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Category:Letter type:L
MONTHYEARL-24-233, Proposed Alternative Request to Defer ASME Code Section XI Inservice Inspection Examinations for Pressurizer and Steam Generator Pressure-Retaining Welds and Full Penetration Welded Nozzles2024-12-18018 December 2024
Proposed Alternative Request to Defer ASME Code Section XI Inservice Inspection Examinations for Pressurizer and Steam Generator Pressure-Retaining Welds and Full Penetration Welded Nozzles
L-24-259, ISFSI; Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI & Perry Nuclear Power Plant, Unit No. 1 ISFSI - Triennial ISFSI Decommissioning Funding Plan2024-12-17017 December 2024
ISFSI; Davis-Besse Nuclear Power Station, Unit No. 1 ISFSI & Perry Nuclear Power Plant, Unit No. 1 ISFSI - Triennial ISFSI Decommissioning Funding Plan
L-24-227, Response to Request for Additional Information for Relief Request RR-A 12024-11-20020 November 2024
Response to Request for Additional Information for Relief Request RR-A 1
L-24-188, Submittal of Quality Assurance Program Manual, Revision 302024-08-27027 August 2024
Submittal of Quality Assurance Program Manual, Revision 30
L-24-186, Response to RAI for Exemption Request from 10 CFR 50.71(e)(4) Final Safety Analysis Update Schedule2024-08-15015 August 2024
Response to RAI for Exemption Request from 10 CFR 50.71(e)(4) Final Safety Analysis Update Schedule
L-24-032, Cycle 23 and Refueling Outage 23 Inservice Inspection Summary Report2024-07-15015 July 2024
Cycle 23 and Refueling Outage 23 Inservice Inspection Summary Report
L-24-063, License Amendment Request to Remove the Table of Contents from the Technical Specifications2024-07-0808 July 2024
License Amendment Request to Remove the Table of Contents from the Technical Specifications
L-24-024, Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2024-06-19019 June 2024
Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models
L-23-214, Submittal of Relief Request for Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements2024-06-0505 June 2024
Submittal of Relief Request for Impractical American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI Examination Requirements
L-24-019, Unit No.1 - Report of Facility Changes, Tests, and Experiments2024-05-22022 May 2024
Unit No.1 - Report of Facility Changes, Tests, and Experiments
L-24-111, Response to Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations2024-05-15015 May 2024
Response to Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations
L-24-072, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report - 20232024-05-15015 May 2024
Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report - 2023
L-24-031, Unit No.1 - Steam Generator Tube Circumferential Crack Report - Spring 2024 Refueling Outage2024-05-14014 May 2024
Unit No.1 - Steam Generator Tube Circumferential Crack Report - Spring 2024 Refueling Outage
L-24-069, Occupational Radiation Exposure Report for Year 20232024-04-30030 April 2024
Occupational Radiation Exposure Report for Year 2023
L-24-018, Submittal of Core Operating Limits Report, Cycle 24, Revision 02024-04-16016 April 2024
Submittal of Core Operating Limits Report, Cycle 24, Revision 0
L-24-013, Annual Notification of Property Insurance Coverage2024-03-26026 March 2024
Annual Notification of Property Insurance Coverage
L-23-264, Request for Exemption from 10 CFR 50.71(e)(4) Final Safety Analysis Report Update Schedule2024-02-23023 February 2024
Request for Exemption from 10 CFR 50.71(e)(4) Final Safety Analysis Report Update Schedule
L-24-050, Retrospective Premium Guarantee2024-02-22022 February 2024
Retrospective Premium Guarantee
L-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023
Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station
L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023
Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
L-23-215, Changes to Emergency Plan2023-10-19019 October 2023
Changes to Emergency Plan
L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023
Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments
L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023
Quality Assurance Program Manual
L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023
Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments
L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023
Submittal of Fifth Ten Year Inservice Testing Program
L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023
2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models
L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023
Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations
L-23-065, Annual Financial Report2023-05-22022 May 2023
Annual Financial Report
L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023
Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022
L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023
Readiness for Resumption of NRC Supplemental Inspection
L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023
Occupational Radiation Exposure Report for Year 2022
L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023
Submittal of the Decommissioning Funding Status Reports
L-23-037, And Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023
And Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments
L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023
Annual Notification of Property Insurance Coverage
L-23-059, Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-0022023-03-0909 March 2023
Response to Apparent Violation in NRC Inspection Report 05000346/2022091; EA 23-002
