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MONTHYEARTMI-12-158, Three Mile, Unit 1, Submittal of Relief Request VR-01 Associated with the Fifth Inservice Testing (IST) Interval2012-10-18018 October 2012 Three Mile, Unit 1, Submittal of Relief Request VR-01 Associated with the Fifth Inservice Testing (IST) Interval Project stage: Request ML12321A0922012-11-16016 November 2012 E-mail Acceptance Review Project stage: Acceptance Review ML13044A6652013-02-13013 February 2013 Electronic Transmission, Draft Request for Additional Information Regarding Relief Request VR-01, Associated with the Fifth Inservice Testing Interval Project stage: Draft RAI ML13045A6432013-02-25025 February 2013 Request for Additional Information Regarding Relief Request VR-01, Associated with the Fifth Inservice Testing Interval Project stage: RAI TMI-13-043, Response to Request for Additional Information - Relief Request VR-01 Associated with the Fifth Inservice Testing (IST) Interval2013-03-15015 March 2013 Response to Request for Additional Information - Relief Request VR-01 Associated with the Fifth Inservice Testing (IST) Interval Project stage: Response to RAI ML13232A0512013-08-28028 August 2013 Relief Request VR-01, Proposed Alternative Testing of the Pressurizer Pilot Operated Relief Valve Project stage: Other 2013-02-13
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Category:Code Relief or Alternative
MONTHYEARML20099D9552020-04-17017 April 2020 Request to Use Provisions in the 2013 Edition of the ASME Boiler and Pressure Vessel Code for Performing Non-Destructive Examinations ML19269C5342019-09-27027 September 2019 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19226A0232019-09-19019 September 2019 Relief from the Requirements of the Asme Code Examination and Testing for Containment Unbonded Post-Tensioning System (EPID-L-2018-LLR-0132) ML19161A2572019-06-0404 June 2019 BWR Fleet Msv/Srv - Testing Frequency Relief Request NRC Pre-Application Meeting June 4, 2019 JAFP-19-0023, Relief Request Associated with the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography for Ferritic and Austenitic Piping Welds2019-02-15015 February 2019 Relief Request Associated with the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography for Ferritic and Austenitic Piping Welds JAFP-18-0052, Proposed Alternative to Utilize Code Case N-8792018-05-30030 May 2018 Proposed Alternative to Utilize Code Case N-879 JAFP-18-0053, Proposed Alternative to Utilize Code Cases N-878 and N-8802018-05-30030 May 2018 Proposed Alternative to Utilize Code Cases N-878 and N-880 ML16308A0272017-01-10010 January 2017 Relief from the Requirements of the ASME Code ML15163A2492015-09-15015 September 2015 Relief Request RR-14-01 Concerning Alternative Root Mean Square Depth Sizing Requirements TMI-14-136, Response to Request for Additional Information - Submittal of Relief Request RR-14-01 Concerning Alternative Root Mean Square (Rms) Depth Sizing Requirements2014-11-19019 November 2014 Response to Request for Additional Information - Submittal of Relief Request RR-14-01 Concerning Alternative Root Mean Square (Rms) Depth Sizing Requirements ML13232A0512013-08-28028 August 2013 Relief Request VR-01, Proposed Alternative Testing of the Pressurizer Pilot Operated Relief Valve ML13227A0072013-08-27027 August 2013 End-of-Interval Relief Request RR-12-01, Pressurizer Nozzle-to-Head Weld Examinations ML13227A0242013-08-15015 August 2013 Relief Requests PR-01, PR-02, and VR-02, Associated with the Fifth Ten-Year Inservice Test Interval TMI-12-168, Submittal of Relief Requests Associated with the Fifth Inservice Testing (IST) Interval2012-11-0707 November 2012 Submittal of Relief Requests Associated with the Fifth Inservice Testing (IST) Interval ML12121A6372012-05-10010 May 2012 Request to Use Code Case N-789 ML1117304752011-07-20020 July 2011 Fourth Inservice Inspection Interval Relief Requests I4R-02, I 4R-03, I4R-04, I4R-05, and I4R-06 TMI-11-017, Submittal of Relief Request RR-11-01 and RR-11-022011-02-10010 February 2011 Submittal of Relief Request RR-11-01 and RR-11-02 ML1029303472010-10-21021 October 2010 Acceptance of Requested Licensing Action Request for Relief l4R-02, Fourth Inservice Inspection Interval, Alternate Risk Informed Selection and Examination Criteria for Pressure