Letter Sequence Approval |
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EPID:L-2020-LLR-0046, Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves (Approved, Closed) |
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MONTHYEARML20089A0082020-03-29029 March 2020
Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves
Project stage: Request
ML20092L8532020-03-31031 March 2020
Email Limerick Generating Station, Unit 1 (LGS) - MOVs Relief Request Verbal Authorization Related to COVID-19 Issues
Project stage: Approval
ML20090A6522020-03-31031 March 2020
Verbal Authorization of Relief Request GVRR-9
Project stage: Approval
ML20090B4102020-06-0202 June 2020
Issuance of Relief Request GVRR-9 Associated with Pandemic-Related Issues - Inservice Testing Interval Extension for Motor Operated Valves (EPID L-2020-LLR-0046 (COVID-19))
Project stage: Approval
2020-03-31
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Category:Code Relief or Alternative
MONTHYEARML23354A0032024-01-19019 January 2024
Authorization and Safety Evaluation for Alternative Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations
ML23278A1292023-12-14014 December 2023
Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines
ML21280A0782021-10-27027 October 2021
Proposed Alternative to Use of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case N-893 (Epids L-2020-LLR-0147 and L-2020-LLR-0148)
ML21230A2062021-09-0303 September 2021
Proposed Alternative to Use ASME OM Code Case OMN-28
ML21216A2202021-08-0505 August 2021
Proposed Alternative to Eliminate Certain Documentation Requirements for Pressure Retaining Bolting
ML20322A0092020-12-10010 December 2020
Issuance of Alternative Requests 41-VRR-8 and 41-VRR-7 Regarding Certain Inservice Testing Program Requirements for Safety Relief Valves
ML20280A7572020-11-0505 November 2020
Revised Safety Evaluation of Relief Requests GVRR-8, 11 PRR-1, 90 PRR-1, and 47 VRR-2 Regarding the Fourth 10-Year Interval of the Inservice Testing Program (EPID L-2018-LLR-0384 Through EPID L-2018-LLR-0387)
ML20269A2002020-09-30030 September 2020
Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI (EPID L2020-LLR-0117
ML20252A1352020-09-0404 September 2020
Relief Request I4R-24 Associated with Residual Heat Removal Heat Exchanger Category C-A and C-B Examinations
ML20188A2642020-07-0606 July 2020
Clinton Power Station, R.E. Ginna Station, Limerick Station, Nine Mile Point Station & Peach Bottom Station - Proposed Alternative to Utilize Code Case OMN-26 - Response to Request for Additional Information
ML20113F0412020-04-30030 April 2020
Proposed Alternative to the Submittal Schedule for Certain Reports (COVID-19)
ML20099D9552020-04-17017 April 2020
Request to Use Provisions in the 2013 Edition of the ASME Boiler and Pressure Vessel Code for Performing Non-Destructive Examinations
ML20093M8202020-04-0303 April 2020
Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLR-0014 (COVID-19))
ML20090A6522020-03-31031 March 2020
Verbal Authorization of Relief Request GVRR-9
ML20089A0072020-03-31031 March 2020
Verbal Authorization by the Office of Nuclear Reactor Regulation for Relief Request I4R-23
ML20089A0082020-03-29029 March 2020
Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves
ML20088B0222020-03-28028 March 2020
Relief Request I4R-23 Associated with Pandemic Related Issues - Examination of Containment Surfaces Requiring Augmented Examination (Category E-C)
RS-20-020, Relief Request for Alternative Frequency to Supplemental Indication Requirements of 10 CFR 50.55a(b)(3)(xi)2020-02-28028 February 2020
Relief Request for Alternative Frequency to Supplemental Indication Requirements of 10 CFR 50.55a(b)(3)(xi)
ML19228A1952019-10-28028 October 2019
Safety Evaluation of Relief Requests GVRR-8, 11-PRR-1 and 47-VRR-2 Fourth 10-Year Interval of the Inservice Inspection Program EPID L-2018-LLR-0384, EPID L-2018-LLR-0385, EPID L-2018-LLR-0386, and
ML19269C5342019-09-27027 September 2019
Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques
ML19161A2572019-06-0404 June 2019
BWR Fleet Msv/Srv - Testing Frequency Relief Request NRC Pre-Application Meeting June 4, 2019
ML19098A0342019-04-30030 April 2019
Units 1 and 2; Limerick, Units 1 and 2; Peach Bottom, Units 2 and 3, and Quad Cities, Units 1 and 2 - Revision to Approved Alternative to Use BWR Vessel and Internal Proj Guidelins
ML19099A2632019-04-22022 April 2019
Issuance of Relief Request 14R-08, Revision 1, Regarding Pressure Testing of Containment Atmospheric Control Penetration Piping
ML19099A3072019-04-16016 April 2019
