Information Notice 2021-01, Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Design-Basis Capability of Power-Operated Valves at Nuclear Power Plants

From kanterella
(Redirected from ML23129A014)
Jump to navigation Jump to search
Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Design-Basis Capability of Power-Operated Valves at Nuclear Power Plants
ML23129A014
Person / Time
Issue date: 07/24/2023
From: Russell Felts
NRC/NRR/DRO
To:
References
IN-21-001, Suppl 1
Download: ML23129A014 (10)


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001 July 24, 2023 INFORMATION NOTICE 2021-01, SUPPLEMENT 1: LESSONS LEARNED FROM U.S.

NUCLEAR REGULATORY

COMMISSION INSPECTIONS OF

DESIGN-BASIS CAPABILITY OF

POWER-OPERATED VALVES AT

NUCLEAR POWER PLANTS

ADDRESSEES

All holders of operating licenses, construction permits, or combined licenses for nuclear power

reactors, except those that have permanently ceased operations and have certified that fuel has

been permanently removed from the reactor vessel.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this supplement to Information

Notice (IN) 2021-01, Lessons Learned from U.S. Nuclear Regulatory Commission Inspections

of Design-Basis Capability of Power-Operated Valves at Nuclear Power Plants, dated May 6,

2021 (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML21061A265) to alert addressees to lessons learned from NRC inspections of the

design-basis capability of power-operated valves (POVs) at nuclear power plants. The NRC

expects that addressees will review the information for applicability to their facilities and

consider actions, as appropriate, to identify and address similar issues. Suggestions contained

in this IN are not NRC requirements. Therefore, no specific action or written response is

required.

DESCRIPTION OF CIRCUMSTANCES

As discussed in IN 2021-01 (ML21061A265), the NRC staff initiated an inspection program

described in Attachment 21N.02, Design-Basis Capability of Power-Operated Valves Under

10 CFR 50.55a Requirements, to NRC Inspection Procedure (IP) 71111, Reactor Safety

Initiating Events, Mitigating Systems, Barrier Integrity. The most recent revision to IP

71111.21N.02 is dated October 9, 2020, and is publicly available at ADAMS Accession No.

ML20220A667. The NRC issued IP 71111.21N.02 to assess the reliability, functional capability, and design-basis capability of risk-important POVs to determine whether licensees are

maintaining the POV capability to perform as intended under design-basis conditions. During

public meetings in late 2019 and early 2020 (for example, see ADAMS Accession Nos.

ML19351E131 and ML20038A207), the NRC staff described the purpose of the

IP 71111.21N.02 inspections and indicated that lessons learned from those inspections would

be made available to the stakeholders. During a public meeting on December 8, 2020

(ML20338A012), participants requested that the lessons learned from the initial POV

inspections be documented and made available as soon as possible. As a result, the NRC

issued IN 2021-01 to provide lessons learned from the POV inspections conducted in 2020.

ML23129A014

IN 2021-01, Supplement 1 During the POV inspection program, the NRC staff presented lessons learned from POV

inspections at several industry meetings. For example, the NRC staff presented lessons learned

from POV inspections at a public meeting with the Boiling Water Reactor Owners Group

(BWROG) on December 1, 2021 (ML21334A168), and at a Motor-Operated Valve (MOV) Users

Group meeting on January 24, 2023 (ML23018A081). With the completion of the POV

inspection program at the end of 2022, participants at the January 24, 2023, meeting requested

that the NRC staff provide a complete list of the lessons learned from all of the POV inspections

as soon as possible.

DISCUSSION

The NRC staff conducted inspections using IP 71111.21N.02 to assess the reliability, functional

capability, and design-basis capability of POVs to determine whether licensees are maintaining

the POV capability to perform their safety functions as intended under design-basis conditions.

The enclosure to IN 2021-01 contains background information related to the design-basis

capability of POVs in nuclear power plants. The NRC inspections using IP 71111.21N.02 identified numerous lessons learned related to the design-basis capability of POVs installed in

nuclear power plants.

