ML20272A013
| ML20272A013 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/07/2020 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Exelon Generation Co |
| Marshall M, NRR/DORL/LPLI, 415-2871 | |
| References | |
| EPID L-2020-LLR-0090 | |
| Download: ML20272A013 (5) | |
Text
October 7, 2020 LICENSEE: Exelon Generation Company, LLC FACILITY: Calvert Cliffs Nuclear Power Plant, Unit 2
SUBJECT:
SUMMARY
OF SEPTEMBER 3, 2020, MEETING WITH EXELON GENERATION COMPANY, LLC CONCERNING ALTERNATIVE REQUEST FOR SUPPLEMENTAL POSITION INDICATION TESTING INTERVAL (EPID L-2020-LLR-0090)
On September 3, 2020, a Category 1 public teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (the licensee). The purpose of the meeting was to discuss the timeliness of the Calvert Cliffs Nuclear Power Plant, Unit 2 (Calvert Cliffs 2), alternative request for the supplemental position indication (SPI) testing interval. The meeting notice and agenda, dated August 17, 2020, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20247J308. A list of attendees is enclosed. A copy of the licensees presentation is available in ADAMS at Accession No. ML20246G877.
On June 30, 2020 (ADAMS Accession No. ML20182A162), the licensee submitted an alternative request under Title 10 Code of Federal Regulations (10 CFR) 50.55a(z) to delay the SPI testing for nine containment isolation valves. Per 10 CFR 50.55a(b)(3)(xi), when implementing paragraph ISTC-3700, Position Verification Testing, in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Division 1, Section IST, 2012 Edition, licensees are required to verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications to provide assurance of proper obturator position for valves with remote position indication.
The licensee stated that the alternative request for a one-time extension was submitted in accordance with 10 CFR 50.55a(z)(1) and prior to the date that the licensee determined that the SPI testing needed to be completed. The licensee stated that it determined the due date for the SPI testing based on the date that it adopted the 2012 Edition of the ASME OM Code and the interval for paragraph ISTC-3700 testing. Additionally, the licensee asserted that that paragraph ISTC-3700 includes two tests (i.e., position verification testing and SPI testing) that do not need to be performed concurrently.
The NRC staff discussed whether the licensee submitted the alternative request to the NRC after the timeframe that paragraph ISTC-3700 testing with SPI testing should have been completed based on the staffs understanding of when the licensee adopted the 2012 Edition of the ASME OM Code at Calvert Cliffs 2 and last implemented paragraph ISTC-3700.
The licensee and the NRC discussed whether the SPI testing must be conducted concurrently with ISTC-3700 testing and whether the SPI testing was expected to have been conducted at the first occurrence of ISTC-3700 testing after adopting the 2012 Edition of the ASME OM Code.
No regulatory decisions were made during the public teleconference. Members of the public were in attendance. No public meeting feedback forms were received. Verbal feedback was provided after the meeting was concluded. Those comments are included with the comments received during the meeting in the list below. The NRC staff received comments from members of the public during the teleconference.
A member of the public provided examples of other new ASME OM Code requirements that were handled differently than the way the NRC staff described the implementation SPI testing requirement.
A member of the public stated that new requirements where phased in over several years.
A member of the public stated that the NRC staff said the new requirement had to be implemented with the adoption of the 2012 Edition of the ASME OM Code, and therefore, the interval for conducting the SPI testing started at the time the 2012 Edition of the ASME OM Code was adopted.
A member of the public stated that contrary to NRC staff assertions, the industry was not confused with whether SPI testing was required or necessary prior to the rulemaking that superseded the intent of the ASME OM Code.
A member of the public stated that since a frequency was not associated with the SPI testing and paragraph ISTC-3700 states that SPI testing and position verification testing do not need to be done concurrently, owners get to set their own frequency.
Please direct any inquiries to me at (301) 415-2871 or Michael.Marshall@nrc.gov.
Sincerely,
/RA/
Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-318
Enclosure:
List of Attendees cc: Listserv
LIST OF ATTENDEES SEPTEMBER 3, 2020, MEETING WITH EXELON GENERATION COMPANY, LLC CONCERNING ALTERNATIVE REQUEST FOR SUPPLEMENTAL POSITION INDICATION TESTING INTERVAL AT CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 2 Name Affiliation Angela Buford U. S. Nuclear Regulatory Commission (NRC)
Blake Purnell NRC David Kern NRC Earl Bousquet NRC Gregory Suber NRC Jane Marshall NRC James Danna NRC Eugene Dipaolo NRC Kent Chambliss NRC Matt Young NRC Mary Woods NRC Michael Marshall NRC Michael Farnan NRC Nicholas Hansing NRC Rodney Clagg NRC Stephanie Devlin-Gill NRC Thomas Scarbrough NRC Travis Jones NRC Tyson Campbell NRC Arthur Simpson Exelon Generation Company, LLC (Exelon)
Armanso Johnson Exelon Ashley Burress Exelon Buey Murray Exelon David Helker Exelon David Neff Exelon Frank Massitelli Exelon Glenn Weiss Exelon Ken Greene Exelon Larry Smith Exelon Leslie Turner Exelon Mark Dirado Exelon Michael Faivus Exelon Shannon Rafferty Cincilla Exelon Sheldon Waiters Exelon Thomas Haaf Exelon Todd Cervini Exelon Enclosure
2 Name Affiliation William Reynolds Exelon Jeff Stumb Dominion Energy Eli Arnold Palo Verde Generating Station Maria Lisa García Ares Tecnatom True North Consulting/Chair of OM Standards Ronald Lippy Committee Jim Rogers True North Consulting Tennessee Valley Authority and IST Owners Group Mark Gowin Chairman
Meeting Summary: ML20272A013 Meeting Presentation: ML20246G877 Meeting Notice: ML20247J308 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MMarshall LRonewicz JDanna MMarshall DATE 09/30/2020 09/30/2020 10/06/2020 10/07/2020