Issuance of Relief Request 14R-18 Associated with Inaccessible Supports for the Fourth 10-Year Inservice Inspection Interval Pipping
ML19009A0022019-03-0505 March 2019
Issuance of Relief Request IR4-17, Revision 1, Reactor Pressure Vessel Nozzle Repair in Lieu of Specific ASME Code Requirements
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
ML18274A0152018-10-0101 October 2018
Relief Request 14R-OB, Revision 1, Associated with Pressure Testing of Containment Atmospheric Control Penetration Piping
ML18165A0022018-06-11011 June 2018
Relief Request 14R-18 Associated with Inaccessible Emergency Service Water and Residual Heat Removal Service Water Pump Supports
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
JAFP-18-0052, Proposed Alternative to Utilize Code Case N-8792018-05-30030 May 2018
Proposed Alternative to Utilize Code Case N-879
ML18129A3312018-05-0404 May 2018
Proposed Relief Request Associated with Reactor Pressure Vessel Nozzle Repairs
ML17208A0902017-08-14014 August 2017
Relief Request I4R-17 Associated with the Alternate Repair of a 2-Inch Instrument Line Nozzle at Penetration N-16D on the Reactor Pressure Vessel
ML17170A0132017-06-26026 June 2017
Proposed Alternative to Eliminate Examination of Threads in Reactor Pressure Vessel Flange (CAC Nos. MF8712-MF8729 and MF9548)
ML17137A3072017-05-17017 May 2017
Verbal Authorization by the Office of Nuclear Reactor Regulation for Relief Request I4R-17
ML17004A0632017-02-0707 February 2017
Proposed Alternative Request GVRR-8 Inservice Testing Program Third 10-Year Interval
ML16344A3242016-12-29029 December 2016
Safety Evaluation of Relief Request I4R-01 for the Fourth 10-Year Interval of the Inservice Inspection Program for Limerick Generating Station, Units 1 and 2
ML16301A4012016-11-21021 November 2016
Safety Evaluation of Relief Requests I4R-02 and I4R-10 for the Fourth 10-Year Interval of the Inservice Inspection Program for Limerick Generating Station, Units 1 and 2
ML16230A2372016-09-0606 September 2016
Fleet Request for Proposed Alternative to Use ASME Code Case N-513-4 (CAC Nos. MF7301-MF7322)
ML12121A6372012-05-10010 May 2012
Request to Use Code Case N-789
ML0930803822009-11-17017 November 2009
Evaluation of Relief Requests Associated with the Third Inservice Testing Interval (TAC ME0742 - ME0751)
ML0809803112008-04-30030 April 2008
Relief Request to Use Boiling Water Reactor Vessel & Internals Project Guidelines..
ML0312601152003-06-23023 June 2003
Relief Request Review, American Society of Mechanical Engineers Boiler and Pressure Vessel Code-Relief for Qualification Requirements for Dissimilar Metal Piping Welds
ML0311300292003-05-0505 May 2003
Relief from Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Concerning Check Valve Inservice Testing Program, MB4804 & MB4805
ML0306204912003-03-0303 March 2003
Relief, American Society of Mechanical Engineers Boiler and Pressure Vessel Code - Relief for Risk-Informed Inservice Inspection of Piping, MB4633 and MB4634
ML0208701612002-05-0202 May 2002
Evaluation of Relief Requests RR-05, RR-07, RR-12, Tables RR-12-5 and RR-12-9 and RR-13, Tables RR-13-8 (TAC Nos. MB1018 and MB1019)
ML0210607752002-05-0202 May 2002
Evaluation of Relief Request RR-12, Table RR-12-6, Rotation of Snubbers and Relief Valves (TAC Nos. MB1018 and MB1019)
ML0208604792002-03-15015 March 2002
Request for Relief, Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Class 1 & 2 Piping
ML0201501402002-02-14014 February 2002
Evaluation of Relief Request RR-12, Table RR-12-7, Underwater Welding (Tac Nos. MB1018 and MB1019)
ML0202502652002-02-14014 February 2002
Evaluation of Relief Request RR-04 - ASME Class 1, 2, 3 Snubbers Visual Examination and Functional Testing (TAC Nos. MB1018 and MB1019)
2024-01-19
[Table view] |
Text
VERBAL AUTHORIZATION BY THE NRC OFFICE OF NUCLEAR REACTOR REGULATION FOR RELIEF REQUEST GVRR-9 ASSOCIATED WITH PANDEMIC-RELATED ISSUES -
INSERVICE TESTING INTERVAL EXTENSION MOTOR-OPERATED VALVES LIMERICK GENERATING STATION, UNIT 1 EXELON GENERATION DOCKET NO. 50-352 MARCH 31, 2020 Technical Evaluation read by Thomas G. Scarbrough, Acting Chief, Mechanical Engineering and Inservice Testing Branch, Division of Engineering and External Hazards, NRC Office of Nuclear Reactor Regulation By letter dated March 29, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20089A008), Exelon Generation (the licensee) proposed an alternative to specific requirements in the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code:
Section IST (OM Code), for Limerick Generating Station, Unit 1 (Limerick Unit 1), pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 55a (10 CFR 50.55a).
