ML20113A579

NRR E-mail Capture - Draft RAI North Anna Fifth 10-year Interval Relief Request (L-2020-LLR-0023)

ML20113A579
Person / Time
Site:	North Anna
Issue date:	04/21/2020
From:	Ed Miller NRC/NRR/DORL/LPL2-1
To:	Aitken D Dominion Generation
References
L-2020-LLR-0023
Download: ML20113A579 (4)

Text

From: Miller, Ed Sent: Tuesday, April 21, 2020 3:50 PM To: diane.aitken@dominionenergy.com Cc: craig.d.sly@dominionenergy.com

Subject:

Draft RAI North Anna Fifth 10-year Interval Relief Request (L-2020-LLR-0023)

Attachments: North Anna fifth 10year interval RAIs.docx

Diane, Attached is the NRC staffs draft RAI for the subject relief request. The questions are being transmitted to you to determine 1) If the question clearly conveys the NRC information needs, 2)

Whether the regulatory basis for the question is clear, and 3) If the information has already been provided in existing docketed correspondence. Additionally, review of the draft question will allow you to determine whether you are able to support a 30 day response time. Thank you.

Ed Miller (301) 415-2481

Hearing Identifier: NRR_DRMA Email Number: 543 Mail Envelope Properties (MN2PR09MB5963730D9B706C855A6FE7B4E9D50)

Subject:

Draft RAI North Anna Fifth 10-year Interval Relief Request (L-2020-LLR-0023)

Sent Date: 4/21/2020 3:50:20 PM Received Date: 4/21/2020 3:50:00 PM From: Miller, Ed Created By: Ed.Miller@nrc.gov Recipients:

"craig.d.sly@dominionenergy.com" <craig.d.sly@dominionenergy.com>

Tracking Status: None "diane.aitken@dominionenergy.com" <diane.aitken@dominionenergy.com>

Tracking Status: None Post Office: MN2PR09MB5963.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 527 4/21/2020 3:50:00 PM North Anna fifth 10year interval RAIs.docx 36928 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION (RAI)

DOMINION ENERGY VIRGINIA NORTH ANNA POWER STATION UNITS 1 AND 2 FIFTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM DOCKET NOS. 50-338 AND 50-339

References:

Letter from Mark D. Sartain of Dominion Energy Virginia to NRC, Inservice Testing Program Plan for Pumps, Valves, and Snubbers Fifth 10-Year Interval Update for Units 1 and 2 Request for Alternatives to Requirements of ASME OM Code, dated January 22, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20024F137).

Paragraph (f), Preservice and inservice testing requirements, of Section 55a, Codes and standards, in Part 50, Domestic Licensing of Production and Utilization Facilities, to Title 10, Energy, of the Code of Federal Regulations (10 CFR 50.55a(f)), states, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.

RAI EMIB-1 The licensee states that Request P-1 is intended to obtain NRC authorization to implement Code Case OMN-22, Smooth Running Pumps, for specific pumps at North Anna Units 1 and 2.

In describing the implementation of Code Case OMN-22, Request P-1 specifies: If the measured parameters are outside the normal operating range or are determined by analysis to be trending toward an unacceptable degraded state, appropriate actions are taken that may

[emphasis added] include:

Increased monitoring to establish rate of change, Review of component specific information to identify cause, and Removal of the pump from service to perform maintenance.

The NRC staff does not consider these provisions in Request P-1 to be consistent with the guidance in Code Case OMN-22.

For example, Code Case OMN-22 states: If a PdM Supplemental Monitoring activity identifies a parameter outside the normal operating range or identifies a trend toward an unacceptable degraded state, action shall be taken [emphasis added] to (1) identify and document the condition in the corrective action program established in accordance with the Owner's Quality Assurance Program, (2) increase monitoring to establish the rate of change of the monitored parameter, (3) review component-specific information to identify the degradation cause, (4) develop a plan to remove the pump from service to perform maintenance prior to significant performance degradation, and (5) address potential common cause issues applicable to other pumps based on the results of the analysis of the specific pump performance.

The NRC staff requests that the licensee describe its intent to implement the provisions of Code Case OMN-22 with respect to corrective actions, or provide justification for its planned approach.

RAI-EMIB-2 The licensee states that Request P-2 issubmitted under 10 CFR 50.55a(z)(1), Acceptable level of quality and safety. However, Section 5.0, Proposed Alternatives and Bases, of Request P-2 specifies: Using these provisions of the relief request as an alternative to the specific requirements of ISTB-3400 and Table ISTB-3400-1 identified above, which have been identified to be impractical, will provide adequate indication of pump performance.

The NRC regulations in 10 CFR 50.55a(f)(5)(iii), IST program update: Notification of impractical IST Code requirements, state: If the licensee has determined that conformance with certain Code requirements is impractical for its facility, the licensee must notify the Commission and submit, as specified in §50.4, information to support the determination.

The NRC staff requests that the licensee explain the basis for submitting Request P-2 under 10 CFR 50.55a(z)(1) rather than 10 CFR 50.55a(f)(5)(iii).

RAI-EMIB-3 In Request S-1, the licensee proposes to implement ASME OM Code Case OMN-13 (Revision 2), Performance-Based Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants, as part of its application of the 2012 Edition of the ASME OM Code in the Fifth Interval of its IST Program. On March 16, 2020, the Federal Register (85 FR 14736) reported the modification of 10 CFR 50.55a to incorporate by reference NRC Regulatory Guide (RG) 1.192 (Revision 3), Operation and Maintenance Code Case Acceptability, ASME OM Code, (ADAMS Accession No. ML19128A261), which accepts the use of Code Case OMN-13 (Revision 2) where implemented in accordance with Table 2, Conditionally Acceptable OM Code Cases. Based on this update to the NRC regulations, licensees may implement Code Case OMN-13 (Revision 2) without submitting an alternative request where the Code Case is implemented in accordance with RG 1.192 (Revision 3). Please advise if you prefer that the NRC staff continue to review Request S-1 and prepare a safety evaluation, or if you prefer to withdraw Request S-1.

RAI-EMIB-4 The Fifth 10-year IST Interval Update includes several Station Technical Positions for the IST Program at North Anna Units 1 and 2. Some of those technical positions appear to involve deviations from the provisions of the ASME OM Code or the conditions in 10 CFR 50.55a. For example, Technical Position No. TP-04, Obturator Verification, indicates that the obturator verification interval might apply the leak test interval allowed by 10 CFR Part 50, Appendix J, and extend beyond the 2-year interval specified in paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, Subsection ISTC. Please describe the bases for specifying these planned activities as technical positions, and not as deviations from the ASME OM Code or 10 CFR 50.55a conditions. As appropriate, please submit requests for relief from or alternatives to the ASME OM Code or 10 CFR 50.55a conditions, in accordance with 10 CFR 50.55a, for those technical positions that involve deviations from the OM Code or 10 CFR 50.55a conditions.