ML23102A283

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ASME OM Code Inservice Testing Program Request for Approval of Alternative Request V-01 Use of Mechanical Agitation Process for Pressure Isolation Valve 1-SI-241 Seat Leakage Testing
ML23102A283
Person / Time
Site: Surry  Dominion icon.png
Issue date: 04/25/2023
From: Geoffrey Miller
Plant Licensing Branch II
To: Stoddard D
Virginia Electric & Power Co (VEPCO)
Klos, J
References
EPID L-2022-LLR-0084
Download: ML23102A283 (1)


Text

April 25, 2023 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Nuclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

SURRY POWER STATION, UNIT 1 - PROPOSED ALTERNATIVE REQUEST V USE OF MECHANICAL AGITATION PROCESS FOR PRESSURE ISOLATION VALVE 1-SI-241 SEAT LEAKAGE TESTING (EPID L-2022-LLR-0084)

Dear Mr. Stoddard:

By letters dated December 8 and 9, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22342B248 and ML22343A000, respectively), and supplemented by letter dated February 22, 2023 (ML23054A192), Virginia Electric and Power Company (Dominion Energy Virginia, the licensee) submitted Alternative Request V-01 for the use of proposed alternatives to certain American Society of Mechanical Engineers (ASME)

Operation and Maintenance of Nuclear Power Plants (OM Code) for pressure isolation valve (PIV) 1-SI-241, the Low Head Safety Injection to Reactor Coolant System cold leg isolation check valve, at the Surry Nuclear Power Station (Surry, SPS) Unit 1. The current ASME OM Code of Record for Surry Unit 1 is the 2004 Edition through the 2006 Addenda. The ASME Code requirements 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.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(2), the licensee requested that the NRC authorize Alternative Request V-01 for PIV 1-SI-241 at Surry Unit 1 on the basis that the alternatives provide an acceptable level of quality and safety.

The NRC staff has reviewed alternative requests V-01 and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes the use of alternative request V-01 for PIV 1-SI-241 at Surry Unit 1 until the next refueling outage. On December 9, 2022 (ML23058A144), the NRC staff provided a verbal authorization of Alternative Request V-01 for Surry Unit 1 as complying with 10 CFR 50.55a(z)(2).

All other ASME OM Code requirements for which an alternative was not specifically requested and authorized remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.

D. Stoddard If you have any questions, please contact the Project Manager at (301) 415-5136, or via email at John.Klos@nrc.gov.

Sincerely, Digitally signed by Glenn Glenn E. E. Miller Date: 2023.04.25 17:28:04 Miller -04'00' Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280

Enclosure:

Safety Evaluation cc: Listserv

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR ALTERNATIVE REQUEST V-01 USE OF MECHANICAL AGITATION PROCESS FOR PRESSURE ISOLATION VALVE 1-SI-241 SEAT LEAKAGE TESTING VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT 1 DOCKET NUMBER 50-280 EPID NO. L-2022-LLR-0084

1.0 INTRODUCTION

By letter dated December 8, 2022 (Agencywide Documents and Access Management System (ADAMS) Accession Number ML22342B248), Virginia Electric and Power Company (Dominion Energy Virginia, licensee) submitted Alternative Request V-01 to the U.S. Nuclear Regulatory Commission (NRC) related to certain Inservice Testing (IST) requirements in the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the IST program at Surry Power Station (Surry), Unit 1, for the remainder of the current operating cycle (1R31), which is scheduled to end in the spring of 2024. In response to a request for additional information (RAI), the licensee provided supplemental information to support the alternative request in a letter dated December 9, 2022 (ML22343A000). The licensee provided clarifying information regarding Alternative Request V- 01 in a letter dated February 22, 2023 (ML23054A192).