The following summarizes the lessons learned from the POV inspections conducted by the NRC

staff using IP 71111.21N.02:

  • Inservice Testing (IST) Program: The NRC regulations in Title 10 of the Code of Federal

Regulations (10 CFR) 50.55a, Codes and standards, require licensees to develop an

IST program to provide assurance of the operational readiness of pumps, valves, and

dynamic restraints in accordance with the applicable edition and addenda of the

American Society of Mechanical Engineers (ASME) Operation and Maintenance of

Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code), as incorporated

by reference in 10 CFR 50.55a. For POVs within the scope of the applicable edition and

addenda of the ASME OM Code, the NRC inspectors found that licensees did not

always ensure that valves were properly included and categorized within the scope of

the IST program, such as POVs with leakage limitation safety functions, remote-operated safety functions, or manual-operated safety functions.

  • POV Operating Requirements and Capability: The NRC inspectors found that licensees

did not always properly determine the operating requirements and actuator capability for

POVs to perform their safety functions. For example, all appropriate parameters (such

as valve friction coefficients or valve factors, maximum differential pressure conditions, motor torque temperature derating factors, stem friction coefficients, and butterfly valve

bearing friction coefficients) are expected to be addressed when calculating valve

operating requirements or actuator capability. Improper values for various parameters in

POV calculations (such as incorrect stem pitch and lead values, valve, and stem friction

coefficients less than tested values, and incorrect uncertainty assumptions) can lead to

inadequate determinations of POV functionality. The NRC inspectors found that

licensees did not always justify the use of POV parameters, such as valve friction

coefficients, from outside sources. See IN 2012-14, Motor-Operated Valve Inoperable

Due to Stem-Disc Separation, dated July 24, 2012 (ML12150A046) for guidance on

using POV data from outside sources. The NRC inspectors found that licensees did not

always ensure that valve-specific valve factors were used if determined to be higher than

generic valve factors with an appropriate extent of condition review. For globe valves, there is a potential for increased thrust and torque requirements (referred to as side

IN 2021-01, Supplement 1 loading) to operate globe valves under high-flow dynamic conditions. The unwedging

load required for valves is part of the evaluation of the capability of POVs to open to

perform their safety functions. The specific design of each POV, including its valve, is

used in determining appropriate calculation assumptions. The NRC inspectors found that

licensees did not always ensure that all normal operating loads that act simultaneously

with seismic loads were addressed. For MOVs, high ambient temperature can impact

MOV motor output, such as described in Limitorque Technical Update 93-03, Reliance

3-Phase Limitorque Corporation Actuator Motors (Starting Torque @ Elevated

Temperature), dated September 1993, which is available from Flowserve Corporation.

The NRC inspectors found that licensees did not always ensure that sufficient

information and test data were developed to validate the assumptions for rate-of-loading

and load-sensitive behavior for plant-specific MOV applications. Stem lubricant

degradation can impact the performance of all types of MOV stem nuts, including the

ball-screw design. One-time stall torque limits for actuators are intended to address the

structural capability of the actuator rather than calculating performance capability.

  • Joint Owners Group (JOG) Program for MOV Periodic Verification: Most licensees

committed to implement the JOG Program on MOV Periodic Verification in response to

Generic Letter (GL) 96-05, Periodic Verification of Design-Basis Capability of

Safety-Related Motor-Operated Valves, dated September 18, 1996 (ADAMS Legacy

Library Accession No. 9609100488). The NRC staff accepted the JOG topical report on

the JOG Program on MOV Periodic Verification in a safety evaluation report (SER) dated

September 25, 2006 (ML061280315), and the associated supplement dated

September 18, 2008 (ML082480638). In November 2006, the JOG issued Topical

Report MPR-2524-A, Joint Owners Group (JOG) Motor Operated Valve Periodic

Verification Program Summary (ML063490194), to reflect the final NRC SER and

included the JOG responses to NRC staff requests for additional information and the

final SER. The JOG MOV Program included a limited amount of MOV tests performed

by the participating licensees at their nuclear power plants over approximately 5 years to

assess whether there was a potential for degradation of valve friction coefficients for

various valve types and applications. Because of the limited amount of MOV test data

and the different methods used by individual licensees to evaluate the test data, the

valve friction coefficients determined for MOVs as part of the JOG MOV Program do not

represent a database of valve friction coefficients that can be applied in general to

calculate the thrust and torque required to operate various MOVs under design-basis

conditions. Therefore, the MOV test results collected by participants of the JOG MOV

Program are only applicable to the implementation of the JOG MOV Program. The NRC

inspectors found that licensees did not always re-justify the qualifying basis for MOVs

following extensive maintenance (such as disassembly) to determine whether the valves

were susceptible to performance degradation as part of the JOG MOV Program. The

JOG periodic verification test intervals are based on the margin and risk ranking of each

MOV within the scope of the JOG MOV Program, such that up-to-date POV risk rankings

are important when implementing the JOG MOV Program.

  • ASME OM Code, Appendix III, Preservice and Inservice Testing of Active Electric

Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants: As

required under 10 CFR 50.55a(b)(3)(ii), licensees implementing the 2009 or later

editions of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, must

meet the MOV requirements in ASME OM Code, Mandatory Appendix III. For MOVs

within the scope of the JOG MOV Program, a licensee may rely on the dynamic testing

conducted as part of that program to satisfy the requirement in Appendix III for a mix of

IN 2021-01, Supplement 1 static and dynamic testing. The ASME OM Code, Mandatory Appendix III, as

incorporated by reference in 10 CFR 50.55a relies on new MOVs being demonstrated to

be capable of performing their safety functions.

testing requirements for MOVs in the ASME OM Code by requiring that licensees

establish a program to ensure that MOVs continue to be capable of performing their

design-basis safety functions. When implementing the JOG MOV Program, the MOV

diagnostic test frequency is based on the provisions of the JOG MOV Program, such as

when the design-basis capability margin is determined to be low. Licensees committed

to implementing the JOG MOV Program are expected to follow their commitment

process to modify the JOG MOV Program test intervals or notify the NRC in accordance

with that process. For example, the JOG MOV Program does not include grace periods

for the specified JOG test intervals. Further, the JOG program schedule is specified in

years rather than refueling outages. In addition, a change in the risk ranking of an MOV,

or an adjustment to MOV capability margin based on performance data, can result in a

different diagnostic testing interval under the JOG MOV Program.

that some MOVs are outside the scope of the JOG MOV Program, which are defined by

JOG as Class D valves. Therefore, licensees committed to implementing the JOG MOV

Program to satisfy GL 96-05 and that are implementing the JOG MOV Program as part

of their compliance with 10 CFR 50.55a(b)(3)(ii) are required by the NRC regulations to

establish methods to periodically demonstrate the design-basis capability of their

Class D valves. The NRC staff considers it infeasible to modify the classification of a

JOG Class D valve to a JOG Class A or JOG Class B valve, which the JOG defines as

not susceptible to degradation by direct information or not susceptible to degradation by

extension, respectively.

  • Electric Power Research Institute (EPRI) MOV Performance Prediction Methodology

(PPM): The NRC inspectors found that licensees evaluating MOVs using the EPRI

MOV PPM did not always address all of the applicable provisions when determining

valve operating requirements under the EPRI MOV PPM Program. JOG Topical

Report MPR-2524-A, and the EPRI MOV PPM Topical Report TR-103237, as

accepted in the applicable NRC safety evaluations1 specify the conditions for

implementing these programs. As part of the EPRI MOV PPM Methodology, EPRI

assumed that each valve is maintained in good condition for the EPRI MOV PPM to

remain valid for that valve. Therefore, MOVs classified as JOG Class A or JOG

Class B need to be maintained in good internal condition to satisfy the EPRI MOV

PPM. Further, this method includes EPRI Type 1 warnings, which indicate potential

valve damage, when implementing the EPRI MOV PPM. Where the EPRI MOV PPM

is used as the best available information, industry data should be monitored for those

valves to identify any information that might challenge that assumption. When

implementing the EPRI MOV PPM for butterfly valves, the calculated maximum

transmitted torque is applied when evaluating the acceptability of the valve weak link

and actuator ratings. When applying the EPRI MOV PPM for globe valves, the globe

valve model in the EPRI methodology specifies the provisions to be implemented, such as using the outside seat diameter to calculate the required operating thrust.

1 The EPRI MOV PPM safety evaluation report is available at ML15142A761 with later updates based on topical

report supplements.

IN 2021-01, Supplement 1 Separate EPRI guidance for evaluating MOV diagnostic test data obtained under

static conditions (i.e., without differential pressure or flow) cannot be applied beyond

the capability of that testing to predict MOV performance under dynamic conditions

(i.e., differential pressure and flow). Additional guidance on the EPRI methodology is

provided in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power

Plants, Revision 3, issued July 2020 (ML20202A473).

  • Limitorque Actuator Structural Capability: The NRC inspectors found that licensees

evaluating Limitorque motor actuators for their structural capability did not always justify

increasing the thrust ratings beyond their original limits. Limitorque Technical Update

92-01, Thrust Rating Increase SMB-000, SMB-00, SMB-0 & SMB-1 Actuators (undated

technical guidance available from Limitorque) evaluated Kalsi Engineering Document

  1. 1707C (a proprietary report by Kalsi Engineering) and approved its use to increase the

maximum allowable thrust for Limitorque actuator models SMB-000, SMB-00, SMB-0,

and SMB-1 up to 140 percent of the original ratings, with certain conditions.2 Limitorque

has indicated that licensees that participated in the Kalsi study or that possess a copy of

proprietary Kalsi Engineering Document #1707C may apply the 162 percent maximum

thrust rating described in the Kalsi report, where the specific conditions are implemented

as provided in that document. The individual POV subparts are expected to be able to

withstand the maximum thrust and torque that the POV actuator can produce

(sometimes referred to as a weak link evaluation). The structural limits specified in the

ASME Boiler and Pressure Vessel Code are not applicable to POV internal parts that

involve the operating motion of the valve and actuator. Proper bolt material and length

are part of weak link calculations for POVs.

  • POV Testing: For POV diagnostic testing, the NRC inspectors found that licensees did

not always ensure that (1) POV tests were properly conducted, (2) acceptance criteria

for the POV testing applied the correct assumptions (such as actuator thrust limits), (3)

proper evaluations of test data were completed to demonstrate that the POVs can

perform their safety functions, and (4) records of evaluations were maintained in

accordance with plant procedures. Computer software relies on appropriate values for

applicable parameters to be input when conducting diagnostic testing to determine

accurate thrust and torque values (such as proper stem material properties). POV test

acceptance criteria are expected to be properly translated from POV design calculations

into test procedures. Diagnostic equipment are expected to be installed and operating

properly as part of the POV testing and evaluation of results. Operating requirements for

valves apply throughout the full valve stroke. Fully complete POV test data evaluations

will ensure that the required parameters (such as valve friction coefficient or valve factor, stem factor, and rate of loading) are properly calculated and within the acceptable range.

The JOG MOV Program specifies that valve friction values from testing are compared to

the JOG threshold values for valve friction to verify that the valve is operating in a

manner consistent with the results of the JOG program assumptions. Variation in valve

performance can occur when relying on a single test to establish POV operating

requirements.

  • POV Leakage Limitations: Some POVs have specific limitations related to leakage past

the valve disk when closed. MOVs can be set to fully close and meet their leakage

2 NRC IN 92-83, Thrust Limits for Limitorque Actuators and Potential Overstressing of Motor-Operated

Valves, dated December 17, 1992, discussed Limitorque Technical Update 92-01 and the applicable study

by Kalsi Engineering.

IN 2021-01, Supplement 1 limitations when controlled by the torque switch. MOVs that have a safety function to

close and be leaktight have more challenges when controlled by the limit switch instead

of the torque switch. For example, the NRC inspectors found that licensees did not

always have a valid test or analysis demonstrating that the limit switch control setting of

the MOV under static conditions would achieve the required leaktight performance when

the MOV is closed under dynamic conditions. The leak rate requirements are also to be

addressed for MOVs with long closing torque switch bypass settings. The ASME OM

Code as incorporated by reference in 10 CFR 50.55a requires a documented program

for leak-testing power-operated relief valves. With respect to previous POV capability

issues, GL 79-46, Containment Purging and Venting During Normal Operation

Guidelines for Valve Operability, dated September 27, 1979 (ML031320191), provides

recommendations to demonstrate that containment purge valves can close and seal

under design-basis conditions, including seismic loads.

  • POV Qualification: The NRC inspectors found that licensees did not always justify the

qualification of POVs to perform their design-basis safety functions, including functional, environmental, and seismic capability. With respect to environmental qualification, preventive maintenance activities include replacing all valve subcomponents within their

specific qualified lifetime. Environmental effects can affect the performance of POVs

(including squib valves) that must remain functional for long periods of time following a

loss-of-coolant accident or other adverse conditions. NRC inspections identified that

some licensees lacked adequate justification to extend the qualified life of POVs

installed in their nuclear power plants. Limitorque qualified its safety-related MOV

actuators for 40 years or 2,000 cycles, whichever comes first. Licensees may extend the

qualified life of their Limitorque actuators if they have adequate justification. The

justification for the extension of the qualified life of the actuator, including attention to

radiation levels and ambient temperature conditions where MOVs are located, includes

assurance that the environmental qualification requirements are not exceeded and that

appropriate replacement frequencies for MOVs or their individual parts are established.

EPRI has developed guidance for extending the qualified life of Limitorque actuators

beyond their original qualified life. The presence of radiation hot spots and ambient

temperature conditions can impact the service life for the environmental qualification of a

valve actuator.

  • MOV Stem-Disk Connections: The NRC staff discussed operating experience with

MOV stem-disk connections in IN 2017-03, Anchor/Darling Double Disc Gate Valve

Wedge Pin and Stem-Disc Separation Failures, dated June 15, 2017 (ML17153A053). The BWROG prepared guidance to address the issue of potential

failure of the stem-disk connection in Anchor/Darling double-disk gate valves. The

BWROG guidance (such as evaluating the weak link of the wedge pin under motor

stall conditions) includes specific provisions in assessing the susceptibility for

separation of the stem-disk connection in Anchor/Darling double-disk gate valves.

  • Valve Position Verification: Paragraph ISTC-3700, Position Verification Testing, in

Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear

Power Plants, of the ASME OM Code requires that valves with remote position

indicators be observed locally at least once every 2 years to verify that valve

operation is accurately indicated. The NRC regulations in 10 CFR 50.55a(b)(3)(xi)

specify supplemental position indication (SPI) requirements when implementing

ASME OM Code, 2012 Edition (or later editions), paragraph ISTC-3700, for

licensees to verify that valve operation is accurately indicated by supplementing