Retaining Welds ML1026406132010-09-23023 September 2010 Supplemental Information Needed for Acceptance of Requested Licensing Action Request for Relief l4R-02, Fourth Inservice Inspection Interval, Alternate Risk Informed Selection and Examination Criteria for ML0830903882008-10-29029 October 2008 Request for Relief 2008-TMI-01 to Utilize Code Case N-725 ML0527906602005-10-0606 October 2005 Response to Request for Additional Information Request for Relief to Utilize Code Case N-638-1, Similar and Dissimilar Metal Welding Using Ambient Temperature Machine GTAW Temper Bead Technique, Section XI Division 1 ML0416705102004-07-21021 July 2004 (TMI-1) Request for Relief from Flaw Removal, Heat Treatment, and Nondestructive Examination Requirements for the Third 10-Year Inservice Inspection (ISI) Interval ML0416701962004-07-0202 July 2004 (TMI-1) Request for Relief (P5) for the Nuclear Service Closed Cooling Water (Nsccw) Pumps for Third 10-Year Inservice Testing (IST) Interval ML0334305002003-11-25025 November 2003 Additional Information Concerning a Proposed Alternative Associated with the Use of a Weld Overlay ML0333709532003-11-20020 November 2003 Additional Information Concerning a Proposed Alternative with the Use of Weld Overlay ML0335602922003-11-0707 November 2003 Additional Information Concerning a Proposed Alternative Associated with the Use of a Weld Overlay ML0335602942003-11-0303 November 2003 Proposed Alternative Associated with the Use of a Weld Overlay ML0323205482003-09-0505 September 2003 Request for Relief from Selected Aspects of ASME Code. 2020-04-17
[Table view] Category:Letter
MONTHYEARIR 07200077/20240012024-06-18018 June 2024 Constellation Energy Generation, LLC, Three Mile Island Nuclear Station, Unit 1 - NRC Inspection Report No. 07200077/2024001 ML24157A3672024-06-13013 June 2024 Updated Post-Shutdown Decommissioning Activities Report Request for Additional Information Transmittal Letter ML24135A1972024-06-13013 June 2024 – Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0091 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities ML24120A3242024-05-24024 May 2024 TMI-2 Email to Fws RS-24-055, 2023 Corporate Regulatory Commitment Change Summary Report2024-05-17017 May 2024 2023 Corporate Regulatory Commitment Change Summary Report ML24120A2552024-04-29029 April 2024 Annual Radiological Environmental Operating Report ML24121A2472024-04-29029 April 2024 and Three Mile Island, Unit 2 - 2023 Occupational Radiation Exposure Annual Report ML24113A0212024-04-18018 April 2024 (TMI-2), Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RS-24-002, Constellation Energy Generation, LLC - Annual Property Insurance Status Report2024-04-0101 April 2024 Constellation Energy Generation, LLC - Annual Property Insurance Status Report ML24065A0042024-03-28028 March 2024 Submittal of 2023 Aircraft Movement Data Annual Report ML24092A0012024-03-28028 March 2024 (TMI-2), Decommissioning Trust Fund Annual Report ML24088A0122024-03-28028 March 2024 Notification of Amended Post-Shutdown Decommissioning Activities Report (PSDAR) in Accordance with 10 CFR 50.82(a)(7), Revision 6 ML24085A2152024-03-25025 March 2024 (TMI-2) - Annual Notification of Property Insurance Coverage RS-24-023, Report on Status of Decommissioning Funding.2024-03-22022 March 2024 Report on Status of Decommissioning Funding. ML24052A0602024-03-20020 March 2024 – Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0061 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML24074A3922024-03-14014 March 2024 Response to Request for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 5 ML24075A0062024-03-14014 March 2024 List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected by Your Proposed Project ML24073A2312024-03-13013 March 2024 and Three Mile Island Nuclear Station, Unit 2 - Management Change ML24044A0092024-02-12012 February 2024 License Amendment Request – Three Mile Island, Unit 2, Historic and Cultural Resources Review, Response to Request for Additional Information IR 05000320/20230042024-02-0707 February 2024 TMI-2 Solutions, LLC, Three Mile Island Nuclear Station, Unit 2 - NRC Inspection Report 05000320/2023004 ML24038A0222024-02-0505 February 2024 Achp Letter on Section 106 Programmatic Agreement Participation IR 05000289/20230062024-01-29029 January 2024 