ML20196L826
| ML20196L826 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/14/2020 |
| From: | Barnette J Vistra Operating Co. (VistraOpCo) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20196L876 | List: |
| References | |
| Download: ML20196L826 (7) | |
Text
001 CPNPP IST Relief Request Text Attachment Relief Request Application for IST Relief Request
- 1. Title of Project RELIEF REQUEST V INSERVICE TESTING (IST)
- 2. Licensee Vistra Operations Company LLC (Vistra OpCo)
- 3. Licensee Contact JIm Barnette
- 4. Licensee Contact Phone Number 254-897-5866
- 5. Licensee Contact Email Address James.barnette@luminant.com
- 6. Plant Identification Number 227551
- 7. Plant Name Comanche Peak Nuclear Power Plant (CPNPP)
- 8. Plant Units Unit 1
- 9. Docket Numbers 50-445
- 10. License Numbers NPF-87
- 11. Requested Completion Date August 14, 2020
Select 10 CFR 50.55a(z)(2) IST
- 13. Proposed Alternative Number or Identifier:
V-3
- 14. Applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, or ASME Operations and Maintenance (OM) Code, Edition and Addenda:
American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through the 2006 Addenda (Ref. 1)
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001 CPNPP IST Relief Request Text Attachment
IST Program Third Interval Start Date: August 3, 2013 End Date: August 2, 2023
- 16. ASME Code Class ASME Class 2 & 3
- 17. Applicable Components and or System Description (if applicable):
See attachment, Table 1 Inservice Tests Requested for Deferral to 1RF22.
- 18. Describe the Applicable Code Requirements:
The Code of Federal Regulations, Title 10, Part 50, Section 55a, Codes and standards, requires United States nuclear power plants to follow the requirements of ASME OM Code. This requirement is mandated in paragraph (b), which states in part:
Use and conditions on the use of standards. Systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the requirements of the ASME BPV Code and the ASME OM Code as specified in this paragraph (b).
ISTA-3120, Inservice Test Interval, subparagraph (a), which states:
The frequency for inservice testing shall be in accordance with the requirements of Section IST.
ISTC-5221, Valve Obturator Movement, (c)(3), which states, for check valves:
At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in each group shall be disassembled and examined at least once every 8 years.
Mandatory Appendix I, Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants, paragraph I-1320, Test Frequencies, Class 1 Pressure Relief Valves, subparagraph (a), which states:
5-Year Test Interval. Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval. This 20% shall consist of valves that have not been tested during the current 5-year interval, if they exist. The test interval for any individual valve shall not exceed 5 years.
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001 CPNPP IST Relief Request Text Attachment Mandatory Appendix I paragraph I-1350, Test Frequency, Classes 2 and 3 Pressure Relief Devices, subparagraph (a), which states:
10-year Test Interval. Classes 2 and 3 pressure relief valves, with the exception of PWR main steam safety valves, shall be tested every 10 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested during any single plant operating cycle; however, a minimum of 20% of the valves from each valve group shall be tested within any 48-month interval. This 20% shall consist of valves that have not been tested during the current 10-year test interval, if they exist.
The test interval for any individual valve shall not exceed 10 years. PWR main steam safety valves shall be tested in accordance with I-1320.
- 19. Reason for Request:
The U.S. Federal Government made a COVID-19 declaration of emergency pursuant to the Stafford Act on March 13, 2020. The U.S. Center for Disease Control (CDC) determined that COVID-19 poses a serious public health risk. In the state of Texas, where CPNPP is located, a Major Disaster Declaration was declared on March 25, 2020, to take actions necessary to reduce exposure to the virus associated with the COVID-19 outbreak. Although many of the state restrictions have been lifted or reduced, the CDC has indicated that many U.S. States could experience another increased surge in the spread of the virus again this Fall.
The (CDC) continues to recommend social distancing and the use of masks as it applies to COVID-19. The CDC defines social distancing as "remaining out of congregate settings, avoiding mass gatherings, and maintaining distance (approximately 6 feet or 2 meters) from others when possible."
In response to the COVID-19 Pandemic and to comply with CDC guidance, Vistra Operations LLC (Vistra OpCo) established the following guidelines and restrictions that remain in effect at Comanche Peak Nuclear Power Plant (CPNPP):
- 1. Employees who do not have a critical need to be at CPNPP facilities must work remotely.
- 2. Employees who must work from a CPNPP facility are to practice strict social distancing.
- 3. 1RF21 Outage scope shall be reduced to limit the number of supporting contract personnel.
These guidelines and restrictions were established to eliminate the potential of inadvertently spreading the COVID-19 virus to critical personnel who are necessary to complete 1RF21 refueling outage activities, return the unit safely to service, and to maintain the unit operational to meet its power demands along with the surrounding community.
A large concern with spreading the virus focuses on outside specially trained and qualified resources who perform work to supplement the small CPNPP staff during outages. The concerns associated with outside resources consists of the risk of their availability either due to the potential for travel restrictions and quarantine requirements imposed by both the U.S. Government and the State of Texas making it extremely difficult to travel from out of state to site, or because of illness. Bringing contract personnel on site with unknown medical history and their potential exposure to COVID-19 virus increases the risks of infecting the CPNPP personnel with COVID-19 virus. It is an extreme hardship for CPNPP to quarantine incoming contractors for sufficient durations to ensure they are free of COVID-19 virus symptoms or to conduct adequate testing of all contractors for COVID-19 virus. However, without these safeguards, the Page 3 of 7
001 CPNPP IST Relief Request Text Attachment CPNPP staff and surrounding community are at increased risk of contracting COVID-19 virus, which has the potential of affecting the outage and future operation of the station.
Additionally, in general, work during outages tends to be in close spaces and does not allow for social distancing which can be a large contributor towards the spread of the virus as well.
Many of the planned 1RF21 Outage activities are being postponed until future outages based on the above guidelines, restrictions and concerns such that compliance with the applicable code requirements for inspection and testing results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current and future concerns related to the pandemic. Testing and inspections mandated by the Code of Federal Regulations in Title 10, Part 50, Section 55a, (10CFR50.55a) cannot be postponed without prior NRC approval.
Due to the COVID-19 virus pandemic and in an effort to comply with CDC guidance, Vistra OpCo is requesting this one-time relief associated with performing certain check valve and relief valve testing. This relief request demonstrates that there is reasonable assurance that the operational readiness of each identified valve will be maintained through the next refueling outage currently scheduled for the spring of 2022 (1RF22). The technical justification utilizes available detailed data from the most recent valve test, and a review of the maintenance history for each valve. This provides the technical justification necessary to show that the proposed alternative is acceptable, and that deferral of the testing in 2020 will not result in an adverse consequence to safety.
- 20. Brief Description of the Proposed Alternative (500 characters or less):
Vistra OpCo proposes one-time relief from ASME OM Code requirements to support deferral of testing to the next refueling outage. As an alternative to:
- 1. ISTC-5221(c)(3), defer the disassembly examination of specific check valves.
- 2. I-1350(a), extend the interval of specific relief valve tests to 11 years and the minimum group test interval to 54 months.
- 3. I-1320(a), extend the interval of specific safety valve tests to 6 years and the minimum group test interval to 36 months.
- 21. Full Description of the Proposed Alternative:
Proposed Alternative Vistra OpCo is requesting this one-time relief associated with performing the identified valve examination or testing activities in accordance with 10 CFR 50.55a(z)(2) on the basis that compliance results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current pandemic due to COVID-19 outbreak. Vistra OpCo proposes this one-time relief from the following ASME OM Code requirements and proposes alternative testing as follows:
- 1. The ISTC-5221(c)(3) requirement to disassemble and examine at least one valve from each group at each refueling outage for specific CPNPP, Unit 1, check valves and to alternatively defer the disassembly examination to the next refueling outage currently scheduled for the spring of 2022 (1RF22).
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001 CPNPP IST Relief Request Text Attachment
- 2. The I-1350(a) requirement to test specific Class 2 and 3 pressure relief valves every 10 years and to alternatively extend the interval to 11 years so that the specific relief valve test may be deferred to the next refueling outage currently scheduled for the spring of 2022 (1RF22).
- 3. The I-1350(a) requirement to test a minimum of 20% of the valves from each relief valve group within any 48-month interval for specific CPNPP, Unit 1, relief valve groups and to alternatively extend the interval to 54-months for specific CPNPP, Unit 1, relief valve groups so that the specific relief valve tests may be deferred to the next refueling outage currently scheduled for the spring of 2022 (1RF22).
- 4. The I-1320(a) requirement to test specific PWR Class 2 Main Steam Safety Valves (MSSVs) every 5 years and to alternatively extend the interval to 6 years so that the specific MSSV tests may be deferred to the next refueling outage currently scheduled for the spring of 2022 (1RF22).
- 5. The I-1320(a) requirement to test a minimum of 20% of the valves from each valve group within any 24-month interval for specific CPNPP, Unit 1, MSSVs and to alternatively extend the interval to 36-months for specific CPNPP, Unit 1, MSSVs so that the specific valve tests may be deferred to the next refueling outage currently scheduled for the spring of 2022 (1RF22).
In the event that CPNPP, Unit 1, has an extended shutdown prior to 1RF22, and the US, State, and/or Local Government has relaxed the pandemic restrictions, then a good faith effort to test the valves that were deferred from 1RF21 during the unplanned shutdown will be made in a similar manner as is expected for cold shutdown exercise testing.
An evaluation was performed for each check valve and pressure relief valve identified in the Table 1 attachment to this RR that utilized detailed data from the most recent examination or test, and a review of the maintenance history for each valve. This evaluation concluded that the proposed alternative is acceptable, and that deferral of the specific valve testing in 2020 to the next refueling outage in the spring of 2022 will not result in an adverse consequence to safety. No deficiencies, adverse trends or open maintenance work orders were identified that would impact or degrade each valves performance capability and exclude it from this interval extension RR. Each valve in the scope of this RR is currently on a standard testing interval with acceptable performance. None of the valve test or examination intervals have been extended on the basis of their Risk Rank. Considering the valves current acceptable performance, there is reasonable assurance that each valve will be operationally ready to perform its safety function for the duration of this RR.
