ML24073A360
| ML24073A360 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/13/2024 |
| From: | V Sreenivas Plant Licensing Branch 1 |
| To: | Henry M Constellation Nuclear |
| Sreenivas V, NRR/DORL/LPL1, 415-2596 | |
| References | |
| EPID L-2024-LLR-0006 | |
| Download: ML24073A360 (2) | |
Text
From:
V Sreenivas To:
Henry, Michael:(Constellation Nuclear)
Cc:
Hipo Gonzalez; Thomas Scarbrough
Subject:
GINNA: REQUEST FOR ADDITIONAL INFORMATION (RAI) ALTERNATIVE REQUEST PR-03 SIXTH INTERVAL INSERVICE TESTING PROGRAM (EPID L-2024-LLR-0006)
Date:
Wednesday, March 13, 2024 3:17:00 PM
Background
By letter dated January 26, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24026A011), Constellation Energy Generation, LLC (CEG) submitted an alternative request to the U.S. Nuclear Regulatory Commission (NRC) for deferral of certain Inservice Testing (IST) Program requirements for the B Auxiliary Feedwater (AFW) Pump (PAF01B) at the R. E. Ginna Nuclear Power Plant (Ginna). The licensee proposes the alternative request in accordance with Title 10 of the Code of Federal Regulations (CFR), Part 50, Section 55a, Codes and standards, paragraph (z)(2).
Regulatory Requirements 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 American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (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 paragraphs 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in paragraph 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), Alternatives to codes and standards requirements, state:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or
(2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Request for Additional Information (RAI)
In its submittal, the licensee states that the request is pursuant to 10 CFR 50.55a(z)(2) based on the determination that compliance with the ASME OM Code comprehensive pump test and periodic verification pump test requirements cannot be achieved without considerable plant safety and reliability risks prior to significant repairs to address the disc separation of a Condensate Heater 4B Outlet Check Valve at Ginna. The licensee is requested to indicate whether the Condensate Heater 4B Outlet Check Valve is within the
scope of the IST Program at Ginna, and to discuss the evaluation of the check valve failure and whether any changes to IST Program activities related to check valves were necessary based on the extent of condition review of the check valve failure.
Please submit response to this RAI by March 28, 2024. If you have any questions, please contact me.
V. Sreenivas, Ph.D., CPM.,
Licensing Project Manager for Beaver Valley, Ginna, Seabrook Stations Division of Operating Reactors Licensing, LPL1 U.S. Nuclear Regulatory Commission V.Sreenivas@nrc.gov
Docket No.
50-244
cc: Listserv