Constellation Energy Generation, LLC, Three Mile Island Nuclear Station, Unit 1 - NRC Inspection Report No. 05000289/2023006 ML23342A1242024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan ML23325A1092024-01-0505 January 2024 Review of the Management Plan for Three Mile Island Station, Unit No. 2, Debris Material ML23354A2112023-12-20020 December 2023 Response to Request for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 5 ML23354A2062023-12-20020 December 2023 (TMI-2), Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000320/20230032023-11-28028 November 2023 TMI-2 Solutions, LLC, Three Mile Island Nuclear Station, Unit 2, NRC Inspection Report No. 05000320/2023003 ML23243A9082023-08-29029 August 2023 Shpo Letter to TMI-2 Regarding Section 106 Activities IR 05000320/20230022023-08-17017 August 2023 TMI-2 Solutions, LLC, Three Mile Island Nuclear Station, Unit 2 - NRC Inspection Report 05000320/2023002 ML23216A1772023-08-14014 August 2023 Consultation Letter to Rebecca Countess for TMI-2 ML23216A1742023-08-14014 August 2023 Consultation Letter to David Morrison for TMI-2 ML23216A1752023-08-14014 August 2023 Consultation Letter to Joanna Cain for TMI-2 ML23216A1732023-08-14014 August 2023 Consultation Letter to Christine Turner for TMI-2 IR 05000289/20230052023-08-14014 August 2023 Constellation Energy Generation, LLC, Three Mile Island Nuclear Station, Unit 1 - NRC Inspection Report 05000289/2023005 ML23216A1782023-08-14014 August 2023 Consultation Letter to Steve Letavic for TMI-2 ML23221A1402023-08-0808 August 2023 (TMI-2), Response to Requests for Additional Information for the TMI-2 Post-Shutdown Decommissioning Activities Report, Rev. 5 ML23200A1882023-07-31031 July 2023 TMI-2 Correction Letter Amendment 67 ML23209A7632023-07-28028 July 2023 Letter from PA Shpo to TMI-2 Solutions on Cultural and Historic Impacts of Decommissioning ML23192A8272023-07-10010 July 2023 TMI-2 Solutions, LLC - Response to Shpo Request for Additional Information for Er Project 2021PR03278.006, TMI-2 Decommissioning Project ML23167A4642023-07-0505 July 2023 Letter - TMI-2- Exemption 10 CFR Part 20 Append G Issuance ML23167A0312023-06-28028 June 2023 Acceptance Review and Schedule for the Request for Exemption from a Requirement from 10 CFR 20, Appendix G, Section Iii.E, EPID L-2023-LLE-0016 ML23171B0222023-06-19019 June 2023 (TMI-2) - Notification Pursuant to 10 CFR 72.140(d) Regarding Application of Previously Approved TMI-2 Quality Assurance Program to Independent Spent Fuel Storage Installation Activities ML23138A0662023-05-17017 May 2023 TMI-2 NHPA Section 106 Shpo Letter to NRC 5-17-23 ML23137A2822023-05-17017 May 2023 (TMI-2), Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E ML23026A3132023-05-0202 May 2023 Issuance of Exemption from 10 CFR 70.24 (EPID-L-2023-LLE-0003) ML23122A1842023-05-0101 May 2023 Shpo_Er_Summary_Letter 2024-06-03
[Table view] Category:Safety Evaluation
MONTHYEARML23094A2692023-04-20020 April 2023 Safety Evaluation - Exemption from 10 CFR 70.24 ML23051A0442023-03-31031 March 2023 Safety Evaluation ML23024A0122023-01-26026 January 2023 Letter to Energysolutions Transmitting Threshold Determination for Merger/Restructuring ML22074A0272022-04-0707 April 2022 TMI 1 ISFSI Emergency Plan Only SER Input ML20297A6272020-12-0404 December 2020 Issuance of Amendment No. 301 Removal of Cyber Security Plan License Condition ML20297A6352020-12-0303 December 2020 Issuance of Amendment No. 300 Deletion of Permanently Defueledt Technical Specification 3/4.1.4, Handling of Irradiated Fuel with Fuel Handling Building Crane ML20261H9252020-12-0202 December 2020 Issuance of Amendment No. 299 for Unit 1 Permanently Defueled Emergency Plan and Emergency Action Level Scheme Changes ML20279A3732020-12-0202 December 2020 Enclosure 3: TMI-2 LTA Safety Evaluation ML20244A2922020-12-0101 December 2020 Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation ML20134H9402020-07-0808 July 2020 Issuance of Amendments Revising the High Radiation Area Administrative Controls ML20021A0702020-04-0606 April 2020 Issuance of Amendments to Delete License Conditions for Decommissioning Trusts ML20065J4762020-03-11011 March 2020 Safety Evaluation Spent Fuel Management Plan ML19269C5342019-09-27027 September 2019 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19226A0232019-09-19019 