Letter Sequence Approval |
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EPID:L-2020-LLR-0046, Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves (Approved, Closed) |
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MONTHYEARML20089A0082020-03-29029 March 2020 Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves Project stage: Request ML20092L8532020-03-31031 March 2020 Email Limerick Generating Station, Unit 1 (LGS) - MOVs Relief Request Verbal Authorization Related to COVID-19 Issues Project stage: Approval ML20090A6522020-03-31031 March 2020 Verbal Authorization of Relief Request GVRR-9 Project stage: Approval ML20090B4102020-06-0202 June 2020 Issuance of Relief Request GVRR-9 Associated with Pandemic-Related Issues - Inservice Testing Interval Extension for Motor Operated Valves (EPID L-2020-LLR-0046 (COVID-19)) Project stage: Approval 2020-03-31
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Category:E-Mail
MONTHYEARML24026A2922024-01-26026 January 2024 Request for Additional Information Regarding Limerick Digital Instrumentation and Controls License Amendment Request ML23331A0062023-11-22022 November 2023 (External Sender) Supplement - Limerick Security Rule Exemption Request ISFSI Docket No. Reference ML23311A2412023-11-0707 November 2023 NRR E-mail Capture - NRC Notification to the Commonwealth of Pennsylvania Re. Limerick Generating Station, Units 1 and 2 Amendment - Control Room Ventilation System Technical Specifications ML23304A0192023-10-30030 October 2023 NRR E-mail Capture - Final RCI - Constellation Energy Generation, LLC - Limerick 1 & 2 - Exemption from Security Rule (L-2023-LLE-0026) ML23276B4642023-10-0303 October 2023 NRR E-mail Capture - NRC Request for Additional Information Limerick TSTF-477 LAR ML23255A2872023-09-12012 September 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Alternative to Use the Successive Inspection Requirements of BWRVIP-75-A ML23248A1282023-09-0101 September 2023 NRR E-mail Capture - Action: Opportunity to Review and Comment on a New NRC Information Collection, 10 CFR Part 50.55a, Codes and Standards (3150-XXXX) ML23237B3972023-08-24024 August 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Alternative Request to Use Updated BWRVIP Guidelines ML23208A1942023-07-27027 July 2023 NRR E-mail Capture - Limerick Generating Station - Audit Plan for TSTF-477 LAR Review (L-2022-LLA-0174) ML23202A0682023-07-21021 July 2023 NRR E-mail Capture - NRC Request for Additional Information Re. TSTF-477 LAR ML23201A1262023-07-18018 July 2023 Additional RAIs for Limerick Generation Station, Units 1 and 2 - LAR and Exemption Request for Digital I&C Installation Support ML23173A0632023-06-20020 June 2023 RAIs for Limerick Generation Station, Units 1 and 2 - LAR and Exemption Request for Digital I&C Installation Support ML23102A1642023-04-12012 April 2023 Generation Station, Unit No. 2 Potential Emergent Relief Request for HPCI IST (EPID L-2023-LLR-0015) - Closure E-mail Dated 4/12/2023 ML23125A0522023-03-31031 March 2023 NRR E-mail Capture - Clean OL Pages for 50.69 LAR ML23089A1602023-03-30030 March 2023 NRR E-mail Capture - NRC Notification to the Commonwealth of Pennsylvania Re. Limerick Generating Station, Units 1 and 2 Amendment - Alternative 10 CFR 50.69 Categorization Approaches ML23086B9282023-03-27027 March 2023 Acceptance of Requested Licensing Action for License Amendment Request to Support Digital Modernization Project Installation ML23086A0822023-03-27027 March 2023 Acceptance of Requested Licensing Action for Exemption Request to Support Digital Modernization Project Installation ML22354A2622022-12-20020 December 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Request to Use Certain Provisions of the 2019 Edition of the ASME BPV Code, Section XI ML23060A1662022-12-20020 December 2022 Acceptance Review: Adopt TSTF-477, Revision 3-Acceptance Letter ML22200A0782022-07-19019 July 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request to Use Honeywell Mururoa V4F1 R Supplied Air Suits ML22172A0752022-06-17017 June 2022 Response: Review and Feedback on Draft Limerick Digital License Amendment Request (L-2020-LRM-0041) ML22136A0032022-05-13013 May 2022 NRR E-mail Capture - NRC Request for Additional Information - Limerick License Amendment Request (L-2021-LLA-0042) ML22124A2862022-05-0404 May 2022 Information Needed to Provide Substantive Feedback on Human Factors Engineering Supporting the Planned Limerick Digital I&C License Amendment Request ML22089A1172022-03-30030 March 2022 Additional Comments and Questions on Constellation'S March 31st Presentation ML22112A2152022-03-28028 March 2022 Limerick_Acceptance Review TS Change to Correct Nonconservative Technical Specification Table 3.3.3-1 ML22089A1162022-03-28028 March 2022 Comments and Questions on Constellation'S March 31st Presentation ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML22034A0142022-02-0202 February 2022 NRR E-mail Capture - Audit Plan Supplement for LIM 50.69 LAR (L-2021-LLA-0042) ML22028A1832022-01-24024 January 2022 NRR E-mail Capture - Audit Plan Supplement for LIM 50.69 LAR (L-2021-LLA-0042) ML22020A0642022-01-13013 January 2022 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles ML22005A1812022-01-0505 January 2022 NRR E-mail Capture - Staff'S Questions Pertaining to Limerick Generating Station Digital Modernization Project LAR Pre-submittal Meeting Slides December 7, 2021 ML21301A0672021-10-28028 October 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-541 ML21295A0362021-10-20020 October 2021 NRR E-mail Capture - Supplement to Limerick 50.69 Audit Plan Dated October 1, 2021 (L-2021-LLA-0042) ML21286A0302021-10-13013 October 2021 Staff'S Questions Pertaining to Limerick Generating Station Digital Modernization Project LAR Pre-submittal Meeting Slides October 20, 2021 ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21252A0482021-09-0707 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21215A3502021-08-0303 August 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-554 ML21154A0132021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0142021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0112021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21140A0842021-05-19019 May 2021 Acceptance of Requested Licensing Action Revision to Appendix C License Conditions in Accordance with the Requirements of 10 CFR 50.69 (E-mail) ML21117A0442021-04-26026 April 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21111A0312021-04-20020 April 2021 Application to Modify 50.69 Categorization to Implement an Alternate Defense-in-Depth Categorization Process, an Alternate Pressure Boundary Categorization Process, and an Alternate Seismic Tier 1 Categorization Process ML21084A2532021-03-24024 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Transfer Application ML21070A0062021-03-10010 March 2021 Acceptance Review to Adopt TSTF-205-A Revision of Calibration, Channel Functional Test, and Related Definitions ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) 2024-01-26
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From: Sreenivas, V To: Neff, David B:(Exelon Nuclear); Helker, David P:(Exelon Nuclear)
Cc: Greives, Jonathan; Patel, Jigar; Scarbrough, Thomas; Danna, James; Suber, Gregory; Farnan, Michael
Subject:
Limerick Generating Station, Unit 1 (LGS): MOVs Relief Request Verbal Authorization related to COVID-19 issues Date: Tuesday, March 31, 2020 1:57:00 PM Effective today, March 31, 2020, and as discussed in todays 12:00 pm call, the NRC staff communicated its verbal authorization to Exelon Generation (the licensee) for the following Relief Request:
By letter dated March 29, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20089A008), Exelon Generation (the licensee) proposed an alternative to specific requirements in the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code), for Limerick Generating Station, Unit 1 (Limerick Unit 1), pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a (10 CFR 50.55a).
Please see below the transcript of the NRC staffs verbal authorization. These are added to ADAMS as a publicly available official agency record, documenting the staffs aforementioned approval. The NRC staffs formal safety evaluation will be transmitted via separate correspondence. Please contact me if you have any questions regarding this licensing action.
The following link may not be available during a declaration waiting period. The transcript is also copied below for a quick reference.
