ML051390107
| ML051390107 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/13/2005 |
| From: | Vanderheyden G Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML051390107 (3) | |
Text
George Vanderheyden Vice President Calvert Cliffs Nuclear Power Plant Constellation Generation Group, LLC 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.4455 410.495.3500 Fax I
Constellation Energy May 13, 2005 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
Document Control Desk Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Supplementary Information Regarding a Request for Approval to Implement a Portion of the ASME OM Code, 1995 Edition, and the 1996 and 1997 Addenda for Check Valve [n-service Testing
REFERENCE:
(a) Letter from Mr. G. Vanderheyden (CCNPP) to Document Control Desk (NRC), dated January 27, 2005, 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 By letter dated January 27, 2005 (Reference a), Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP) requested 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 IO CFR 50.55a(b)(3).
Specifically, CCNPP requested 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 10 CFR 50.55a(b)(3)(iv). The purpose of this letter is to provide supplementary information requested by the NRC staff during a telecon, on April 26, 2005.
Requested Information 1:
Provide a more detailed description of your implementation plan to achieve 100% compliance wvith the bidirectional testing requirementfor all IST finservice testing] check valves.
Response
As stated in Reference (a), the bulk of IST check valves at CCNPP have been bi-directionally tested for several years. All of the check valves that are not currently tested in both directions are tested in the open direction, and none have a significant failure history. The check valves that are not already subject to bi-directional testing can be grouped into three categories:
- a.
Check valves that can be tested on-line (approximately 5 check valves per Unit).
- b.
Check valves that can only be tested during shut down conditions (approximately 12 check valv per Unit) 7 0;4
Document Control Desk May 13, 2005 Page 2
- c.
Check valves that can not be tested in the closed direction for which radiographic examination is the best option to verify valve closure (approximately 14 check valves per Unit).
The implementation plan for bi-directional testing of these check valves is:
- 1.
All necessary procedure revisions and initial bi-directional testing of all Unit I and Unit 2 check valves not already subject to bi-directional testing that can be tested online will be completed by December 2005.
- 2.
All necessary procedure revisions for all Unit I and Unit 2 check valves not already subject to bi-directional testing that can be tested only during shut down conditions will be completed prior to the 2006 Unit I refueling outage (February-March 2006).
- 3.
Initial bi-directional testing of all Unit I check valves not already subject to bi-directional testing that can only be tested during shut down conditions will be completed during the 2006 Unit I refueling outage (February-March 2006).
- 4.
Initial bi-directional testing of all Unit 2 check valves not already subject to bi-directional testing that can only be tested during shut down conditions will be completed during the 2007 Unit 2 refueling outage (February-March 2007).
- 5.
All necessary procedures required to support radiographic examination of those check valves not already subject to bi-directional testing that can not be tested in the closed direction will be completed by January 2006.
- 6.
Baseline radiographic examination of those check valves not already subject to bi-directional testing that can not be tested in the closed direction will be accomplished as follows:
- a.
Baseline radiographic examination of Unit I check valves located in areas where radiation fields are higher during on-line operation (approximately two check valves) will be performed during the 2006 Unit I refueling outage.
- b. Baseline radiographic examination of Unit 2 check valves located in areas where radiation fields are higher during on-line operation (approximately two check valves) will be performed during the 2007 Unit 2 refueling outage.
- c.
Baseline radiographic examination of Unit I and Unit 2 check valves located in areas where radiation fields are lower during on-line operation (approximately 12 check valves per Unit) will be started after the 2006 Unit I refueling outage and continue until completed, except during the 2007 Unit 2 refueling outage, with all baseline radiographic examinations completed by December 2007.
Therefore, approval of our phased implementation of Subsection ISTC is requested as soon as possible to allow our implementation plan to proceed on the schedule above.
Document Control Desk May 13, 2005 Page 3 Requested Information 2:
Consider implementing the 1998 Edition of ISTCM with the 1999 and 2000 Addenda, and as modified in 10 CFR 50.55a(b)(3)(iv), in lieu of the 1995 Edition of ISC, with the 1996 and 1997,Addenda.
Response
Calvert Cliffs Nuclear Power Plant, Inc. has revisited the requirements contained in the 1998 Edition of ISTC through the 2000 Addenda. As discussed during our telecon on April 26, 2005, there are no substantial differences when compared to the 1995 Edition of ISTC, with the 1996 and 1997 Addenda.
Additionally, there are also no substantial differences in the modifications to the Code requirements contained in 10 CFR 50.55a(b)(3)(iv).
Therefore, CCNPP amends Reference (a) to implement the 1998 Edition of ISTC through the 2000 Addenda, including the limitations and modifications identified in 10 CFR 50.55a(b)(3)(iv) and listed below:
A. Valve opening and closing functions must be demonstrated when flow testing or examination methods (nonintrusive, or disassembly and inspection) are used; B. The initial interval for tests and associated examinations may not exceed two fuel cycles or three years, whichever is longer; any extension of this interval may not exceed one fuel cycle per extension with the maximum interval not to exceed ten years; trending and evaluation of existing data must be used to reduce or extend the time interval between tests; C. Not applicable for the 1998 Edition through the 2000 Addenda.
D. The provisions of ISTC-3510, JSTC-3520, and JSTC-3540 in addition to ISTC-5221 must be implemented if the Appendix 11 condition monitoring program is discontinued.
Should you have questions regarding this matter, please contact Mr. L. S. Larragoite at (410) 495-4922.
Very truly you s, GV/GT/bjd cc:
R. V. Guzman, NRC Resident Inspector, NRC S. J. Collins, NRC R. l. McLean, DNR