September 2019 Relief from the Requirements of the Asme Code Examination and Testing for Containment Unbonded Post-Tensioning System (EPID-L-2018-LLR-0132) ML19211D3172019-08-29029 August 2019 Issuance of Amendment No. 297 Defueled Technical Specifications and Revised License Conditions ML19192A2442019-07-18018 July 2019 Proposed Alternative to Use ASME Code Cases N-878 and N-880 ML19065A1142019-04-18018 April 2019 Issuance of Amendment No. 296 for Unit 1 Changes to Emergency Plan for Post-Shutdown and Permanently Defueled Condition ML18305B4192018-12-14014 December 2018 Issuance of Amendment No. 295 Changes to Technical Specifications Sections 1.0, Definitions, and 6.0, Administrative Controls, for Permanently Defueled Condition ML18310A0322018-11-22022 November 2018 Safety Evaluation Input for Proposed Changes to the Three Mile Island Nuclear Station Emergency Plan for Post-Shutdown and Permanently Defueled Condition ML18206A2822018-08-0202 August 2018 Issuance of Amendments to Relocate the Staff Qualification Requirements ML17121A0492017-10-30030 October 2017 Safety Evaluation by the Office of Nuclear Reactor Regulation for the Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography ML17233A1382017-10-0505 October 2017 Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendment 293 Re: Changes to Technical Specifications 5.4.2, 6.1.2, and 6.2.2 (CAC No. MF9462) ML17137A3932017-06-23023 June 2017 Three Mile Island Nuclear Station, Units 1 And 2 Issuance of Amendment Re: Changes to the Emergency Plan Related to Staffing (CAC No. MF8147) ML17137A3882017-05-0909 May 2017 Safety Evaluation-Ultrasonic Examination Techniques in Lieu of Radiography-Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, Dresden Nuclear Pow ML17055A6472017-05-0808 May 2017 Brunswick, Catawba, McGuire, Shearon Harris, and H. B. Robinson - Issuance of Amendments to Revise Technical Specifications to Adopt TSTF-522, Revision 0 (CAC Nos. MF8422, MF8423, MF8424, MF8425, MF8426, MF8427, MF8428, and MF8429) ML17025A4092017-02-14014 February 2017 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (CAC Nos. MF0803 and MF0866) ML16308A0272017-01-10010 January 2017 Relief from the Requirements of the ASME Code ML15225A1582015-10-0101 October 2015 Issuance of Amendment for Temporary Restoration of the Borated Water Storage Tank Cleanup and Recirculation Operation (TAC No. 6504) ML15163A2492015-09-15015 September 2015 Relief Request RR-14-01 Concerning Alternative Root Mean Square Depth Sizing Requirements ML15153A2822015-07-30030 July 2015 Issuance of Amendments Revising the Completion Date for Milestone 8 of the Cyber Security Plan (TAC Nos. MF4728, MF4729, MF4730, MF4731, MF4732, MF4733, MF4734, MF4735, MF4736, MF4737, MF4738, MF4739, MF4740 ML15090A5842015-07-28028 July 2015 Issuance of Amendments Technical Specifications to Modify Reactor Coolant System Pressure Isolation Check Valve Maximum Allowable Leakage Limits ML15141A0582015-07-28028 July 2015 Issuance of Amendments Regarding Emergency Action Level Schemes (TAC Nos. MF4232-MF4251) ML15121A5892015-06-30030 June 2015 Issuance of Amendment Regarding Technical Specifications Task Force (TSTF) Traveler-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2, Using the Consolidated Line Item Improvement Process ML14330A3002014-12-30030 December 2014 Issuance of Amendment to Eliminate Certain Technical Specifications Reporting Requirements ML14226A9402014-12-24024 December 2014 Issuance of Amendments Regarding the Emergency Plan Definition of Annual Training (TAC Nos. MF3003, MF3004, MF3005, MF3006, MF3007, MF3008.. ML14175B5932014-07-31031 July 2014 Proposed Alternative to Utilize Code Case N-786, Alternative Requirements for Sleeve Reinforcement of Class 2 and 3 Moderate-Energy Carbon Steel Piping Section XI Division1 ML13325A0232013-12-13013 December 2013 Issuance of Amendment Revision to the Pressure and Temperature Limit Curves and the Low Temperature Overpressure Protection Limits ML13232A0512013-08-28028 August 2013 Relief Request VR-01, Proposed Alternative Testing of the Pressurizer Pilot Operated Relief Valve ML13227A0072013-08-27027 August 2013 End-of-Interval Relief Request RR-12-01, Pressurizer Nozzle-to-Head Weld Examinations ML13227A0242013-08-15015 August 2013 Relief Requests PR-01, PR-02, and VR-02, Associated with the Fifth Ten-Year Inservice Test Interval ML13134A4672013-06-10010 June 2013 Proposed Alternative RR-12-02 Regarding Weld Overlay of the Lower Cold Leg Letdown Nozzle Dissimilar Metal Welds and Alloy 600 Safe-End ML13114A9732013-05-12012 May 2013 Approval of Request to Use a Provision of a Later Addenda of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants ML12209A3922012-09-0404 September 2012 Issuance of Amendment Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection ML12121A6372012-05-10010 May 2012 Request to Use Code Case N-789 ML1210804372012-05-0707 May 2012 Issuance of Amendment Administrative Technical Specification Changes ML1208202662012-03-29029 March 2012 Request to Use Later Edition of Code for Listed Plants ML1134104692011-12-19019 December 2011 (TMI-1) - Third Inservice Inspection Interval Relief Requests RR-11-01 and RR-11-02 ML1123605812011-09-14014 September 2011 Issuance of Amendment Maximum Allowable Power with Inoperable Main Steam Safety Valves ML1121504862011-08-22022 August 2011 Issuance of Amendment Relocation of Equipment Load List from Technical Specifications to Updated Final Safety Analysis Report ML1121403972011-08-15015 August 2011 Proposed Alternative RR-10-02 Regarding Weld Overlay of the Pressurizer Spray Nozzle to Safe-End and Safe-End to Elbow Dissimilar Metal Welds 2023-04-20
[Table view] |
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UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 August28,2013 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 THREE MILE ISLAND NUCLEAR STATION, UNIT 1 -RELIEF REQUEST VR-01, PROPOSED ALTERNATIVE TESTING OF THE PRESSURIZER PILOT OPERATED RELIEF VALVE (TAC NO. ME9819)
Dear Mr. Pacilio:
By letter dated October 18,2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12292A585), supplemented by letter dated March 15, 2013 (ADAMS Accession No. ML 13074A700), Exelon Generation Company, LLC (the licensee) submitted proposed alternative request VR-01, associated with the fifth 1 O-year inservice test (1ST) interval at Three Mile Island, Unit 1 (TMI-1). This proposed alternative applies to certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code). VR-01 proposes an alternative method for testing of the Pressurizer Pilot Operated Relief Valve (PORV), submitted pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a(a)(3)(i).
The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of the proposed alternative, as discussed in the enclosed safety evaluation.
The NRC staff review concludes that alternative request VR-01 provides an acceptable level of quality and safety, and that it provides reasonable assurance that the PORV is operationally ready. Therefore, the NRC staff authorizes proposed alternative request VR-01, as proposed, for the fifth 10-year 1ST program interval at TMI-1, which begins on October 15,2013, and is scheduled to end on October 14, 2023.
M. Pacilio -If you have any questions, please contact the TMI-1 Project Manager, Mr. Peter J. Bamford, at 301-415-2833.
Sincerely, Veronica Rodriguez, Actin hief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.
Safety cc w/encl: Distribution via
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- UNITED STATES ,::,V 01> NUCLEAR REGULATORY COMMISSION
- ... .... ("> WASHINGTON, D.C. 20555-0001
<< 0 tn i: i' '*'" ",0 £' ****1' SAFETY EVALUATION BYTHE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING RELIEF REQUEST VR-01 PROPOSED ALTERNATIVE TESTING OF THE PRESSURIZER PILOT OPERATED RELIEF VALVE EXELON GENERATION COMPANY, LLC THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO. 50-289
1.0 INTRODUCTION
By letter dated October 18, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12292A585), supplemented by letter dated March 15, 2013 (ADAMS Accession No. ML13074A700), Exelon Generation Company, LLC (the licensee) submitted proposed alternative request VR-01, associated with the fifth 1 O-year inservice test (1ST) interval, at Three Mile Island, Unit 1 (TMI-1). The proposed alternative applies to certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code). VR-01 relates to a proposed alternative method for testing of the Pressurizer Pilot Operated Relief Valve (PORV), submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR). Part 50, Section 55a(a)(3)(i).