In Alternative Request V-01, the licensee reported that it might have difficulty in achieving acceptable seat leakage test results for pressure isolation valve (PIV) 1-SI-241, which is the Low Head Safety Injection (LHSI) to Reactor Coolant System (RCS) cold leg isolation check valve, during startup from the then-ongoing refueling outage (RFO) at Surry Unit 1. Therefore, the licensee proposed the use of a mechanical agitation process to assist in achieving acceptable seat leakage test results for PIV 1-SI-241 in lieu of meeting specific IST requirements in the ASME OM Code at Surry Unit 1. To repair or replace PIV 1-Sl-241 during the RFO as required by the ASME OM Code, the licensee stated that it would have to reverse Unit 1 startup activities and cooldown, depressurize, reduce RCS water level, and remove fuel, as required, from the reactor vessel. The licensee also noted that this evolution would subject plant personnel to increased dose rates in a high ambient heat stress environment for an Enclosure

extended period of time to perform the actual repair or replacement. Based on these factors, the licensee asserted that the applicable IST requirements to address potential valve seat leakage for 1-SI-241 during startup from the then-current RFO would cause a hardship or unusual difficulty without a compensating increase in the level of quality and safety.

As a result, pursuant to subparagraph (2) in paragraph (z), Alternatives to codes and standards requirements, of Section 55a, Codes and standards, in Part 50, Domestic Licensing of Production and Utilization Facilities, to Title 10, Energy, of the Code of Federal Regulations (10 CFR 50.55a(z)(2)), the licensee requested that the NRC authorize Alternative Request V-01 for Surry Unit 1 on the basis that compliance with the ASME OM Code would result in hardship or unusual difficulty without a compensating increase in level of quality or safety.

On December 9, 2022 (ML23058A144), the NRC staff provided a verbal authorization of Alternative Request V-01 for Surry Unit 1 as complying with 10 CFR 50.55a(z)(2). In this written safety evaluation (SE), the NRC staff describes its review of Alternative Request V-01 for Surry Unit 1.

2.0 REGULATORY EVALUATION

The NRC regulations in 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, state, in part, that throughout the service life of a boiling or pressurized water- cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.

The NRC regulations in 10 CFR 50.55a(z) state, in part, that alternatives to the requirements of 10 CFR 50.55a(f) may be used, when authorized by the NRC, if the licensee demonstrates (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

3.0 TECHNICAL EVALUATION

3.1 Licensees Alternative Request V-01 Applicable ASME OM Code Edition and Addenda The current Code of record for the IST Program at Surry Unit 1 is the 2004 Edition through the 2006 Addenda of the ASME OM Code as incorporated by reference in 10 CFR 50.55a.

ASME OM Code Component Affected PIV 1-SI-241, LHSI to RCS Cold Leg Isolation Check Valve Valve Type: 6-inch Velan Swing Check Valve OM Code Class: 1 OM Code Category: AC

Applicable ASME OM Code Requirements The IST requirements in the ASME OM Code (2004 Edition through 2004 Addenda) as incorporated by reference in 10 CFR 50.55a related to Alternative Request V-01 for Surry Unit 1 are as follows:

ASME OM Code, Subsection ISTC, Inservice Testing of Valves in Light-Water Reactor Nuclear Power Plants, paragraph ISTC-3630, Leakage Rate for Other Than Containment Isolation Valves, states in part:

Valve closure before seat leakage testing shall be by using the valve operator with no additional closing force applied.

ASME OM Code, Subsection ISTC, paragraph ISTC-3630(a), Frequency, requires PIV leakage rate testing to be conducted at least once every 2 years.

ASME OM Code, Subsection ISTC, paragraph ISTC-3630(f), Corrective Action, states in part:

Valves or valve combinations with leakage rates exceeding the [values] specified by the Owner per ISTC-3630(e) shall be declared inoperable and either repaired or replaced.

ASME OM Code, Subsection ISTC, paragraph ISTC-5221, Valve Obturator Movement, in subparagraph (a)(1) states:

Check valves that have a safety function in both the open and closed directions shall be exercised by initiating flow and observing that the obturator has traveled to either the full open position or to the position required to perform its intended function(s) (see ISTA-1100), and verify that on cessation or reversal of flow, the obturator has traveled to the seat.

