ML23058A144
| ML23058A144 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/09/2022 |
| From: | John Klos NRC/NRR/DORL/LPL2-1 |
| To: | Geoffrey Miller, Sly C Dominion Energy Co |
| References | |
| Download: ML23058A144 (1) | |
Text
From: John Klos Sent: Friday, December 09, 2022 8:13 AM To: gary.d.miller@dominionenergy.com; craig.d.sly@dominionenergy.com Cc: John Klos
Subject:
Verbal Authorization of Relief Request Surry Unit 1, ALTERNATIVE REQUEST V-01, ALTERNATIVE MECHANICAL AGITATION PROCESS FOR PRESSURE ISOLATION valve 1-SI-241
Gary, Craig,
By telephone conversation on December 9, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff provided a verbal authorization to Virginia Electric and Power Company, (the licensee, Dominion Energy Virginia) for the proposed alternative V-01 for Surry Unit 1.
The staffs evaluation and verbal authorization is repeated below as an attachment to this email.
This email will be recorded as an official agency record and made publicly available.
Thanks in advance,
John Klos DORL Mcguire, Surry Licensing Project Manager U.S. NRC, Office of Nuclear Reactor Regulation (NRR),
Division of Operating Reactor Licensing (DORL),
NRC/NRR/DORL/LPL2-1, MS O9E3 Washington, DC 20555-0001 301.415.5136, John.Klos@NRC.gov
Attachment:
VERBAL AUTHORIZATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR
ALTERNATIVE REQUEST V-01
ALTERNATIVE MECHANICAL AGITATION PROCESS FOR PRESSURE ISOLATION
VALVE 1-SI-241 SEAT LEAKAGE TESTING
VIRGINIA ELECTRIC AND POWER COMPANY
SURRY UNIT 1 DOCKET NO. 50-380
DECEMBER 9, 2022
Technical Evaluation Read by Stewart Bailey, Chief, Mechanical Engineering and
1 Inservice Testing Branch, Division of Engineering and External Hazards,
NRC Office of Nuclear Reactor Regulation
This call is for the NRC to verbally authorize a request by Virginia Electric and Power Company (the
licensee, Dominion Energy Virginia) to use an alternative to certain inservice testing (IST) requirements of the
ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) at Surry Power
Station Unit 1. In particular, the licensee submitted Alternative Request V-01 by letter dated December 8, 2022
(Agencywide Documents Access and Management S ystem (ADAMS) Accession No. ML22342B248) as
supplemented by letter dated December 9, 2022 (ADAMS Accession No. ML22343A000) proposing a
mechanical agitation process for pressure isolation valve 1-SI-241, which is the Low Head Safety Injection to
Reactor Coolant System cold leg isolation check valve, to assist in achieving acceptable seat leakage test
results in lieu of meeting specific inservice testing requirements in the ASME OM Code at Surry Unit 1.
Title 10 of the Code of Federal Regulations, Section 50.55a, permits the NRC staff to verbally authorize
alternatives to IST requirements in circumstances w here the licensee has docketed all pertinent information,
the NRC staff has completed its review, and there is not enough time for the NRC to issue its written safety
evaluation before the alternative is needed. That is the case here.
The licensee submitted Alternative Request V-01 in accordance with 10 CFR 50.55a(z)(2) on the basis
that the applicable inservice testing requirements to address potential valve seat leakage for 1-SI-241 during
startup from the current refueling outage would cause a hardship or unusual difficulty without a compensating
increase in the level of quality and safety.
The NRC regulations in 10 CFR 50.55a(f) require licensee s to implement inservice testing programs for
pumps, valves, and dynamic restraints that meet the requirements of the ASME OM Code as incorporated by
reference in 10 CFR 50.55a. The current ASME OM Code of Record for Surry Unit 1 is the 2004 Edition
through the 2006 Addenda. The ASME OM Code requirement s applicable to Alternative Request V-01 include
ASME OM Code, Subsection ISTC, paragraphs ISTC-3630, ISTC-3630(a), ISTC-3630(f), ISTC-5221(a)(1),
and ISTC-5224.
