NMP1L3420, Proposed Alternative to Implement Code Case OMN-28

Proposed Alternative to Implement Code Case OMN-28

ML21217A117
Person / Time
Site:	Calvert Cliffs, Peach Bottom, Nine Mile Point, Braidwood, Limerick, Ginna, Clinton
Issue date:	08/05/2021
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L3420, RS-21-081
Download: ML21217A117 (7)

Text

10 CFR 50.55a RS-21-081 NMP1L3420 August 5, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Proposed Alternative to Implement Code Case OMN28, Alternative Valve Position Verification Approach to Satisfy ISTC3700 for Valves Not Susceptible to StemDisk Separation In accordance with 10 CFR 50.55a, Codes and standards, paragraph (z)(1), Exelon Generation Company, LLC (Exelon), requests NRC approval of a proposed relief request associated with the use of ASME Code Case OMN28, Alternative Valve Position Verification Approach to Satisfy ISTC3700 for Valves Not Susceptible to StemDisk Separation.

Proposed Alternative to Implement Code Case OMN28 August 5, 2021 Page 2 Exelon requests your review and approval of this request by October 4, 2021.

There are no regulatory commitments contained in this letter.

If you have any questions, please contact Tom Loomis at 610-765-5510.

Respectfully, David T. Gudger Sr. Manager - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Relief Request to Utilize Code Case OMN28, Alternative Valve Position Verification Approach to Satisfy ISTC3700 for Valves Not Susceptible to Stem Disk Separation

Proposed Alternative to Implement Code Case OMN28 August 5, 2021 Page 3 cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Project Manager - Braidwood Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - R.E. Ginna Nuclear Power Plant Maryland DNR - S. Seaman Pennsylvania DEP - W. DeHaas NYSERDA - A. L. Peterson Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT Relief Request to Utilize Code Case OMN28, Alternative Valve Position Verification Approach to Satisfy ISTC3700 for Valves Not Susceptible to StemDisk Separation

10 CFR 50.55a Relief Request Revision 0 (Page 1 of 3)

Request to Utilize OMN-28 In Accordance with 10 CFR 50.55a(z)(1)

1. ASME Code Component(s) Affected:

The valves covered by this Code Case are those stemdisk separation nonsusceptible valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies, in accordance with regulatory requirements.

A listing of the valves requiring position indication and testing in accordance with ISTC-3700 was submitted as part of the Inservice Testing Program update performed as part of the interval update and latest revisions for each of the plants identified below.

2. Applicable ASME OM Code Edition:

American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2012 Edition with no Addenda. The Intervals dates are:

Station Code in Effect Start of Interval End of Interval Braidwood Station, OM-2012 Edition, no 7/29/2018 7/28/2028 Units 1 and 2 Addenda Calvert Cliffs Nuclear OM-2012 Edition, no 7/1/2018 6/30/2028 Power Plant, Units 1 Addenda and 2 Clinton Power OM-2012 Edition, no 7/1/2020 6/30/2030 Station, Unit 1 Addenda R. E.Ginna Nuclear OM-2012 Edition, no 1/1/2020 12/31/2029 Power Plant Addenda Limerick Generating OM-2012 Edition, no 1/8/2020 1/7/2030 Station, Units 1 and 2 Addenda Nine Mile Point OM-2012 Edition, no 1/1/2019 12/31/2028 Nuclear Station, Units Addenda 1 and 2 Peach Bottom Atomic OM-2012 Edition, no 11/16/2018 8/14/2028 Power Station, Units Addenda 2 and 3

3. Applicable Code Requirements

ISTC-3700 , Position Verification Testing, states: "Valves with remote position indicators shall be observed locally at least once every 2 yr to verify that valve operation is accurately indicated. Where practicable, this local observation should be supplemented by other indications such as use of flow meters or other suitable instrumentation to verify obturator position. These observations need not be concurrent. Where local observation is not

10 CFR 50.55a Relief Request Revision 0 (Page 2 of 3) possible, other indications shall be used for verification of valve operation. Position verification for active MOVs shall be tested in accordance with Mandatory Appendix III of this Division.

10 CFR 50.55a(b)(3)(xi) OM condition: Valve Position Indication states: When implementing paragraph ISTC-3700, "Position Verification Testing," in the ASME OM Code, 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees shall verify that valve operation is accurately indicated by supplementing 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.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and standards, paragraph (z)(1), an alternative is proposed to the requirement of ASME OM Code ISTC-3700. The position verification with Supplemental Position Indication (SPI) requires the valves to be exercised in the open and closed direction and the valves position verified by other indications such as use of flow meters or other suitable instrumentation to verify obturator position.

Code Case OMN-28, Alternative Valve Position Verification Approach to Satisfy ISTC3700 for Valves Not Susceptible to StemDisk Separation, has been determined to satisfy the valve position verification requirements in ASME OM Code, Subsection ISTC, paragraph ISTC3700, for valves that are not susceptible to stemdisk separation.

5. Proposed Alternative and Basis for Use

In lieu of compliance with the ISTC-3700, Exelon Generation Company, LLC (Exelon) proposes to implement Code Case OMN-28 on the basis that it provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a, Codes and standards, paragraph (z)(1).

The valves covered by this Code Case are those stemdisk separation nonsusceptible valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices and their verification methods and frequencies, in accordance with regulatory requirements. Valves with remote position indication within the scope of ASME OM Code, Subsection ISTA, paragraph ISTA1100, not satisfying the scope and provisions of this Code Case shall meet the valve position verification requirements in ASME OM Code, Subsection ISTC3700, in accordance with regulatory requirements.

To categorize a valve as not susceptible to stem-disk separation, the valve shall have a documented justification that the stemdisk connection is not susceptible to separation based on the internal design, service conditions, applications and evaluation of the stem disk connection using plantspecific and industry operating experience, and vendor recommendations. The plants subject to this relief request will prepare this justification.

Valves with remote position indicators that are not susceptible to stemdisk separation shall be verified to accurately represent valve operation as discussed in Section 1.4, Position

10 CFR 50.55a Relief Request Revision 0 (Page 3 of 3)

Verification Testing Requirements for Valves Not Susceptible to StemDisk Separation of the Code Case.

Code Case OMN-28 was approved for use by ASME on March 4, 2021.

No deviations from the Code Case are being proposed.

6. Duration of Proposed Alternative

The proposed alternative is for the remainder of the current intervals as provided in Section 2.

7. Precedent:

None

8.

References:

None