In particular, the licensee submitted Relief Request GVRR-9 Associated with Pandemic Related Issues - Inservice Testing Interval Extension for Motor Operated Valves on March 29, 2020, requesting NRC authorization for a one-time Inservice Testing (IST) Program interval extension to the next refueling outage for diagnostic testing of 17 motor-operated valves (MOVs) at Limerick Unit 1. The licensee provided justification that compliance with the requirements in the ASME OM Code, Mandatory Appendix III, to conduct diagnostic testing of the specific MOVs at this time would result in a hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(z)(2).
In its alternative request, the licensee stated that the performance of diagnostic testing of the 17 specified MOVs at this time at Limerick Unit 1 would represent a hardship during this COVID-19 outbreak, because performing the MOV diagnostic tests would require work in close spaces which could be detrimental to the occupational health and safety of plant personnel. To support its request for a one-time extension of the diagnostic testing interval for these MOVs until the next refueling outage in the spring of 2022, the licensee provided the calculated functional margin, after accounting for uncertainties and degradation factors, for each specific MOV based on the most current diagnostic test data. The licensees calculations indicate that each of the MOVs has a functional margin of at least 10 percent. The licensee reports that its evaluation in preparing the alternative request included a review of the maintenance history of each MOV. The licensee states that no deficiencies, adverse trends, or open maintenance work orders were identified that would impact or degrade the performance capability of these MOVs.
The licensee reports that each MOV is undergoing the standard testing interval with acceptable performance. The licensee considers that the current acceptable performance and high functional margin supports reasonable assurance that each MOV will continue to be capable of performing its design function during the time interval of this alternative request.
Based on the information described above for the 17 specific MOVs at Limerick Unit 1 identified in the licensees submittal, the NRC staff finds that (1) previous diagnostic testing of those MOVs indicates their acceptable historical performance; (2) ongoing IST activities have not identified MOV performance concerns; (3) periodic maintenance activities will continue; and (4) a hardship exists for the performance of diagnostic testing of these MOVs at this time that would be contrary to the health and safety of plant personnel.
Therefore, the NRC finds that the licensees proposed alternative for a one-time extension of the diagnostic testing interval for the specified 17 MOVs at Limerick Unit 1 is acceptable. The proposed alternative will provide reasonable assurance that the MOVs will be operationally ready to perform their safety functions until the next refueling outage currently scheduled for the spring of 2022.
Authorization read by James Danna, Chief of the Plant Licensing Branch I, Office of Nuclear Reactor Regulation As Chief of the Plant Licensing Branch I, Office of Nuclear Reactor Regulation, I agree with the conclusions of the Mechanical Engineering and Inservice Testing Branch.
The NRC staff concludes that the proposed alternative will provide reasonable assurance that the MOVs will be operationally ready to perform their safety functions until the next refueling outage currently scheduled for the spring of 2022. The NRC staff finds that complying with the requirements of the ASME OM Code for diagnostic testing of the specified MOVs at Limerick Unit 1 at this time would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2).
Therefore, effective March 31, 2020, the NRC authorizes the use of the proposed alternative at Limerick Unit 1 until restart from the next refueling outage for Limerick Unit 1 in the spring of 2022. The licensees testing plans for these MOVs may be adjusted as appropriate by any subsequent NRC-authorized alternative requests.
All other ASME OM Code requirements as incorporated by reference in 10 CFR 50.55a for which relief or an alternative was not specifically requested and approved in this subject request remain applicable. If the licensee identifies a performance issue with any of these MOVs, the licensee will be expected to take action to implement the requirements of its technical specifications.
This verbal authorization does not preclude the NRC staff from asking additional clarification questions regarding the proposed alternative while subsequently preparing the written safety evaluation.
