ML22080A251

NRR E-mail Capture - (External_Sender) ASME OM Code Case OMN-27, Alternative Requirements for Testing Category a Valves (Non- Piv/Civ)

ML22080A251
Person / Time
Site:	Beaver Valley, Davis Besse
Issue date:	03/18/2022
From:	Lashley P FirstEnergy Nuclear Operating Co
To:	Bhalchandra Vaidya NRC/NRR/DORL/LPL3
References
L-2021-LLR-0026
Download: ML22080A251 (3)

Text

From: Lashley, Phil H <phlashley@energyharbor.com>

Sent: Friday, March 18, 2022 1:16 PM To: Vaidya, Bhalchandra Cc: Goodman, Josh

Subject:

[External_Sender] OMN-27 Request Bhalchandra, In our 10 CFR 50.55a request dated 4/1/21, we made the following statements (highlights added for emphasis):

Cover letter: Specifically, Energy Harbor Nuclear Corp. requests approval to use ASME OM Code Case OMN-27, "Alternative Requirements for Testing Category A Valves (Non- PIV/CIV),"

to determine valve test frequency in lieu of the two-year leakage rate test frequency requirement specified in ASME OM Code Section ISTC-3630(a) for Category A valves that are not reactor coolant system pressure isolation valves (PIVs) or containment isolation valves (CIVs).

Section 1 of request: Davis-Besse Nuclear Power Station (DBNPS) and Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and BVPS-2, respectively) Category A valves that are not reactor coolant system pressure isolation valves (PIVs) or containment isolation valves (CIVs).

Section 5 of request: Code Case OMN-27 does not apply to pressure isolation valves (PIVs) or containment isolation valves (CIVs).

The NRCs safety evaluation (dated 1/21/22) states (highlights added for emphasis):

Cover letter, third paragraph: The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that Alternative Requests RV-2, VRR5, and VRR7 for DBNPS, BVPS-1, and BVPS-2, respectively, provide an acceptable level of quality and safety for the ASME OM Code Category A valves, excluding reactor coolant system, PIVs, and CIVs.

Section 3.1 of the SE: The licensee requested to use the proposed alternative described below for all ASME OM Code Category A valves, excluding reactor coolant system (RCS), pressure isolation valves (PIVs), and containment isolation valves (CIVs), in their IST program that meet the requirements of ASME OM Code Case OMN-27, Alternative Requirements for Testing Category A Valves (Non- PIV/CIV).

Section 3.1.2 of the SE: This will apply to all ASME OM Code Category valves except RCS, PIVs, and CIVs.

Also Section 3.1.2 of the SE: The plant staff at DBNPS, BVPS-1, and BVPS-2, have been testing their Category A valves, excluding RCS, PIVs, and CIVs, every 2 years, so this trending history provides justification to implement ASME OM Code Case OMN-27 for these valves.

Section 3.2 of the SE: The licensee proposes to apply ASME OM Code Case OMN-27 in its entirety for all Category A valves that are not RCS, PIVs, or CIVs, at DBNPS, BVPS-1, and BVPS-2.

Section 4 of the SE: As set forth above, the NRC staff has determined that Alternative Requests RV-2, VRR5, and VRR7 for DBNPS, BVPS-1, and BVPS-2, respectively, provide an acceptable

level of quality and safety for the ASME OM Code Category A valves, excluding RCS, PIVs, and CIVs.

The problem is that the NRC SE includes a comma after RCS that has changed the intent of the sentence. Whereas our request included PIVs that are within the RCS, the NRC SE excludes PIVs as well as all other RCS valves. That is a change in meaning from what was requested. Of note, it is characterized correctly in the second paragraph of the cover letter, which states (highlight added), Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(z)(1), the licensee requested to use Alternative Request RV-2 for DBNPS, Alternative Request VRR5 for BVPS-1, and Alternative Request VRR7 for BVPS-2, regarding valve IST, ASME OM Code Case OMN-27, Alternative Requirements for Testing Category A Valves (Non-PIV [pressure isolation valve]/CIV [containment isolation valve]), to determine valve test frequency in lieu of the 2-year leakage rate test frequency requirement specified in ASME OM Code Section ISTC-3630(a) for Category A valves that are not reactor coolant system PIVs or CIVs on the basis that the proposed alternative would provide an acceptable level of quality and safety.

Please review and we can discuss how to proceed to correct the issue.

Respectfully, Phil H. Lashley Fleet Licensing Manager (330) 696-7208 Electronic Confidentiality and Privacy Notice: This e-mail, and any attachments, contains information that may be confidential, constitutes non-public information, may be protected by electronic communication privacy laws, or is a privileged communication (attorney-client or otherwise). The information contained in this message is intended only for the personal and confidential use of the recipient(s) named above. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, use, disclosure, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify the sender immediately by reply e-mail or by phone, and destroy all copies of the original message.

Hearing Identifier: NRR_DRMA Email Number: 1561 Mail Envelope Properties (SA1P110MB13920866F58F2D55132A1ED5CD139)

Subject:

[External_Sender] OMN-27 Request Sent Date: 3/18/2022 1:15:37 PM Received Date: 3/18/2022 1:15:48 PM From: Lashley, Phil H Created By: phlashley@energyharbor.com Recipients:

"Goodman, Josh" <joshgoodman@energyharbor.com>

Tracking Status: None "Vaidya, Bhalchandra" <Bhalchandra.Vaidya@nrc.gov>

Tracking Status: None Post Office: SA1P110MB1392.NAMP110.PROD.OUTLOOK.COM Files Size Date & Time MESSAGE 4902 3/18/2022 1:15:48 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: