ML20246G877

Licensee'S Presentation for September 3, 2020 Public Telephone Conference

ML20246G877
Person / Time
Site:	Calvert Cliffs
Issue date:	09/03/2020
From:	Dirado M, Deborah Neff, Waiters S Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
Marshall M, NRR/DORL/LPLI, 415-2871
References
EPID L-2020-LLR-0090
Download: ML20246G877 (10)

Text

Calvert Cliffs Nuclear Power Plant Supplemental Position Indication (SPI)

IST Program Relief Request September 3, 2020

Introductions

Presenters Dave Neff - Corporate Licensing Mark DiRado - Sr. Manager, Component Programs Sheldon Waiters - Manager, Engineering Programs Other Attendees Tom Haaf - Station Vice President Doug Hild - Director, Org. Performance and Regulatory Armando Johnson - Director, Corporate Engineering Shannon Rafferty-Czincila - Director, Corporate Licensing Ed Schinner Mike Faivus Todd Cervini Dave Helker Bill Reynolds Larry Smith Glenn Weiss Art Simpson Ashley Burress Frank Mascitelli 1

Regulatory Requirements for SPI Testing NRC rulemaking in August 2017 imposed a condition in 10 CFR 50.55a(b)(3)(xi) applicable to sites utilizing the 2012 ASME OM Code:

When implementing OM Code paragraph ISTC-3700, Licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flowmeters 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.

2017 Final Rule (10CFR50.55a) American Society of Mechanical Engineers Codes and Code Cases Analysis of Public Comments (NRC-2011-0088;RIN 3150-A197) states:

(1) The NRC agrees that additional time for implementation of the condition on valve position verification is appropriate. Therefore, the NRC has revised the condition to allow additional implementation time, as discussed below.

(2) The NRC agrees that the implementation date of this condition should be clarified. The NRC has revised this condition to indicate that it is associated with implementation of the 2012 Edition of the ASME OM Code. As such, nuclear power plant licensees will be required to implement the condition when adopting the 2012 Edition of the ASME OM Code as their code of record for the 120-month IST interval.

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Regulatory Requirements for SPI Testing Co de

• OM Code Paragraph ISTC-3700, Position Verification Testing, requires:

- Position Verification Testing of Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated.

• Where local observation is not possible, other indications shall be used for verification of valve operation.

- 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. (i.e., SPI testing does not need to be performed with the occurrence of the valve stroking/Position Verification test.

Position Verification and Supplemental Position Indication are considered two separate tests in the IST Program.)

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Regulatory Requirements for SPI Testing Co de

• 10 CFR 50.55a, Reg Guide 1.192 and the 2012 Edition of the OM Code form the approvals for use of Code Case OMN-20, Inservice Test Frequency.

• Code Case OMN-20 specifics:

- Components whose test frequencies are based on elapsed time periods shall be tested at the specified frequency (i.e., 2 years for ISTC-3700).

- For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test. (i.e., a frequency of up to 30 months for ISTC-3700).

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CCNPP Implementation of SPI Testing Requirement Co de

• CCNPP adopted the 2012 Edition of the ASME OM code on 7/01/2018 with implementation of the fifth ten-year interval of the Inservice Testing Program Plan.

• The additional testing specified by the Final Rule that added 10 CFR 50.55a(b)(3)(xi) became applicable to CCNPP on 7/01/2018 (i.e., t=0 for the new requirement).

• CCNPP Unit 2 Refueling outage was completed in March 2019 with some of the SPI testing still to be completed.

• The due date for the non-completed Unit 2 SPI testing was determined to be 12/31/2020 based on the testing frequency of ISTC-3700 with a starting date of 7/01/2018 and with a maximum extension of 6 months.

• CCNPP identified in May 2020 that (9) nine valves not previously tested required a reactor shutdown to conduct the SPI testing. The issue was placed in the CAP and action plans were developed to address the missed opportunity to perform SPI testing.

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CCNPP Relief Request for SPI Testing Requirement Co de

• Per 10 CFR 50.55a(z)(1), an IST Relief Request was submitted on 6/30/2020 that requested a one-time extension of four-months for the SPI testing interval for the nine valves (i.e., extension from 12/31/2020 to 4/30/2021).

• The Relief Request was submitted with a request for a six-month NRC review to have NRC approval prior to exceeding the end of the extended 30-month test interval.

• Each valve has had acceptable performance as evidenced by consecutive satisfactory as-found leakage tests with qualification for an extended test period in accordance with the Appendix J Program.

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NRC Acceptance of CCNPP IST RR Submittal Co de

• NRC accepted the Relief Request on 8/04/2020 and stated the submittal does provide technical information in sufficient detail to enable the NRC staff to complete their detailed technical review and make an independent assessment regarding the acceptability of the proposed relief in terms of regulatory requirements and the protection of public health and safety and the environment.

• During the acceptance review, the NRC staff identified an issue regarding the timeliness of the alternative request that might impact the NRC staffs review and the public meeting of 9/03/2020 is the result of the request to discuss this issue.

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Exelons Conclusion and Extent of Condition Review Co de

• Justification for an alternative testing interval was provided in the request for relief submitted on 6/30/2020 in accordance with 10 CFR 50.55a(z)(1) and was provided six months prior to the requested approval date.

• The safety significance of the missed SPI testing is very low based on past valve performance and that none of the nine valves are of a design that had experienced the stem-disc separation (i.e., not of a design that is the central concern for the SPI testing).

• CCNPP acknowledges a missed opportunity to schedule the testing of the nine valves listed in the Relief Request. This issue has been entered into CAP and appropriate actions are being taken.

• The action plan for completing the missed SPI testing was not timely and could have identified sooner the need for NRC approval of a Relief Request. This issue has been entered into CAP and appropriate actions are being taken.

• This SPI testing for CCNPP Unit 1 requiring an outage has been completed. All remaining on-line testing will be completed prior to 12/31/2020.

• An industry survey indicates that other Licensees have also started or are planning to start the SPI testing interval with the date they adopted the 2012 Edition of the OM Code. Furthermore the other Licensees have implemented a testing schedule that does not require the position indication and SPI testing to be performed concurrently.

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Questions 9