)," dated March 10, 2005.

4. Letter from U. S. NRC to Mr. J. H. Mueller (Niagara Mohawk Power Corporation), "Nine Mile Point Nuclear Power Station, Unit No. 2 -

Alternative to American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Regarding lnservice Testing of Main Steam Safety/Relief Valves (TAC No. MB0290)," dated April 17, 2001 ..

RBS, River Bend S~ation 10 CFR 50.55a Relief Request Number VRR-RBS-2017-1 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)

Acceptable Level of Quality and Safety

5. Letter from U.S. NRC to Mr. Charles G. Pardee (Exelon Generating Company LLC) "Clinton Power Station Unit NO. 1" - Request for relief from ASME OM Code 5-Year Test Interval for Safety Relief Valves (TAC NO. ME0044) dated August 26, 2009. ,
6. Letter from U.S. NRC to Mr. Mark A. Schimmel (Northern States Power Company) "Monticello Nuclear Power
  • Plant" - Relief from the Requirements* of the Americar society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for the Fifth 1o:..

Year lnservice testing Program Interval (TAC Nos. ME8067, ME8088, ME8089, ME8090, ME8091, ME8092, ME8093, ME8094, ME8095, and ME809).

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