ML050330102
| ML050330102 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/27/2005 |
| From: | Vanderheyden G Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML050330102 (3) | |
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.4 George Vanderheyden 1650 Calvert Cliffs Parkway Vice President Lusby, Maryland 20657 Calvert Cliffs Nuclear Power Plant 410.495.4455 Constellation Generation Group, LLC 410.495.3500 Fax Constellation Energy January 27, 2005 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Request for Approval to Implement a Portion of the ASME OM Code, 1995 Edition, and the 1996 and 1997 Addenda for Check Valve In-service Testing Pursuant to the provisions of 10 CFR 50.55a(f)(4)(iv), Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP) requests approval to implement the requirements set forth in subsequent editions and addenda of the American Society of Mechanical Engineers (ASME) Code that are incorporated by reference in Paragraph 50.55a(b)(3). Specifically, CCNPP requests approval to implement Subsection ISTC of the 1995 Edition, and the 1996 and 1997 Addenda of the ASME Code for the Operation and Maintenance (OM) of Nuclear Power Plants for check valve testing, including the limitations and modifications identified in Paragraph 50.55a(b)(3)(iv).
Calvert Cliffs is committed to the 1987 Edition, and the 1988 Addenda, of the OM Code for in-service testing. Paragraph 50.55a(f)(4)(iv) states in-service tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in Paragraph 50.55a(b),
subject to the identified limitations and modifications, and subject to Commission approval.
Paragraph 50.55a(f)(4)(iv) further states portions of the editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The OM Code currently incorporated by reference in Paragraph 50.55a(b)(3) is the 1995 Edition through the 2003 Addenda.
As required by Subsection ISTC of the 1995 Edition, and the 1996 and 1997 Addenda, of the OM Code, and Paragraph 50.55a(b)(3)(iv), CCNPP commits to implement bi-directional testing for all check valves in the in-service testing program in accordance with the implementation plan provided below. Calvert Cliffs also commits to implement a condition monitoring program for selected check valves per Appendix II of the OM Code, as allowed by ISTC-4.5.5, including the limitations and modifications identified in Paragraphs 50.55a(b)(3)(iv) and listed below.
A. Valve opening and closing functions shall be demonstrated when flow testing or examination methods (non-intrusive, or disassembly and inspection) are used; B. The initial interval for tests and associated examinations shall not exceed two fuel cycles or three years, which ever is longer; any extension of this interval shall not exceed one fuel cycle per
Document Control Desk January 27, 2005 Page 2 extension with the maximum interval not to exceed ten years; trending and evaluating of existing data shall be used to reduce or extend the time interval between tests; C. If the Appendix II Check Valve Condition Monitoring Program is discontinued, then the requirements of ISTC 4.5.1 through 4.5.4 shall be implemented.
The purpose of the check valve condition monitoring program is to improve valve performance and/or to optimize testing, examination, and preventive maintenance activities in order to maintain the continued acceptable performance of selected check valves and selected groups of check valves.
Current State of CCNPP Check Valve In-service Testing Calvert Cliffs' in-service testing program includes 134 Unit I check valves, 128 Unit 2 check valves, and 2 common check valves.
- All check valves that have safety functions in both the open and closed direction are tested/exercised in both directions as required by the current Code of Record.
- Many of check valves that have a safety function in only one direction are already tested/exercised in both directions.
- There are approximately 33 check valves per Unit that have a safety function in only one direction and are tested/exercised in only one direction, which will require upgrades/revisions to the applicable surveillance test procedures to implement bi-directional testing. Approximately eight of these check valves in each Unit are currently included in test procedures that are capable of detecting valve failure in both directions, but the surveillance test procedures require upgrading. Approximately seven of these check valves in each Unit can be incorporated into existing surveillance test procedures with line-up changes that are a little more extensive in nature. The remaining check valves in each Unit will require new surveillance test procedures and will likely require use of non-intrusive technology, such as acoustics or radiography.
Of the check valves that are not yet subject to bi-directional testing, none have a significant failure history. Therefore, the effort needed to develop the test procedures and procure new instrumentation and test equipment would unnecessarily delay the benefits associated with implementing a check valve condition monitoring program. Calvert Cliffs requests approval to phase in the implementation of bi-directional testing for the remaining check valves on the schedule given below.
Proposed Implementation Plan Calvert Cliffs' Fourth Ten-Year in-service testing interval will begin in January 2008. All requirements of the 1995 Edition and 1996 and 1997 Addenda shall be completed no later than the beginning of the Fourth Ten-Year in-service testing interval. Implementation of the necessary Code requirements only for check valves will be phased in based on the following schedule.
- The minor test procedure upgrades will be completed by June 2006;
- The more extensive test procedure revisions that require changes to test line-ups will be completed by December 2006; and
- The new surveillance test procedures shall be completed by December 2007.
In parallel with these activities, Calvert Cliffs will also be implementing the check valve condition monitoring program.
Document Control Desk January 27, 2005 Page 3 Should you have questions regarding this matter, we will be pleased to Very tr1 Y91p VTe GV/GT/bjd them with you.
cc:
S. L. Miller, Esquire J. E. Silberg, Esquire R. V. Guzman, NRC S. J. Collins, NRC Resident Inspector, NRC R. I. McLean, DNR