Specifically, the proposed alternative would utilize a bench testing protocol for the PORV in lieu of certain provisions of the ASME OM Code that require in-situ testing.
2.0 REGULATORY EVALUATION
Pursuant to 10 CFR 50.55a(f), "Inservice Testing Requirements," 1ST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda. Pursuant to 10 CFR 50.55a(a)(3), alternatives to ASME Code reqUirements may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternatives provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Based on the above, and subject to the NRC's findings with respect to authorizing the proposed alternative to the ASME OM Code given below, the NRC staff finds that regulatory authority exists for the licensee to request, and the NRC staff to authorize, the alternative requested by the licensee.
Enclosure
-The Code of Record for the TMI-1 fifth 10-year 1ST program is the ASME OM Code, 2004 Edition with Addenda through OMb-2006.
The TMI-1 fifth 10-year 1ST interval begins on October 15. 2013. and is currently scheduled to end on October 14. 2023. 3.0 TECHNICAL EVALUATION
3.1 Licensee's
Alternative Request The ASME OM Code requirements that apply to the TMI-1 PORV (1-RC-RV-2), applicable to this request, include requirements to exercise the valve after replacement, and requirements to perform exercise testing of the valve once per fuel cycle. Currently, the licensee satisfies these requirements by manually stroking the valve once every operating cycle. This is performed during plant startup following a refueling outage. The valve must also be stroke-timed during this exercise test. The licensee is proposing an alternative to this required in-situ testing for several reasons, stated as follows in the submittal dated October 18, 2012: There are several disadvantages to the in-situ testing of the PORV. The PORV is a 2.5 inch Dresser Electromatic, solenoid actuated, pilot operated relief valve. Operation of the pilot valve vents the chamber under the main valve disc which causes the main valve to open. The PORV requires steam pressure for the main disc to open. Stroke testing the PORV during cold shutdown conditions does not exercise the main valve disc which, therefore, does not satisfy the subject ASME OM Code requirements.
To test the PORV in-place, the RCS [reactor coolant system] must be pressurized to supply the necessary fluid (steam) pressure to open the main valve disc. Also, since the PORV design does not provide direct obturator position indication, the valve disc position must be inferred from alternate indications (tailpipe l:::.T, acoustic monitoring, RCS pressure decrease, or quench tank pressure or level rise). In-situ testing of the PORV also results in an in-surge of cooler water from the RCS hot leg into the pressurizer.
The resulting thermal cycle on the pressurizer surge line is a thermal stress concern. as described in NRC Bulletin 88-08 ("Thermal Stresses in Piping Connected to Reactor Coolant Systems")
and should be avoided. Requiring that the PORV be tested in-place prevents plant personnel from verifying proper reseating of the main valve disc because the discharge is not visible as it is during bench testing. Minor leakage would not be readily evident before it would cause damage to the main valve disc/seat.
Excessive leakage from the pilot valve can lead to inadvertent opening of the main valve and impair its ability to re-close.
The proposed alternative will allow testing of the PORV that is appropriate to demonstrate functionality without cycling the valve in place using reactor steam pressure.
This is consistent with NUREG-0737, "Clarification of TMI Action Plan Requirements," Item II,K.3.16, "Reduction of Challenges and Failures of Relief Valves," which recommended that the number of relief valve openings be reduced as much as possible and that unnecessary challenges should be avoided. The licensee proposes the following alternatives to the requirements regarding stroking following replacement, and once per refueling cycle, for the fifth 1ST interval at TMI-1: Bench testing of the PORV to satisfy valve exercise and stroke time requirements is performed at the vendor test facility prior to installation.
