ML22109A212
| ML22109A212 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire  |
| Issue date: | 04/20/2022 |
| From: | Duke Energy Corp |
| To: | Andrew Hon NRC/NRR/DORL/LPL2-2 |
| Hon A | |
| References | |
| Download: ML22109A212 (16) | |
Text
Duke Energy Pre-Submittal Meeting April 20, 2022
Pre-Submittal Meeting License Amendment Request to Revise Reactor Coolant System Pressure Isolation Valve Operational Leakage Surveillance Requirement Frequency Catawba Nuclear Station (CNS)
Shearon Harris Nuclear Power Plant (HNP)
McGuire Nuclear Station (MNS)
Oconee Nuclear Station (ONS)
H.B. Robinson Steam Electric Plant (RNP) 2
Duke Energy Attendees Lee Grzeck (Acting Manager, Nuclear Fleet Licensing)
Dennis Earp (Nuclear Fleet Licensing)
David Dobson (Fleet Engineering) 3 3
Agenda Current and Proposed Technical Specification (TS) / Surveillance Requirement (SR)
System Design and Operation
Background
Reason for the Proposed Change Justification Regulatory Requirements and Guidance Precedent Schedule 4
Current and Proposed TS / SR (CNS and MNS) 5 5
Current and Proposed TS / SR (ONS) 6 6
Current and Proposed TS / SR (RNP) 7 7
Current and Proposed TS / SR (HNP) 8 8
System Design and Operation 9
9 RCS PIVs Any two normally closed valves in series within the reactor coolant pressure boundary which separate the high-pressure RCS from an attached low-pressure system.
Main purpose is to prevent overpressure failure of the low-pressure portions of connecting systems.
Failure consequences could be a LOCA outside of containment, an unanalyzed accident, that could degrade the ability for low pressure injection.
PIV leakage limit applies to each individual valve.
RCS PIV leakage satisfies Criterion 2 of 10 CFR 50.36.
A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
=
Background===
Surveillance Frequency Control Program Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1 Implemented per license amendment adopting TSTF-425, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b Inservice Testing Program Fulfills the requirements of 10 CFR 50.55a(f), which requires, in part, that Class 1, 2, and 3 components and their supports meet the requirements of the ASME OM Code or equivalent quality standards.
TS Definition implemented per license amendment adopting TSTF-545, TS Inservice Testing [IST]
Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ASME OM Code Section ISTC-3630(a)
Valve leakage rate testing frequency of at least once every 2 years.
10
Reason for the Proposed Change 11 11 Regulatory Guide 1.192, Revision 4 Operation and Maintenance Code Case Acceptability, ASME OM Code Incorporated by reference into 10 CFR 50.55a Contains new OM Code Cases and revisions to existing OM Code Cases the staff has approved for use.
Case OMN-23: Alternative Rules for Testing Pressure Isolation Valves Establishes requirements for implementing and maintaining a condition monitoring program for RCS PIV that may be implemented in lieu of the 2-year leakage rate test frequency specified by ASME OM Code Section ISTC-3630(a).
Does not replace or exclude any test method requirement specified in ISTC-3630.
Interval extensions limited to a 24-month interval.
Intervals shall not exceed the maximum interval of 6 years.
Justification 12 12 10 CFR 50.55a(f)(5)(ii)
IST program update: Conflicting IST Code requirements with technical specifications If a revised inservice test program for a facility conflicts with the technical specifications for the facility, the licensee must apply to the Commission for amendment of the technical specifications to conform the technical specifications to the revised program. The licensee must submit this application, as specified in § 50.4, at least 6 months before the start of the period during which the provisions become applicable, as determined by paragraph (f)(4) of this section.
Regulatory Requirements and Guidance 13 Regulations 10 CFR 50.36, Technical Specifications 10 CFR 50.55a, Codes and Standards 10 CFR 50 Appendix A, General Design Criteria for Nuclear Power Plants GDC 1, Quality Standards and Records GDC 14, Reactor coolant pressure boundary GDC 32, Inspection of reactor coolant pressure boundary GDC 54, Piping systems penetrating containment Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 4
14 Precedent Virgil C. Summer Nuclear Station, 2019 Revised surveillance frequency of TS 3/4.4.6, Reactor Coolant System Leakage, SR 4.4.6.2.2.a to allow the RCS PIV leakage test to be extended to a performance-based frequency not to exceed 3 refueling outages (to a maximum of 60 months) following two consecutive satisfactory tests.
The amendment was issued by the NRC on March 7, 2019 (ADAMS Accession No. ML19023A420)
Schedule 15 15 Submit LAR by May 19, 2022 Implementation within 120 days of receipt of safety evaluation
16