View ADAMS Properties ML20090A652 Open ADAMS Document (Limerick Generating Station, Unit 1, Verbal Authorization of Relief Request GVRR-9 (EPID L-2020-LLR-0046))
If you have any questions, please contact me at (301) 415-2597 or V.Sreenivas@nrc.gov Docket Nos. 50-352 V. Sreenivas, Ph.D., CPM.,
Licensing Project Manager Limerick and Ginna Nuclear Plants Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation VERBAL AUTHORIZATION BY THE NRC OFFICE OF NUCLEAR REACTOR REGULATION FOR RELIEF REQUEST GVRR-9 ASSOCIATED WITH PANDEMIC-RELATED ISSUES - INSERVICE TESTING INTERVAL EXTENSION MOTOR-OPERATED VALVES LIMERICK GENERATING STATION, UNIT 1 EXELON GENERATION DOCKET NO. 50-352 MARCH 31, 2020 Technical Evaluation read by Thomas G. Scarbrough, Acting Chief, Mechanical Engineering and Inservice Testing Branch, Division of Engineering and External Hazards, NRC Office of Nuclear Reactor Regulation By letter dated March 29, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20089A008), Exelon Generation (the licensee) proposed an alternative to specific requirements in the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code), for Limerick Generating Station, Unit 1 (Limerick Unit 1), pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a (10 CFR 50.55a).
In particular, the licensee submitted Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves on March 29, 2020, requesting NRC authorization for a one-time Inservice Testing (IST) Program interval extension to the next refueling outage for diagnostic testing of 17 motor-operated valves (MOVs) at Limerick Unit 1. The licensee provided justification that compliance with the requirements in the ASME OM Code, Mandatory Appendix III, to conduct diagnostic testing of the specific MOVs at this time would result in a hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(z)(2).
In its alternative request, the licensee stated that the performance of diagnostic testing of the 17 specified MOVs at this time at Limerick Unit 1 would represent a hardship during this COVID19 outbreak, because performing the MOV diagnostic tests would require work in close spaces which could be detrimental to the occupational health and safety of plant personnel. To support its request for a one-time extension of the diagnostic testing interval for these MOVs until the next refueling outage in the spring of 2022, the licensee provided the calculated functional margin, after accounting for uncertainties and degradation factors, for each specific MOV based on the most current diagnostic test data. The licensees calculations indicate that each of the MOVs has a functional margin of at least 10 percent. The licensee reports that its evaluation in preparing the alternative request included a review of the maintenance history of each MOV. The licensee states that no deficiencies, adverse trends, or open maintenance work orders were identified that would impact or degrade the performance capability of these MOVs. The licensee reports that each MOV is undergoing the standard testing interval with acceptable performance. The licensee considers that the current acceptable performance and high functional margin supports reasonable assurance that each MOV will continue to be capable of performing its design function during the time interval of this alternative request.
Based on the information described above for the 17 specific MOVs at Limerick Unit 1 identified in the licensees submittal, the NRC staff finds that (1) previous diagnostic testing of those MOVs indicates their acceptable historical performance; (2) ongoing IST activities have not identified MOV performance concerns; (3) periodic maintenance activities will continue; and (4) a hardship exists for the performance of diagnostic testing of these MOVs at this time that would be contrary to the health and safety of plant personnel.
Therefore, the NRC finds that the licensees proposed alternative for a one-time extension of the diagnostic testing interval for the specified 17 MOVs at Limerick Unit 1 is acceptable. The proposed alternative will provide reasonable assurance that the MOVs will be operationally ready to perform their safety functions until the next refueling outage currently scheduled for the spring of 2022.
Authorization read by James Danna, Chief of the Plant Licensing Branch I, Office of Nuclear Reactor Regulation As Chief of the Plant Licensing Branch I, Office of Nuclear Reactor Regulation, I agree with the conclusions of the Mechanical Engineering and Inservice Testing Branch.
The NRC staff concludes that the proposed alternative will provide reasonable assurance that the MOVs will be operationally ready to perform their safety functions until the next refueling outage currently scheduled for the spring of 2022. The NRC staff finds that complying with the requirements of the ASME OM Code for diagnostic testing of the specified MOVs at Limerick Unit 1 at this time would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2).
Therefore, effective March 31, 2020, the NRC authorizes the use of the proposed alternative at Limerick Unit 1 until restart from the next refueling outage for Limerick Unit 1 in the spring of 2022. The licensees testing plans for these MOVs may be adjusted as appropriate by any subsequent NRC-authorized alternative requests.
All other ASME OM Code requirements as incorporated by reference in 10 CFR 50.55a for which relief or an alternative was not specifically requested and approved in this subject request remain applicable. If the licensee identifies a performance issue with any of these MOVs, the licensee will be expected to take action to implement the requirements of its technical specifications.
This verbal authorization does not preclude the NRC staff from asking additional clarification questions regarding the proposed alternative while subsequently preparing the written safety evaluation.
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