ExerCising of the valve at both the normal power operation set point and the Low Temperature Overpressure Protection (LTOP) set point (as provided in Technical Specification 3.1.12, "Pressurizer Power Operated Relief Valve (PORV), Block Valve, and Low Temperature Overpressure Protection (L TOP),,) will be verified during this testing. Measured stroke time will be based on the pressure response indication of main disc opening. The installed valve will be removed and replaced each refueling outage, with a spare valve that has been previously bench tested. The removed valve will be bench tested within one year of removal from the system. In-situ exercising of the PORV will be performed only as necessary to reestablish operational readiness after maintenance on an installed valve. In the application, the licensee provided a detailed justification for the use of bench testing in lieu of in-situ testing. Included in this justification was a table showing bench test stroke time history between August 31, 2000, and November 4, 2011, for both the L TOP function and the normal reactor coolant system pressure function of the PORV. According to the licensee, these results consistently show that the valve opens well within the 2-second limiting stroke time allowed by ISTC-5114(c) for rapid acting valves. 3.2 NRC Staff Evaluation The licensee has categorized the Pressurizer PORV, 1-RC-RV-2, as OM Code category BIC and, therefore, the valve is subject to the applicable test requirements of both ASME OM Code Subsection ISTC for power-operated valves and Mandatory Appendix I for pressure relief devices. The requirements of Mandatory Appendix I allow the valve to be removed from the system for testing and do not specifically require that the valve be exercised when it is returned to the system. However, paragraphs ISTC-3310 and ISTC-3510 could be interpreted to require in-situ exercising of the valve following replacement (lSTC-3310) or routinely at a once perfuel cycle frequency (ISTC-351 0). The licensee has determined that exercising the PORV in-situ is undesirable for a number of reasons. The NRC staff finds that exercising the PORV in-situ at normal steam pressures does present undesirable circumstances.
There is some precedent in ASME OM Code itself for not exercising relief devices following reinstallation after testing. For Boiling Water Reactor (BWR) Class 1 Main Steam Pressure Relief Valves with Auxiliary Actuating Devices, Mandatory Appendix 1-3410(d) allows that after removal and reinstallation for testing, the electrical and pneumatic connections may be verified by inspection in lieu of test, and that valve main disk movement (Le., exercise) is not required.
While this ASME OM Code example is not specifically applicable to Pressurized Water Reactor PORVs, it is analogous.
There is further precedent in a number of prior licensing actions wherein the NRC staff has approved technical specification changes for various licensees to remove routine in-situ exercise requirements for BWR Class 1 safety/relief valves for the same and similar reasons as presented by this licensee.
The licensee has proposed alternatives, which include a series of verifications and controls to demonstrate the operational readiness of the valve: Multiple bench test verifications performed in the same orientation as the plant installation and using test conditions similar to those in the plant installation, including ambient temperature, valve insulation, and steam conditions: exercising the pilot and main valve disk as a unit
- obturator movement stroke time testing seat leakage verification refurbishment, as needed The licensee indicates, and the NRC staff agrees, that performing some of these tests on the bench is actually preferred over in-situ testing because they can be performed more precisely.
Additional steps taken by the licensee to ensure operational readiness of the PORV are:
- Receipt inspection and storage in accordance with quality procedures to ensure protection against physical damage and moisture upon return to the plant site Pre-installation inspection for foreign material and damage Installation and connection in accordance with quality maintenance procedures Operation of the solenoid-actuated pilot valve (which controls the actuation of the valve main disk) in-situ to verify electrical power and control connections The licensee has further stated that if maintenance is ever required on an installed valve, in-situ exercising will be performed to reestablish operational readiness.
The NRC staff has reviewed the licensee's proposed alternative and concludes that implementation of these alternatives will continue to meet the fundamental intent of ASME OM Code to assure the PORV operational readiness and to permit detection of PORV degradation.
The proposed alternative demonstrates proper PORV operation without the need for in-situ testing with reactor steam, and therefore provides an acceptable level of quality and safety.
4.0 CONCLUSION
As set forth above, the NRC staff determines that for alternative request VR-01, the proposed alternative provides an acceptable level of quality and safety and also provides reasonable assurance that the PORV is operationally ready. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i).
All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.
Therefore, the NRC staff authorizes alternative request VR-01, to be implemented at TMI-1 for the fifth 10-year 1ST program interval, which is scheduled to begin on October 15, 2013, and conclude on October 14, 2023. Principle Contributor:
John Billerbeck, NRR Date: August 28, 2013 M. Pacilio -If you have any questions, please contact the TMI-1 Project Manager, Mr. Peter J. Bamford, at 301-415-2833.
Sincerely, Ira! Veronica Rodriguez, Acting Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289
Enclosure:
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