ASME OM Code, Subsection ISTC, paragraph ISTC-5224, Corrective Action, states in part:

If a check valve fails to exhibit the required change of obturator position, it shall be declared inoperable. A retest showing acceptable performance shall be run following any required corrective action before the valve is returned to service.

Reason for Request

In Alternative Request V-01, the licensee stated that PIV 1-Sl-241 opens to provide a flow path for Safety Injection (SI) and recirculation from the LHSI pumps to the RCS cold legs. This PIV is normally closed and remains closed until injection to isolate the LHSI low pressure piping from the RCS and the High Head SI (HHSI) headers because the LHSI Pump Cold Leg Discharge motor-operated valve (MOV) is normally open. Typically, the licensee leak tests the Low Head SI to RCS Cold Leg Isolation Check Valve PIVs during startup from RFOs (and certain other non-RFOs) at low differential test pressures (beginning around 150 pounds per square inch gage (psig)). The licensee stated that leak testing of PIV 1-Sl-241 is accomplished by using pressure from a partially pressurized SI accumulator at the check valve, and leakage is collected and measured over time at an upstream low pressure drain valve. While most PIVs tested at the lower pressures meet the leakage rate acceptance criteria when correlated to RCS pressure, the licensee reported that some PIVs have required higher test pressures

(up to nominal RCS pressure) to achieve acceptable leakage results. PIV 1-Sl-241 is usually tested with a partially pressurized accumulator with test pressures between 275 and 300 psig.

In certain cases, the licensee stated that mechanical agitation has been used to assist in seating the valve to achieve an acceptable leakage rate. The licensee noted that mechanical agitation is a troubleshooting activity rather than a repair method, and that the ASME OM Code, paragraph ISTC-3630(f), requires valves with leakage rates that exceed their acceptance criteria to be declared inoperable, either repaired or replaced, and followed by a re-test to confirm acceptable operation prior to being returned to service. The licensee referenced a recent precedent where the NRC authorized an IST alternative request for the Tennessee Valley Authority (TVA) Sequoyah Nuclear Plant (SQN) to apply mechanical agitation as a PIV leakage test troubleshooting activity, and to defer repair or replacement of certain PIVs to the following RFO for that plant.

In Alternative Request V-01, the licensee stated that it was tracking PIV 1-Sl-241 in its corrective action program for repair or replacement during a subsequent outage. The licensee stated that PIV 1-Sl-241 was declared operable but not fully qualified after an engineering evaluation determined that an acceptable leakage test result was achieved after mechanical agitation of the PIV on May 27, 2021. Corrective maintenance for PIV 1-Sl-241 was originally scheduled to occur during RFO 1R31 (December 2022) at Surry Unit 1. The licensee reported that efforts to isolate PIV 1-Sl-241 for the repair activity during RFO 1R31 were not successful.

To repair or replace PIV 1-Sl-241 during RFO 1R31, the licensee would have had to reverse Unit 1 startup activities and cooldown, depressurize, reduce RCS water level, and remove fuel, as required, from the reactor vessel. This would have a significant impact on startup and outage duration and would have required emergent plant maneuvering and an increased shutdown safety risk to achieve the required configuration necessary for repair or replacement of PIV 1-SI-241. The licensee noted that this evolution would also have subjected plant personnel to increased dose rates in a high ambient heat stress environment for an extended period of time to perform the actual repair or replacement. In addition, the licensee stated that substantial emergent support activities would have been required.

Therefore, the licensee asserted in Alternative Request V-01 that performance of the repair or replacement activity for PIV 1-Sl-241 during RFO 1R31 in compliance with ASME OM Code, paragraphs ISTC-3630, ISTC-3630(f), ISTC-5221(a)(1), and ISTC-5224, would have caused a hardship or unusual difficulty without a compensating increase in the level of quality or safety in order to perform the repair or replacement activity for PIV 1-SI-241 required by ISTC-3630(f).