IN 2021-01, Supplement 1 valve position indicating lights with other indications, such as flow meters or other

suitable instrumentation, to provide assurance of proper obturator position for valves

with remote position indication within the scope of Subsection ISTC including its

mandatory appendices and their verification methods and frequencies. Licensees

proposing additional time to implement the 2012 or later editions of the ASME OM

Code (including 10 CFR 50.55a(b)(3)(xi)) may submit a request for an alternative in

accordance with 10 CFR 50.55a(z) for NRC staff review. Additional information on

this topic is found in two monthly Reactor Oversight Process meeting summaries

(ML21041A409 and ML21047A290). The NRC regulations in 10 CFR

50.55a(b)(3)(xi) require verification of valve position indication, including specifying

actions to meet SPI requirements such as leakage testing, flow measurement, or

diagnostic trace analysis.

anomalous behavior that might adversely impact valve performance. A bent or damaged

stem can cause packing loads to become more severe with valve operation. On

occasion, some licensees backseat the stem of a valve to limit packing leaks. The NRC

inspectors found that licensees did not always conduct a detailed evaluation (including

appropriate examination) of the effects of backseating on the valve bonnet and stem to

verify structural integrity. NUREG-1482 provides additional guidance for controlling the

backseating process for a valve stem.

  • Use of POV Computer Software: The NRC inspectors found that licensees did not

always perform a complete verification and validation of POV computer software prior to

implementation. These calculation methodologies need verification and validation for

appropriate assumptions and data points. Further, stroke time might be calculated

improperly when computer data are used to measure the MOV stroke time. The ASME

OM Code specifies that the stroke time for a valve begins with the initiating signal and

ends with completion of the valve stroke. However, some computer data output does not

include the initial portion of the stroke signal for calculating the stroke time. It is important

to update POV programs to address new computer software used in POV calculations.

  • MOV Thermal Overload Devices: Thermal overload devices are installed in the control

circuitry for some MOVs to protect the motor from damage in the event of an overload

event. The performance of thermal overload devices can impact the safety function of

MOVs if not evaluated periodically. NRC Regulatory Guide 1.106 (Revision 2), Thermal

Overload Protection for Electric Motors on Motor-Operated Valves, dated

February 2012 (ML112580358) provides guidance for the use of thermal overloads that

reflects lessons learned from MOV programs.

  • MOV Throttling Operation: Motors used to operate MOVs have limitations regarding their

operating time. Limitorque specifies cooldown times for the frequent operation of MOV

motors. The NRC inspectors found that licensees did not always evaluate the impact of

motor heat-up on the capability of MOVs with design-basis safety functions to throttle

system flow.

  • Actuator Handwheel Operation: Some licensees rely on the actuator handwheel to

manually operate MOVs to perform important functions at their nuclear power plants. For

such MOVs, the NRC inspectors found that licensees did not always evaluate the

handwheel for proper sizing and good working condition in demonstrating that the MOV

IN 2021-01, Supplement 1 could perform its safety function. Improperly operating a valve by its manual handwheel

can result in excessive handwheel torque that can damage the actuator and the valve.

  • Preventive Maintenance and Modifications: The NRC inspectors found that licensees

did not always determine a proper lubrication interval for each MOV stem to address

potential lubrication grease degradation which can adversely affect MOV operation.

MOVs installed in non-normal positions can cause MOV maintenance issues. For

example, grease leakage into the limit switch compartment might interfere with the

electrical operation of actuator wiring. Further, an MOV oriented with the disk in the

horizontal plane can lead to abnormal performance of a gate valve as a result of

increased disk and guide wear over time. In addressing potential pressure locking of a

valve, modifications that prevent a valve from pressure locking, such as drilling a hole in

the valve disk, can have long-term consequences (such as a permanent one-way valve).

The NRC regulations in 10 CFR 50.59, Changes, tests and experiments, are applicable

to pressure-locking modifications for MOVs. Potential degradation of magnesium rotors

in motors can adversely impact MOV performance. Missing or damaged external and

internal parts of motors and actuators can impact operational readiness or qualification

of a POV.

