ULNRC-06035, CFR 50.55a(a)(3) Requests for Relief from ASME OM Code Pump and Valve Testing Requirements Regarding the Frequency of Inservice Tests

CFR 50.55a(a)(3) Requests for Relief from ASME OM Code Pump and Valve Testing Requirements Regarding the Frequency of Inservice Tests

ML13242A294
Person / Time
Site:	Callaway
Issue date:	08/29/2013
From:	Maglio S Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF2642, ULNRC-06035
Download: ML13242A294 (7)

Text

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~Ameren Callaway Plant MISSOURI August 29, 2013 ULNRC-06035 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.55a Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 10 CFR 50.55a(a)(3) REQUESTS FOR RELIEF FROM ASME OM CODE PUMP AND VALVE TESTING REQUIREMENTS REGARDING THE FREQUENCY OF INSERVICE TESTS (TAC NO. MF2642)

Pursuant to 10 CFR 50.55a(a)(3), Union Electric Company (Ameren Missouri) requests NRC approval of the attached relief request regarding the frequency of inservice tests performed pursuant to the ASME OM Code. The Code Edition and Addenda applicable to Callaway for the current (third) inservice testing interval, which began December 19, 2005, are ASME OM Code 2001 Edition through 2003 Addenda.

The attached request, identified as PR-07, is a request to allow extensions to component test frequencies established in the ASME OM Code, consistent with the provisions of Technical Specification Administrative Control (TS AC) 5.5.8, "Inservice Testing Program," and following the guidance of ASME OM Code Case OMN-20.

Although the requested relief is for all applicable pumps and valves subject to the OM Code test requirements identified in the attached relief request, the requested relief is needed to address an emergent issue concerning the testing of a relief valve in the "B" Safety Injection system at Callaway.

That is, the requested relief would prevent having to remove the affected system from service in order to perform a Code-required test prior to the current test interval being exceeded. Please be advised, therefore, that Ameren Missouri expects to promptly request verbal approval of the enclosed relief request following submittal of this written request (i.e., prior to September 3, 2013.)

Supporting information, including the justification for the request, is provided in the attached relief request.

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • PO Box 620 Fulton, MD 65251 AmerenMissouri.com

ULNRC-06035 August 29, 2013 Page 2 This letter does not contain new commitments.

Ifthere are any questions, please contact me at 573-676-8719 or J.P. Kovar at 314-225-1478.

Sincerely, LJ_A, Y\ ~

S.A.Ma~

Regulatory Affairs Manager JPK/nls

Attachment:

Relief Request PR-07

ULNRC-06035 August 29, 2013 Page 3 cc: Mr. Steven A. Reynolds Acting Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-06035 August 29, 2013 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

A. C. Heflin F. M. Diya C. 0. Reasoner III B.L.Cox L. H. Graessle S. A. Maglio Corporate Communications NSRB Secretary T. B. Elwood STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission

Attachment to ULNRC-0603 5 August 29, 2013 10 CFR 50.55a Request Number PR-07 Page 1 of 3 ReliefRequested In Accordance with 10 CFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety

1. ASME Code Components Affected Pumps and Valves contained within the lnservice Testing Program scope.

2. Applicable Code Edition and Addenda ASME OM Code 2001 Edition through 2003 Addenda

3. Applicable Code Requirement This request applies to the following frequency requirements of the ASME OM Code.

ISTA-3120(a)- "The frequency for the inservice testing shall be in accordance with the requirements of Section 1ST."

ISTB-3400- Frequency of lnservice Tests ISTC-3510- Exercising Test Frequency ISTC-3540- Manual Valves ISTC-3630(a)- Frequency ISTC-3700- Position Verification Testing ISTC-5221 (c)(3)- "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

Attachment to ULNRC-0603 5 10 CFR 50.55a Request Number PR-07 Page 2 of3 August 29, 2013 Appendix I, 1-1320- Test Frequencies, Class 1 Pressure Relief Valves Appendix I, 1-1330- Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Appendix I, 1-1340- Test Frequencies- Class 1 Pressure Relief Devices That Are Used for Thermal Relief Application Appendix I, 1-1350- Test Frequencies- Class 2 and 3 Pressure Relief Valves Appendix I, 1-1360- Test Frequencies- Class 2 and 3 Nonreclosing Pressure Relief Devices Appendix I, 1-1370- Test Frequencies- Class 2 and 3 Primary Containment Vacuum Relief Valves Appendix I, 1-1380- Test Frequencies- Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Appendix I, 1-1390- Test Frequencies- Class 1 Pressure Relief Devices That Are Used for Thermal Relief Application Appendix II, ll-4000(a)(1 )- Performance Improvement Activities Interval Appendix II, ll-4000(b)(1 )(e)- Optimization of Condition Monitoring Activities Interval

4. Reason for Request Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in the 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 Specifications (TS) Surveillance Requirements (SRs). The TS 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 (SR 3.0.2). However, regulatory issues have been raised concerning the applicability of the TS "grace period" to ASME OM Code required inservice test frequencies irrespective of allowances provided under TS Administrative Controls. (TS 5.5.8, "lnservice Testing Program," invokes SR 3.0.2 for various OM Code frequencies.)

Attachment to ULNRC-0603 5 10 CFR 50.55a Request Number PR-07 Page 3 of3 August 29, 2013 The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. The NRC recognized this potential issue in the TS, and it was addressed by allowing a frequency tolerance as specified in TS SR 3.0.2. The lack of a similar tolerance applied to 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 extending OM Code testing intervals.

Interval extension can 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). Such extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified.

5. Proposed Alternative and Basis for Use The proposed alternative is to allow extensions to ASME OM Code component test frequencies using ASME approved Code Case OMN-20, "lnservice Test Frequency."

6. Duration of Proposed Alternative The proposed alternative will be utilized for the remainder of the third 120-month 1ST Interval ending December 19, 2014.

7. Precedent A similar relief request (RV-01) has been approved for the Quad Cities Nuclear Power Station in NRC Safety Evaluation dated February 14, 2013.

8. References Letter from Joel S. Wiebe (U.S. NRC) to Mr. Michael J. Pacilio (Exelon Generation Co.),

"Quad Cities Nuclear Power Station, Units 1 And 2 - Safety Evaluation In Support Of Request For Relief Associated With The Fifth 10 Year lntervallnservice Testing Program,"

dated February 14,2013 NRC Regulatory Issue Summary 2012 "NRC STAFF POSITION ON APPLYING SURVEILLANCE REQUIREMENTS 3.0.2 AND 3.0.3 TO ADMINISTRATIVE CONTROLS PROGRAM TESTS ASME OM Code Case OMN "lnservice Test Frequency" Callaway TS Section 5.5.8- "lnservice Testing Program" CallawayTSSR3.0.2-SpecifiedFrequency(25%>GracePeriod)