Proposed Alternative In Alternative Request V-01, the licensee requested an alternative to (1) the ASME OM Code, Subsection ISTC, paragraph ISTC-3630 requirements as they relate to the use of additional force to achieve PIV closure before seat leakage testing; (2) the paragraph ISTC-3630(f) requirements as they relate to corrective action following a failed seat leakage test; (3) the paragraph ISTC-5221(a)(1) requirements as they relate to demonstrating that a PIV check valve disk travels to its seat following cessation of flow; and (4) the paragraph ISTC-5224 requirements as they relate to retesting following any required corrective action before the valve is returned to service. The licensee stated that the proposed alternative was solely applicable to PIV 1-Sl- 241. The licensee specified that the duration of Alternative Request V-01 would be through the remainder of the 1R31 operating cycle for Surry Unit 1, which is scheduled to end in the spring of 2024.

The licensee stated that PIV 1-Sl-241 seat leakage testing occurs at low pressures to expedite startup activities for Surry Unit 1. If PIV 1-Sl-241 seat leakage does not meet the acceptance criteria during the initial testing, the following actions would be taken in implementing Alternative Request V-01:

PIV 1-Sl-241 would be declared inoperable in accordance with the affected Technical Specifications (TS) and the ASME OM Code, and the failed PIV would be entered into the site corrective action program, which would allow the provisions of this alternative to be invoked.

Rather than performing an ASME OM Code repair or replacement, PIV 1-Sl-241 may be mechanically agitated in accordance with the specific guidance provided in Alternative Request V-01.

After PIV 1-Sl-241 is mechanically agitated, it would be seat leakage tested using the normal test procedures. The incremental agitation and testing process may be repeated until seat leakage rate acceptance criteria are met, or it is determined that corrective maintenance is required. The following two scenarios apply:

If the seat leakage test meets the acceptance criteria, then the PIV will be declared operable.

If the seat leakage test does not meet the acceptance criteria, then the PIV will be repaired or replaced during the outage of discovery.

If PIV 1-Sl-241 needs to be mechanically agitated and subsequently passes seat leakage testing, it will be repaired or replaced during the next Unit 1 RFO.

When PIV 1-Sl-241 is either repaired or replaced during the next outage, it must pass post- maintenance tests (including seat leakage tests) before being declared operable.

The licensee asserted that the provisions of Alternative Request V-01, in lieu of the specific requirements of ASME OM Code, Subsection ISTC, paragraphs ISTC-3630, ISTC-3630(f),

ISTC-5221(a)(1) and ISTC-5224, would provide adequate indication of PIV 1-Sl-241 functionality and operability.

Basis for the Proposed Alternative The licensees basis for the proposed alternative in Alternative Request V-01, summarized by the NRC staff, is as follows:

PIV 1-Sl-241 is a common check valve model and design that is used in the industry and typically performs well until operation eventually results in degradation of the seating surfaces.

Seating PIV 1-Sl-241 requires pressure from an SI accumulator pressurized to 275 to 300 psig. To test back-leakage characteristics, SI accumulator pressure and flow are utilized to measure flow from drain valves upstream of the check

valves which would demonstrate quantifiable leakage past the check valves.

Unless there is a significant pressure differential across the seat, the disk might not be pushed into the seat with sufficient force to achieve full contact. The disk is slightly inclined such that gravity does not help maintain the disk closed to the extent that it does for a vertically mounted check valve.

The licensee has experienced challenges at Surry Unit 1 achieving consistent pressure differential across the PIV 1-Sl-241 seat due to the numerous connections and branches involved in the PIV 1-Sl-241 configuration. The licensee has been able to achieve the required pressure differential through realignment, venting, and cycling of valves, but only after extensive troubleshooting and procedure changes. However, a failed test for PIV 1-Sl- 241 would require emergent activities to effect repair or replacement.

Once PIV 1-Sl-241 is closed with an acceptable seat leakage rate, the valve would not be required to open unless a large break loss-of-coolant accident (LBLOCA) occurred and would not be required to perform the PIV function again following an LBLOCA. Should an LBLOCA occur, the plant would be shut down for an extended period of time, which would allow the maintenance planned for the next RFO to be performed prior to startup following the LBLOCA.