In its review of Alternative Request V-01, the NRC staff evaluated (1) the licensees description of the
mechanical agitation process previously performed and planned in the future for 1-SI-241 at Surry Unit 1, (2)
the controls specified for the 1-SI-241 mechanical agitation process, (3) the operational history of seat leakage
2 for 1-SI-241, (4) past performance of mechanical agitation of 1-SI-241 to the reduce its seat leakage, (5) the
licensees engineering assessment of the stress applied to the valve body of 1-SI-241 from mechanical
agitation, and (6) the licensees comparison of its process for mechanical agitation of 1-SI-241 to the
mechanical agitation process specified in the precedent that Dominion Electric Virginia referenced in the
submittal. The precedent is a similar alternative reques t that the NRC staff has already authorized for another
licensee.
In response to NRC staff questions, the licensee s upplemented Alternative Request V-01 in a letter dated
December 9, 2022, as follows:
replaced prior to startup from the next SPS Unit 1 RFO (1R32). The licensee specified this action as a
regulatory commitment in its letter dated December 9, 2022.
- 2. The Dominion Energy Virginia engineering evaluation documents that 1-SI-241 is the same make/model
as the 6 check valve evaluated by TVA (same thickness, same material) and that the results from the TVA
analysis therefore apply to 1-SI-241 assuming mechanical agitation is performed applying the same
approach, which is required by the proposed alternative. Therefore, Dominion Energy Virginia confirms that
the results of our engineering evaluation demonstrate that mechanical agitation will not damage 1-SI-241.
implement the process specified in the Alternat ive Request V-01 section titled Recommendations for
Future Application of Mechanical Agitation to Seat Valve 1-SI-241. The licensee specified this action as a
regulatory commitment in its letter dated December 9, 2022.
Based on the information provided by the licensee, t he NRC staff finds that a hardship exists without a
compensating increase in the level of quality and safety, in accordance with 10 CFR 50.55a(z)(2), for the
performance of the specified inservice testing requirements in the ASME OM Code for 1-SI-241 during startup
from the current refueling outage. With the mechanica l agitation process described in the licensees request,
the NRC finds that the licensees proposed alternative will provide reasonable assurance that 1-SI-241 at Surry
Unit 1 will be operationally ready to perform its safety function until corrective action can be performed during
the next refueling outage. The NRC staff does not authorize Alternative Request V-01 beyond the current
operating cycle. It is only authorized up to the next refueling outage for Surry Unit 1.
3 All other ASME OM Code requirements for which relief or an alternative was not specifically requested
and granted or authorized as part of this alternative request remain applicable. If the licensee identifies a
performance issue with 1-SI-241, the licensee will be expe cted to take action to implement the requirements of
its Technical Specifications. This Verbal Authorization is applicable to Alternative Request V-01 until the next
refueling outage at Surry Unit 1. The NRC staffs detailed review of Alternative Request V-01 for Surry Unit 1
will be provided through a separate safety evaluation.
NRC Staff Conclusion Read by Michael Markle y, Chief, Plant Licensing Branch II-1,
Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation
As Chief of Plant Licensing Branch II-1, I concur wi th the conclusions of the NRR Mechanical Engineering and
Inservice Testing Branch.
The NRC staff concludes that Alternative Request V-01 addresses the identified hardship or unusual difficulty
without a compensating increase in the level of quality and safety for the Surry Power Station Unit 1 for the 1-
SI-241 valve.
Accordingly, the NRC staff concludes that the lic ensee has adequately addressed all of the regulatory
requirements set forth in 10 CFR 50.55a(z)(2) for the 1-SI-241 valve.
Therefore, as of December 9, 2022, the NRC authorizes Alternative Request V-01 for Surry Unit 1 for the next
operating cycle to end in the spring of 2024.
All other requirements of the ASME OM Code, for which re lief or an alternative was not specifically requested
and authorized by the NRC staff, remain applicable.
This verbal authorization does not preclude the NRC staff from asking additional questions and clarifications
regarding the licensees proposed alternative while preparing the subsequent written safety evaluation.
4