ML20156A287
| ML20156A287 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/04/2020 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 20-173 | |
| Download: ML20156A287 (9) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 June 4, 2020 Serial No.:
NRA/ENC:
Docket Nos.:
License No.:
20-173 RO 50-338 50-339 NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)
NORTH ANNA POWER STATION UNITS 1 AND 2 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated January 22, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20028D492), Virginia Electric and Power Company (Dominion Energy Virginia) submitted the North Anna Power Station Units 1 (NAPS1) and 2 (NAPS2) lnservice Testing (1ST) Programs for Pumps, Valves, and Snubbers for the fifth 10-year 1ST interval beginning on December 15, 2020 for both units.
10 CFR 50.55a(a}(1)(iv) refers to the American Society of Mechanical Engineers (ASME)
Code for Operation and Maintenance of Nuclear Power Plants (OM Code}, 2012 Edition.
The most recent revision to the ASME OM Code became effective on August 17, 2017 and applies to the fifth 10-year 1ST interval for NAPS1 and NAPS2. The 1ST Programs for both units were updated to incorporate the most recent revision to the ASME OM Code. Included in the updated 1ST Programs submitted for the fifth 10-year interval were seven relief requests requiring Nuclear Regulatory Commission (NRC) review and approval before implementation.
By email dated April 21, 2020, NRC staff indicated that additional information was necessary to complete their review of the requested alternatives (ML20113A579).
Dominion Energy Virginia held a clarification conference call with NRC staff on May 5, 2020. The NRC requested a response to their request for additional information (RAI) by June 4, 2020. The Enterprise Project Identifier (EPID} referenced for this request is L-2020-LLR-0023.
Dominion Energy Virginia's response to the NRCs RAI is contained in the Enclosure to this letter.
Serial No.: 20-173 Docket Nos.: 50-338/339 Page 2 of 3 Please contact Erica N. Combs at 804-273-3386 if you have any questions regarding this submittal.
Sincerely,
~
Mark D. Sartain Vice President - Nuclear Engineering & Fleet Support
Enclosure:
Response to NRC Request for Additional Information Commitments made by this letter: None
References:
- 1. Letter from Dominion Energy Virginia to NRC, "North Anna Power Station Units 1 and 2 lnservice 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. [ADAMS Accession No. ML20028D492]
- 2. Letter from NRC to Dominion Energy Virginia, "Draft RAI North Anna Fifth 10-Year Interval Relief Request L-2020-LLR-0023)," dated April 21, 2020. [ADAMS Accession No. ML20113A579]
cc:
Regional Administrator, Region II (w/o attachments)
U. S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue, NE, Suite 1200 Atlanta, GA 30303-1257 Mr. G. E. Miller Senior Project Manager - North Anna Power Station U.S. Nuclear Regulatory Commission Mail Stop 09 E-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Marcus Harris (w/o attachments)
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Boulevard, Suite 300 Glen Allen, VA 23060 NRC Senior Resident Inspector (w/o attachments)
North Anna Power Station Serial No.: 20-173 Docket Nos.: 50-338/339 Page 3 of 3
Serial No.: 20-173 ENCLOSURE 1 Response to NRC Request for Additional Information Virginia Electric and Power Company (Dominion Energy Virginia}
North Anna Power Station Unit 1 and Unit 2
Serial No.: 20-173 Docket Nos.: 50-338/339 RAI Response for Fifth 10-Year 1ST Interval Enclosure, Page 1 of 5 Response to Request for Additional Information Related to North Anna Power Station Units 1 and 2 Fifth 10-Year Interval lnservice Testing Program By letter dated January 22, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20028D492), Virginia Electric and Power Company (Dominion Energy Virginia) submitted the North Anna Power Station Units 1 (NAPS 1) and 2 (NAPS2) lnservice Testing (1ST) Programs for Pumps, Valves, and Snubbers for the fifth 10-year 1ST interval beginning on December 15, 2020 for both units.
10 CFR 50.55a(a)(1 )(iv) refers to the American Society of Mechanical Engineers (ASME)
Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2012 Edition.
