ML23192A755
| ML23192A755 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 07/14/2023 |
| From: | Xcel Energy |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| EPID L-2023-LRM-0045 | |
| Download: ML23192A755 (1) | |
Text
Monticello 10 CFR 50.55a(z)(2) Request to Defer PVT of MO-2397 07.14.2023
Agenda Purpose Applicable IST Requirements Proposed Alternative Schedule
© 2023 Xcel Energy 2
Purpose
© 2023 Xcel Energy Discuss proposed 50.55a(z)(2) alternative to the American Society of Mechanical Engineers (ASME) 2017 OM Code for the periodic verification testing (PVT) of the Monticello Nuclear Generating Plant (MNGP) motor-operated MO-2397 (Reactor Water Clean-Up Inboard Isolation Valve).
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Applicable IST Program Requirements
© 2023 Xcel Energy Code of Record: ASME OM Code, 2017 Edition Mandatory Appendix III-3300 Mandatory Appendix III-3310 Mandatory Appendix III-3722 4
Proposed (z)(2) Alternative
© 2023 Xcel Energy To test at a frequency of twelve years, until the MNGP spring 2025 refueling outage.
The valve would return to the test frequency of 2017 OM Code Mandatory Appendix III following the 2025 refueling outage.
This request would allow the testing of MO-2397 during the next refueling outage instead of a forced outage, avoiding a hardship without a compensating increase in the level of quality and safety.
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Reason
© 2023 Xcel Energy During the 2023 MNGP refueling outage, maintenance was performed without first conducting the as-found PVT.
PVT had been required to satisfy the 10-year frequency requirement.
Last As-Found PVT conducted in 2013; functional margin less than 10%
Actuator replacement in 2017 with as-left functional margin greater than 10%
MO-2397 is a Low Safety Significance Component (LSSC) located in the Drywell, which is a Locked High Radiation Area. Forced outage testing would require significant dose accumulation and increase industrial safety risk.
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Schedule
© 2023 Xcel Energy
- Submittal date - 7/24/2023
- NRC approval - 10/8/2023 7
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