L-22-212, CFR 50.55a Request RP-5 Regarding Inservice Pump Testing2023-03-0606 March 2023
CFR 50.55a Request RP-5 Regarding Inservice Pump Testing
L-23-048, Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2023-03-0101 March 2023
Response to Request for Additional Information Regarding Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report
L-23-057, Energy Harbor Nuclear Corp Retrospective Premium Guarantee2023-02-20020 February 2023
Energy Harbor Nuclear Corp Retrospective Premium Guarantee
L-22-253, Submittal of Pressure and Temperature Limits Report, Revision 52023-01-10010 January 2023
Submittal of Pressure and Temperature Limits Report, Revision 5
L-22-284, Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS)2022-12-28028 December 2022
Request for Notice of Enforcement Discretion for Technical Specification 3.7.9, Ultimate Heat Sink (UHS)
L-22-211, Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report2022-09-29029 September 2022
Technical Specification 5.6.6 Steam Generator Tube Inspection 180-Day Report
L-22-216, Submittal of Pressure and Temperature Limits Report. Revision 42022-09-27027 September 2022
Submittal of Pressure and Temperature Limits Report. Revision 4
L-22-213, Occupational Radiation Exposure Report for Year 2021 - Correction2022-09-23023 September 2022
Occupational Radiation Exposure Report for Year 2021 - Correction
L-22-194, Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events2022-09-19019 September 2022
Submittal of Supplemental Information for the Reanalysis for Protection Against Low Temperature Reactor Coolant System Overpressure Events
L-22-203, Submittal of Evacuation Time Estimates2022-09-12012 September 2022
Submittal of Evacuation Time Estimates
L-22-050, Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual2022-08-0909 August 2022
Summary of Changes to the Energy Harbor Nuclear Corp. Quality Assurance Program Manual
L-22-152, Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan2022-07-0505 July 2022
Response to Request for Additional Information Regarding a License Amendment Request That Revises the Davis-Besse Nuclear Power Station Emergency Plan
L-22-068, Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report2022-06-30030 June 2022
Cycle 22 and Refueling Outage 22 Inservice Inspection Summary Report
L-22-037, 2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2022-06-30030 June 2022
2021 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models
L-22-149, Post Accident Monitoring Report2022-06-23023 June 2022
Post Accident Monitoring Report
2024-08-27
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harbor Terry J. Brown Site Vice President, Davis-Besse Nuclear March 6, 2023 L-22-212 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, Licens~ No. NPF-3 Energy Harbor Nuclear Corp.
Davis-Besse Nuclear Power Station 5501 N. State Route 2 Oak Harbor, Ohio 43449 419-321-7676 10 CFR 50.55a 10 CFR 50.55a Request RP-5 Regarding lnservice Pump Testing In accordance with 1 O CFR 50.55a, Energy Harbor Nuclear Corp. hereby requests Nuclear Regulatory Commission (NRC) approval of enclosed 10 CFR 50.55a request RP-5 for the Davis-Besse Nuclear Power Station, Unit No. 1, fifth t~n-year inservice testing program for pumps and valves.
Request RP-5 proposes to perform the pump periodic verification test of high pressure injection pumps each refueling outage in lieu of biennially and reclassify the pumps from Group B to Group AB in order to include vibration test requirements during the quarterly pump tests.
Energy Harbor Nuclear Corp. requests approval of the request described above by March 29, 2024 to support the Davis-Besse Nuclear Power Station, Unit No. 1, fifth ten-year inservice testing program for pumps and valves.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager, Fleet Licensing, at (330) 696-7208.
Davis-Besse Nuclear Power Station L-22-212 Page 2
Attachment:
10 CFR 50.55a Request RP-5 cc: NRC Region III Administrator NRC Resident Inspector NRR Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board
Attachment L-22-212 10 CFR 50.55a Request Number: RP-5 (3 pages follow)
Attachment L-22-212 10 CFR 50.55a Request Number: RP-5 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)
Hardship or Unusual Difficulty Without a Compensating Increase in Level of Quality and Safety Page 1 of 3
- 1. ASME Code Components Affected Component Identification Group Class P58-1, High Pressure Injection Pump AB 2
P58-2, High Pressure Injection Pump AB 2
The High Pressure Injection (HPI) System provides emergency core cooling for small break loss of coolant accidents. Operating in conjunction with Low Pressure Injection and Core Flooding, the HPI limits core damage for a range of small break loss of coolant accidents.
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) for Operation and Maintenance of Nuclear Power Plants (OM Code), 2017 Edition.
- 3. Applicable Code and NRC Requirements 10 CFR 50.55a(f)(3)(iv)(A) IST Design and Accessibility Requirements: First Provision In facilities whose construction permit was issued before November 22, 1999, pumps and valves that are classified as ASME Code Class 2 and Class 3 must be designed and be provided with access to enable the performance of inservice testing of the pumps and valves for assessing operational readiness set forth in the editions and addenda of Section XI of the ASME Code incorporated by reference in paragraph (a)(1)(ii) of this section (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147, as incorporated by reference in paragraph (a)(3)(ii) of this section) applied to the construction of the particular pump or valve or the Summer 1973 Addenda, whichever is later.
