ML21102A260

One-Time Interval Extension for Supplemental Position Indication Testing

ML21102A260
Person / Time
Site:	Ginna
Issue date:	04/12/2021
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML21102A260 (5)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a April 12, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License Nos. DPR-18 NRC Docket No. 50-244

Subject:

One-Time Interval Extension for Supplemental Position Indication Testing In accordance with 10 CFR 50.55a, Codes and standards, paragraph (z)(2), Exelon Generation Company, LLC (Exelon), requests NRC approval of a proposed relief request associated with the Inservice Testing (IST) Program for the R. E. Ginna Nuclear Power Plant.

This request proposes a one-time extension to the 2-year Supplemental Position Indication (SPI) testing frequency for fifteen IST program valves.

The timing for implementation was not clear; therefore, several position verification tests were performed that were not supplemented with alternate indication to demonstrate obturator position. Compliance with the requirements of ISTC-3700 will create undue hardship without a compensating increase in the level of quality or safety. The earliest surveillance testing of these valves is due to expire on April 28, 2021; therefore, Exelon requests your review and verbal approval of this request by April 27, 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 Senior Manager - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Relief Request GR One-Time Interval Extension for SPI Testing cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - Ginna NRC Project Manager - Ginna

ATTACHMENT Relief Request GR One-Time Interval Extension for Supplemental Position Indication Testing

10 CFR 50.55a Relief Request: GR-03 Revision 0 (Page 1 of 3)

Request for Relief GR-03 One-Time Interval Extension for Supplemental Position Indication Testing In Accordance with 10 CFR 50.55a(z)(2)

1. ASME Code Component(s) Affected:

Pneumatically operated and motor operated valves with remote position indications were not verified in the open and/or closed position using a supplemental indication during the Ginna Nuclear Power Plant refueling outage conducted in April 2020. This includes the following valves:

Test Valve Code Description Category Type Expiration ID Class Excess Letdown Loop A Cold to Heat 310 1 B AOV 5/2/2021 Exchanger Valve Letdown Isolation Valve Residual Heat 371 Removal to Non-Regenerative Heat 2 A AOV 5/2/2021 Exchanger Reactor Coolant Pump A and B Seal 386 2 B AOV 5/2/2021 Bypass Valve Instrument Air to Containment Isolation 5392 2 A AOV 5/2/2021 Valve 835A Safety Injection Accumulator A Fill Valve 2 B AOV 5/2/2021 835B Safety Injection Accumulator B Fill Valve 2 B AOV 5/2/2021 Safety Injection Accumulator A Test 839A 2 B AOV 5/2/2021 Valve Safety Injection Accumulator B Test 840A 2 B AOV 5/2/2021 Valve Safety Injection Accumulator A Drain 844A 2 B AOV 5/2/2021 Valve Safety Injection Accumulator B Drain 844B 2 B AOV 5/2/2021 Valve Upper Containment Spray Charcoal 875A 2 B MOV 5/6/2021 Filter Dousing Valve Upper Containment Spray Charcoal 875B 2 B MOV 5/6/2021 Filter Dousing Valve Lower Containment Spray Charcoal 876A 2 B MOV 5/6/2021 Filter Dousing Valve Lower Containment Spray Charcoal 876B 2 B MOV 5/6/2021 Filter Dousing Valve Pressurizer Steam Space Sample 966A 2 A AOV 4/28/2021 Containment Isolation Valve

10 CFR 50.55a Relief Request: GR-03 Revision 0 (Page 2 of 3)

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.

3. Applicable Code Requirements

ISTC-3700 , Position Verification Testing, states: "Valves with remote position indicators shall be observed locally at least once every 2 years 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 possible, other indications shall be used for verification of valve operation.

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.

As required by 10 CFR 50.55a(b)(3)(xi), ISTC-3700 requirements became applicable on January 1, 2020 when the R. E. Ginna Nuclear Power Plant (Ginna) Inservice Testing (IST)

Program was updated to the 2012 Edition of the ASME OM Code.

4. Reason for Request

Pursuant to 10 CFR 50.55a, Codes and standards, paragraph (z)(2), compliance with the requirements of ISTC-3700 will create undue hardship without a compensating increase in the level of quality or safety. Compliance will require a plant shutdown to perform a SPI for the valves listed in Section 2.

The most-limiting Supplemental Position Indication (SPI) testing interval for these valves ends on April 28, 2021, based on the 2-year interval that came into effect on January 1, 2020 and considering the use of the 6-month interval extension allowed by ASME OM Code Case OMN-20, Inservice Test Frequency. The position verification with 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. The timing for implementation was not clear; therefore, several position verification tests were performed that were not supplemented with alternate indication to demonstrate obturator position.

This relief request proposes a one-time interval extension of eight months (December 28, 2021) which will allow testing during the next refueling outage which is scheduled to begin October 4, 2021. This extension will avoid a forced plant shutdown to achieve refueling conditions to permit safely stroking the identified valves.

10 CFR 50.55a Relief Request: GR-03 Revision 0 (Page 3 of 3)

5. Proposed Alternative and Basis for Use

As a proposed alternative to the 2-year SPI testing frequency required by ISTC-3700, this relief request proposes a one-time interval extension of eight months (December 28, 2021) which will allow testing during the next refueling outage which is scheduled to begin October 4, 2021. The listing of valves provided in Section 2 have satisfactorily passed their IST examinations for the past 10 years.

Any component degradation identified prior to the next outage will be evaluated per the Corrective Action Program for operability concerns and compliance with the IST Program and Technical Specifications.

The identified valves have demonstrated exceptional performance and reliability. The subject valves have no history of stem-disc separation. This was confirmed by an internal maintenance history search and by an INPO Industry Reporting Information System (IRIS) search for each valve make and model and review of EPRI Technical Report 3002019621 (Reference 1). The historical performance provides assurance of the valves capabilities to perform their design function(s) within the eight-month SPI interval extension. The past and current performance of each identified valve and the one-time interval extension bounded by test frequencies in existing regulations provide an acceptable level of quality and safety.

6. Duration of Proposed Alternative

The proposed alternative is a one-time interval extension of eight months for the Ginna SPI testing of the identified valves, with an end date of December 28, 2021.

7. Precedent:

None

8.

References:

1. EPRI Technical Report 3002019621, Susceptibility of Valve Applications to Failure of the Stem-to-Disk Connection