  • Corrective Action: The NRC inspectors found that licensees did not always ensure that

appropriate corrective actions in accordance with plant procedures were implemented

when (1) POV test results fell outside of the specified acceptance criteria, (2) POV

performance anomalies were observed, such as abnormal diagnostic traces or valve

friction degradation, or (3) a mechanical problem with the POV was identified, such as a

manual declutch lever malfunction. The ASME OM Code as incorporated by reference in

10 CFR 50.55a includes corrective action requirements for POV leak testing. Overload

events when testing or operating POVs are expected to be addressed in accordance

with the licensees corrective action program and the manufacturer recommendations.

  • POV Records: The NRC inspectors found that licensees did not always follow their

procedures for maintaining records associated with POV qualification, testing, operation, maintenance, and corrective action, in accordance with the quality assurance

requirements in 10 CFR Part 50, Domestic Licensing of Production and Utilization

Facilities, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel

Reprocessing Plants. As part of the QA program, POV performance is monitored and

appropriate reports prepared in accordance with plant procedures to identify any

adverse indications.

  • IST Programs and Technical Specifications: Nuclear power plant licensees are required

to meet the NRC regulations in both 10 CFR 50.36, Technical specifications, and

10 CFR 50.55a for IST programs. Following the criteria in 10 CFR 50.59(c)(1), licensees

must prepare a license amendment to revise its technical specifications when making

changes to POV parameters (such as main steam isolation valve accumulator pressure)

as part of its IST program.

Testing for Water-Cooled Power Reactors: The ASME OM Code, as incorporated by

reference in 10 CFR 50.55a, allows licensees to follow leak testing intervals for valves in

accordance with 10 CFR Part 50, Appendix J, in certain instances. Licensees might

perform POV static testing to meet the containment leakage testing requirements in

10 CFR Part 50, Appendix J. In addition, the NRC regulations in 10 CFR 50.55a(b)(3)(ii)

IN 2021-01, Supplement 1 require that MOV design-basis capability be justified periodically. POV leakage

requirements might be specified in final safety analysis as part of the IST program

description, in addition to the 10 CFR Part 50, Appendix J, requirements.

The NRC staff discussed the above issues in detail with the applicable licensees during the

POV inspections. The licensees took action to address any immediate concerns related to these

issues identified by the NRC inspectors. In many instances, the issues were determined to be

minor because of the capability margin available for the specific POVs being evaluated at the

applicable nuclear power plant. The issues might have been more significant where less

capability margin was available for POVs at other nuclear power plants. Some licensees

initiated long-term activities as appropriate to address specific issues as part of their corrective

action programs. The NRC staff suggests that licensees review this information for applicability

to their facilities and consider actions, as appropriate, to identify and address similar issues.

CONTACT

S

This IN requires no specific action or written response. Please direct any questions about this

matter to the technical contacts listed below or to the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

/RA/

Russell Felts, Director

Division of Reactor Oversight

Office of Nuclear Reactor Regulation

Technical Contacts:

Douglas Bollock, NRR Kenneth Kolaczyk, NRR Thomas Scarbrough, NRR

301-415-6609 585-773-8917 301-415-2794 Douglas.Bollock@nrc.gov Kenneth.Kolaczyk@nrc.gov Thomas.Scarbrough@nrc.gov

Note: NRC generic communications may be found on the NRC public website, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML23129A014 EPIDS No.

NRR/DEX/EMI NRR/DRO/IOEB/

OFFICE Author QTE OE

B/BC PM

Jay PClark

NAME TScarbrough SBailey JPeralta

Dougherty

DATE 5/22/23 5/15/2023 5/18/23 5/19/23 5/22/23 NRR/DRO/ NRR/DRO/IOE NRR/DRO/I

OFFICE NRR/DRO/LA NRR/DRO/D

IOEB/PM B/PM OEB/BC

NAME IBetts BBenny PClark LRegner RFelts

DATE 7/13/2023 5/22/23 5/22/23 7/20/23 7/24/23