In Alternative Request V-01, the licensee provided details describing each of the above factors supporting its request to implement the mechanical agitation process for PIV 1-SI-241 at Surry Unit 1. The licensee also provided an attachment with a summary of its engineering assessment of the mechanical agitation process for PIV 1-SI-241 as part of Alternative Request V-01.

Summary In Alternative Request V-01, the licensee stated that the proposed alternative would permit continued startup of Surry Unit 1 if PIV 1-Sl-241 can be demonstrated to have acceptable seat leakage following mechanical agitation. If mechanical agitation is needed, the licensee specified that the following restrictions would be in place under Alternative Request V-01:

Should the valve fail to meet the TS and ASME OM Code leakage requirements, PIV 1-Sl- 241 will be declared inoperable.

Should the valve fail to meet the TS and ASME OM Code leakage requirements, mechanical agitation will be used to assist in troubleshooting the failure.

Mechanical agitation assists in ascertaining the condition of the valve seat. Prior to using mechanical agitation, the licensee will obtain as-found test results and apply other measures, where possible, such as varying pressure or venting, to seat the check valve.

An engineering evaluation has been performed that provides a reasonable determination that the mechanical agitation process will not create damage to the valve. Mechanical agitation may be performed by tapping the valve body using a 15 pound (maximum) rubber mallet or soft-faced dead blow mallet swung at a maximum of approximately 120 degrees about the elbow, without excessive use of the body to accelerate the hammer head. The surface to be agitated will not include any bolting or flanges. The valve will be visibly inspected prior to and

after the mechanical agitation to ensure that no physical external damage to the check valve has occurred.

During the next RFO 1R32 (scheduled for spring 2024) at Surry Unit 1, PIV 1-SI-241 will be disassembled and inspected and will be repaired or replaced as necessary. Post- maintenance testing will be performed in accordance with the ASME OM requirements.

3.2 NRC Staff Evaluation In Alternative Request V-01 for Surry Unit 1, the licensee proposes a mechanical agitation process for PIV 1-SI-241, LHSI to RCS Cold Leg Isolation Check Valve, to assist in achieving acceptable seat leakage test results in lieu of meeting specific IST requirements in the ASME OM Code, as incorporated by reference in 10 CFR 50.55a. The licensee specified that the duration of Alternative Request V-01 will be through the remainder of the 1R31 operating cycle for Surry Unit 1, which is scheduled to end in the spring of 2024. The licensee submitted Alternative Request V-01 in accordance with 10 CFR 50.55a(z)(2) on the basis that the applicable IST requirements to address potential valve seat leakage for PIV 1-SI-241 during startup from the then-current RFO 1R31 (December 2022) would cause a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The IST requirements applicable to Alternative Request V-01 for Surry Unit 1, 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 PIV 1-SI- 241 at Surry Unit 1; (2) the controls specified for the PIV 1-SI-241 mechanical agitation process; (3) the operational history of seat leakage for PIV 1-SI-241; (4) past performance of mechanical agitation of PIV 1-SI-241 to reduce its seat leakage; (5) the licensees engineering assessment of the stress applied to the valve body of PIV 1-SI-241 from mechanical agitation; and (6) the licensees comparison of its process for mechanical agitation of PIV 1-SI-241 described in Alternative Request V-01 for Surry Unit 1 to a precedent referenced in the licensees submittal related to a mechanical agitation process described in an alternative request submitted by TVA for SQN that the NRC staff authorized on December 1, 2022 (ML22304A186).

In response to NRC staff questions regarding Alternative Request V-01 for Surry Unit 1, the licensee submitted a supplement to its alternative request in a letter dated December 9, 2022. The NRC staff summarizes the information provided in the licensees supplemental letter as follows:

The licensee confirmed that PIV 1-SI-241 will be internally inspected and repaired or replaced prior to startup from the next RFO (1R32) at Surry Unit 1, which is scheduled for the spring of 2024. The licensee specified this action as a regulatory commitment in its letter dated December 9, 2022.