The most recent revision to the ASME OM Code became effective on August 17, 2017 and applies to the fifth 10-year 1ST interval for NAPS1 and NAPS2. The 1ST Programs for both units were updated to incorporate the most recent revision to the ASME OM Code. Included in the updated 1ST Programs submitted for the fifth 10-year interval were seven relief requests requiring Nuclear Regulatory Commission (NRC) review and approval before implementation.
By email dated April 21, 2020, NRC staff indicated that additional information is necessary to complete their review of the requested alternatives (ML20113A579). Dominion Energy Virginia held a clarification conference call with NRC staff on May 5, 2020. The NRC requested a response to their request for additional information (RAI) by June 4, 2020.
The Enterprise Project Identifier (EPID) referenced for this request is L-2020-LLR-0023.
The NRC questions and Dominion responses are provided below.
- 1. NRC RA/ Question No.1 The licensee states that Request P-1 is intended to obtain NRG 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,
Serial No.: 20-173 Docket Nos.: 50-338/339 RAI Response for Fifth 10-Year 1ST Interval Enclosure, Page 2 of 5 Review of component specific information to identify cause, and Removal of the pump from service to perform maintenance."
The NRG 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 [Predictive Maintenance]
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 NRG 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.
Dominion Energy Response North Anna will follow the guidance provided in Code Case OMN-22. 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 to:
(1) Identify and document the condition in the corrective action program established in accordance with North Anna'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
Serial No.: 20-173 Docket Nos.: 50-338/339 RAI Response for Fifth 10-Year 1ST Interval Enclosure, Page 3 of 5 (5) Address potential common cause issues applicable to other pumps based on the analysis of the specific pump performance.
- 2. NRC RA/ Question No. 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 NRG regulations in 10 CFR 50.55a(f)(5)(iii), "/ST program update: Notification of impractical /ST 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 NRG 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).
Dominion Energy Response Upon further review North Anna concurs with the NRC Staff's assessment of the content in Request P-2 and requests that it be submitted under 10 CFR 50.55a(f)(5)
(iii). A comparable request was previously submitted under 10 CFR 50.55a(f)(5)
(iii), reviewed and approved in support of the 4th 1ST Program testing interval.
- 3. NRC RA/ Question No. 3 In Request S-1, the licensee proposes to implement ASME OM Code Case OMN-13 (Revision 2), "Performance-Based Requirements for Extending Snubber lnservice 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 /ST Program. On March 16, 2020, the Federal Register (85 FR 14736) reported the modification of 10 CFR 50.55a to incorporate by reference NRG 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
Serial No.: 20-173 Docket Nos.: 50-338/339 RAI Response for Fifth 10-Year 1ST Interval Enclosure, Page 4 of 5 Acceptable OM Code Cases." Based on this update to the NRG 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 NRG staff continue to review Request S-1 and prepare a safety evaluation, or if you prefer to withdraw Request S-1.
Dominion Energy Response Following the publication of Regulatory Guide 1.192, Revision 3, North Anna prefers to withdraw Request S-1.
- 4. NRC RA/ Question No. 4 The Fifth 10-year /ST lnteNal Update includes several Station Technical Positions for the /ST 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 inteNal might apply the leak test inteNal allowed by 10 CFR Part 50, Appendix J, and extend beyond the 2-year inteNal specified in paragraph /STC-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 1 O 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.
Dominion Energy Response TP-04 was originally authored based on the wording of the 10 CFR 50.55(a) paragraph (b)(3)(xi) condition as proposed in draft NUREG-1482, Revision 3. The final wording of paragraph {b)(3)(xi) differs from that issued in draft NUREG-1482, Revision 3. TP-04 will be revised such that it meets the requirements of {b)(3)(xi) as published in the CFR.
The fifth interval 1ST program plans for North Anna Unit 1 and Unit 2, which include the technical positions referenced in RAI EMIB-4, were provided to the NRC for information purposes to facilitate review of the associated request for alternatives to requirements of the ASME OM Code, 2012 edition.
North Anna recognizes the
Serial No.: 20-173 Docket Nos.: 50-338/339 RAI Response for Fifth 10-Year 1ST Interval Enclosure, Page 5 of 5 regulatory program plan reviews performed during development of the fifth interval Safety Evaluation do not invoke a requirement to seek prior NRG approval of future program plan revisions provided that those changes are bounded by ASME OM Code of record and CFR requirements.