ISTB-1400 Owner's Responsibility ISTB-1400(d) requires establishing a pump periodic verification test program in accordance with Division 1, Mandatory Appendix V.
The Owner shall establish a pump periodic verification test program for certain pumps tested in accordance with paragraph ISTA-1100. The requirements applicable to this request for relief in accordance with the
Attachment L-22-212 Page 2 of 3 requirements of 10 CFR 50.55a include paragraph ISTB-1400(d) whereas it is the responsibility of the Owner to establish a pump periodic verification test program in accordance with Mandatory Appendix V.
Table ISTB-3000-1 lnservice Test Parameters A Pump Periodic Verification Test is required for those pumps identified in Division 1, Mandatory Appendix V.
Table ISTB-3400-1 lnservice Test Parameters A Pump Periodic Verification Test is required Biennially for those pumps identified in Division 1, Mandatory Appendix V.
Mandatory Appendix V - V-3000 Mandatory Appendix V - V-3000 requires certain applicable pumps with specific design basis accident flow rates in the Owner's credited safety analysis (for example technical specifications, technical requirements program, or updated safety analysis report) for inclusion in this program.
4. Reason for Request
Relief is requested pursuant to 10 CFR 50.55a(z)(2) on the basis that the proposed alternative does provide an acceptable level of quality and safety and the current design for the HPI pumps does not allow for Energy Harbor to meet all the requirements of a Pump Periodic Verification Test at Davis-Besse Nuclear Power Station.
The high pressure injection pumps inject water into the reactor coolant system to mitigate the consequences of a loss-of-coolant accident. These pumps were originally categorized as Group B pumps since they are in a standby system that is not operated routinely except for testing. The ASME OM Code required testing for these high pressure injection pumps at a quarterly frequency for Group B pump test and a biennial comprehensive pump test. In order to achieve the necessary flow rate, without creating low temperature overpressure concerns, the high pressure injection pumps are lined up to discharge into the reactor coolant system with the reactor head removed and with water in the refueling canal. These plant conditions are established only during an outage in which a refueling occurs and are not typically established during a maintenance outage. These same plant conditions will be used to satisfy the Pump Periodic Verification Test requirements of Appendix V.
Table ISTB-3400-1 of the ASME OM Code, requires the pump periodic verification test to be performed biennially. Since the plant is on a 24-month fuel cycle, compliance with this requirement is normally achievable.
However, if the plant experiences maintenance shutdowns, the added time between refueling outages could jeopardize compliance with this testing requirement.
Attachment L-22-212 Page 3 of 3 Removal of the reactor head solely to perform the pump periodic verification test is a hardship since it would substantially increase the scope and duration of a maintenance shutdown and result in associated radiation exposure.
5. Proposed Alternative and Basis for Use
Pump periodic verification testing of the high pressure injection pumps will be performed each refueling outage instead of biennially. The classification for high pressure injection pumps will be changed from Group B to Group A in order to include, in addition to other provisions, vibration test requirements of ASME OM Code Paragraph ISTB-5121, "Group A Test Procedure," subparagraphs (d) and (e), with vibration acceptance criteria of ASME OM Code Table ISTB-5121-1, "Centrifugal Pump Test Acceptance Criteria," during the quarterly pump test. A Group B pump that is classified as a Group A pump for testing purposes is referred to herein as a Group AB pump.
Using the provisions of this relief request as an alternative to the requirements of ASME OM Code Table ISTB-3400-1, including the performance of comprehensive and pump periodic verification tests during refueling outages and Group A pump tests quarterly between refueling outages, provides reasonable assurance that the high pressure injection pumps are operationally ready. Removal of the reactor head solely to perform the comprehensive and pump periodic verification tests is a hardship since it would substantially increase the scope and duration of a maintenance shutdown and result in associated radiation exposure.
6. Duration of Proposed Alternative
The duration of the proposed alternative is the fifth 10-year inservice test interval that commences on April 2, 2023.
7. Precedents
A similar request was authorized by the Nuclear Regulatory Commission (NRC) staff for use during the fourth 10-year inservice test interval for Davis-Besse Nuclear Power Station. The letters authorizing the request are cited below.
"Davis-Besse Nuclear Power Station, Unit 1 - Safety Evaluation Concerning Comprehensive Pump Testing Relief Request (TAC NO. MF0756) (L-13-067),
dated March 31, 2014, (Accession No. ML14030A574).