The licensees engineering evaluation documents that PIV 1-SI-241 is the same make and model as the 6-inch check valve evaluated for the TVA precedent (same thickness and material) and that the results from the TVA analysis apply to PIV 1-SI-241 assuming mechanical agitation is performed using the same approach, which is required by Alternative Request V-01 for Surry Unit 1.

Therefore, the licensee confirmed that the results of the engineering evaluation for Alternative Request V-01 demonstrate that the allowed mechanical agitation will not damage PIV 1-SI-241 in Surry Unit 1. The licensee confirmed that the mechanical agitation of PIV 1-SI-241 at Surry Unit 1 will implement the process specified in the Alternative 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.

On December 9, 2022, the NRC staff provided verbal authorization of Alternative Request V-01 for Surry Unit 1 to perform mechanical agitation of PIV 1-SI-241 using the specific controls described in the alternative request (as supplemented). Following issuance of the verbal authorization, the NRC staff requested that the licensee provide its engineering evaluation for the mechanical agitation process referenced in its submittal dated December 8, 2022. In a letter dated February 22, 2023 (ML23054A192), the licensee provided Engineering Technical Evaluation ETE-SU-2021-0034 (Revision 0), Engineering Evaluation of Mechanical Agitation Process for Pressure Isolation Valve 1-SI-241, which had been referenced in its December 8, 2022, submittal. The NRC staff determined that the licensees referenced engineering evaluation for the mechanical agitation process for PIV 1-SI-241 is consistent with the information provided to support the verbal authorization of Alternative Request V-01 by the NRC staff.

Based on the information provided by the licensee, the NRC staff finds that a hardship existed 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 IST requirements in the ASME OM Code for PIV 1-SI-241 during the startup from the then-current RFO 1R31 (December 2022) at Surry Unit 1. With the mechanical agitation process described in Alternative Request V-01 (as supplemented), the NRC finds that the licensees proposed alternative provides reasonable assurance that PIV 1-SI-241 at Surry Unit 1 will be operationally ready to perform its safety function until corrective action can be performed during RFO 1R32, which is scheduled to occur in the spring of 2024.

4.0 CONCLUSION

On December 9, 2022, the NRC staff provided verbal authorization of Alternative Request V-01 to perform mechanical agitation of PIV 1-SI-241 at Surry Unit 1 using the specific controls described in the alternative request (as supplemented) until RFO 1R32, which is scheduled for the spring of 2024. As described above, the NRC staff finds that the licensee justified in Alternative Request V-01, that performance of inservice testing required by the ASME OM Code for PIV 1-SI-241 during startup of Surry Unit 1 from RFO 1R31 in December 2022 would have caused a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The NRC staff finds that Alternative Request V-01 provides reasonable assurance that PIV 1-SI-241 will be operationally ready to perform its safety function until the next RFO (1R32) at Surry Unit 1. Accordingly, the NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(2).

Consistent with the verbal authorization provided on December 9, 2022, the NRC staff authorizes the use of Alternative Request V-01 (as supplemented) until RFO 1R32 at Surry Unit 1, which is scheduled to occur in the spring of 2024. The NRC staff authorization of Alternative Request V-01 (as supplemented) expires upon completion of the current operating cycle at Surry Unit 1.

All other ASME OM Code requirements as incorporated by reference in 10 CFR 50.55a for which relief or an alternative was not specifically requested, and granted or authorized (as appropriate), in the subject request remain applicable.

Principal Contributor: Thomas Scarbrough, NRR/DEX Date: April 25, 2023

ML23102A283 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NAME ZTurner JKlos KGoldstein DATE 04/14/2023 04/17/2023 04/25/2023 OFFICE NRR/DEX/EMIB/BC NRR/DORL/LPL2-1/(A)BC NRR/DORL/LPL2-1/PM NAME SBailey EMiller (MMarkley for) JKlos DATE 03/08/2023 04/25/2023 04/25/2023