In summary, extending the testing interval for each valve in the scope of this RR to the next refueling outage scheduled for the spring of 2022 (1RF22) would not adversely impact the function of the valve or result in a reduction in plant safety. In the current pandemic environment, performing the required tests would result in an increased risk of virus exposure to plant personnel and a reduction in occupational health and safety without a compensating benefit. Therefore, this one-time request for relief meets the criteria in 10 CFR 50.55a(z)(2) for proposing testing alternatives on the basis that compliance results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current COVID-19 pandemic.
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001 CPNPP IST Relief Request Text Attachment
- 22. If needed, include additional information for Question 21:
- 23. Description of the Basis for Use:
An evaluation was performed for each check valve and pressure relief valve identified in the Table 1 attachment to this RR that utilized detailed data from the most recent examination or test, and a review of the maintenance history for each valve. This evaluation concluded that the proposed alternative is acceptable, and that deferral of the specific valve testing in 2020 to the next refueling outage in the spring of 2022 will not result in an adverse consequence to safety. No deficiencies, adverse trends or open maintenance work orders were identified that would impact or degrade each valves performance capability and exclude it from this interval extension RR. Each valve in the scope of this RR is currently on a standard testing interval with acceptable performance. None of the valve test or examination intervals have been extended on the basis of their Risk Rank. Considering the valves current acceptable performance, there is reasonable assurance that each valve will be operationally ready to perform its safety function for the duration of this RR.
- 24. If needed, include additional information for Question 23:
- 25. If requesting an alternative based on 10 CFR 50.55a(z)(2), describe hardship or unusual difficulty without compensating increase in the level of quality and safety associated with compliance with applicable code requirement. For requests under 10 CFR 50.55a(z)(1), leave this section blank.
On March 13, 2020, President Donald Trump declared the Coronavirus (COVID-19) pandemic a national emergency. In addition, Texas Governor Greg Abbott declared a state of disaster due to the COVID-19 pandemic on March 25, 2020. The U.S. Center for Disease Control (CDC) has determined that COVID-19 poses a serious public health risk. The CDC identified the majority of U.S. states reporting community spread of COVID-19. Currently CPNPP is operating in accordance with the CPNPP Pandemic Response Guideline. Due to the COVID-19 pandemic, there is a desire to minimize the potential of inadvertently spreading the COVID-19 virus to CPNPP personnel from outside contractors who perform examinations and testing for the IST program. Due to the potential spread of COVID-19 to CPNPP personnel, Vistra OpCo has identified performance of these examinations and testing as a hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(z)(2). As an alternative, Vistra OpCo is proposing to extend the examination and testing interval for one refueling cycle from fall 2020 (1RF21) to spring 2022 (1RF22).
These examinations and tests in the Unit 1 IST program are delineated by American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) sections ISTC-5221(c)(3), I-1320(a), and I-1350(a).
- 26. Proposed duration of the alternative:
The proposed alternative, upon approval, will be implemented at CPNPP, Unit 1, starting from 1RF21, which is scheduled to begin on October 18, 2020, through the end of refueling outage 1RF22, which is scheduled to begin in the spring of 2022.
- 27. Include any additional information, as necessary:
- 28. Precedents (optional):
The NRC verbally authorized a similar alternative request pursuant to 10 CFR 50.55a(z)(2) for Vistra Operations Company, LLC, to use at Comanche Peak Nuclear Power Plant, Unit 2, via Verbal Authorization by the NRC Office of Nuclear Reactor Regulation for 10 CFR 50.55a Request V-2, Revision 0, Check Valve Page 6 of 7
001 CPNPP IST Relief Request Text Attachment Examination Interval Extension, Docket No. 50-446 (EPID I-2020-LLR-0061), and Verbal Authorization by the NRC Office of Nuclear Reactor Regulation for 10 CFR 50.55a Request V-2, Revision 0, Relief Valve Test Interval Extension, Docket NO. 50-446 (EPID I-2020-LLR-0062) dated April 9, 2020. (ML20099D059)
Similar relief from the requirements of 10 CFR 50.55a(z)(2) was verbally authorized by the NRC for Exelon Generation Company, LLC, to use at Limerick Generating Station, Unit 1, via Verbal Authorization by the NRC Office of Nuclear Regulation for Relief Request GVRR-9 Associated with Pandemic-Related Issues -
Inservice Testing Interval Extension Motor-Operated Valves, Docket No. 50-352 (EPID L-2020-LLR-0046),
dated March 31, 2020. (ML20090A652)
- 29.
References:
- 1. American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through the 2006 Addenda
- 2. 10CFR50.55a, Code and standards, June 3, 2020.
- 30. Do you have attachments?
Yes
- Table 1 Inservice Tests Requested for Deferral to 1RF22 Page 7 of 7