ML23256A166
| ML23256A166 | |
| Person / Time | |
|---|---|
| Issue date: | 10/11/2023 |
| From: | Osborne H NRC/OCFO |
| To: | Camilli N Electric Power Research Institute |
| Shared Package | |
| ML23256A163 | List: |
| References | |
| 3002023774 | |
| Download: ML23256A166 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 11, 2023 Nick Camilli Principal Project Manager/Team Leader Electric Power Research Institute 1300 West W.T. Harris Blvd Charlotte, NC 28262-8550
SUBJECT:
RESPONSE TO REQUEST FOR A FEE EXEMPTION FOR NRC REVIEW OF EPRI TECHNICAL REPORT 3002023774, EPRI MOV PERFORMANCE PREDICTION METHODOLOGY (PPM), VERSION 4.1
Dear Nick Camilli:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated August 18, 2023, (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML23234A117), requesting a fee exemption under Title 10 of the Code of Federal Regulations (10 CFR) 170.11(a)(1)(ii) for NRC review of EPRI Technical Report 3002023774, EPRI MOV Performance Prediction Methodology (PPM), Version 4.1.
NRC regulations pertaining to fee exemption requests are set forth in 10 CFR 170.11 Exemptions. The NRC staff reviewed your request consistent with the provisions in 10 CFR 170.11(a)(1)(ii) and 170.11(d). Section 170.11(a) states:
No application fees, license fees, renewal fees, inspection fees, or special project fees shall be required for: (1) A special project that is a request/report submitted to the NRC . . . (ii) When the NRC, at the time the request/report is submitted, plans to use the information to assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins) . . . .
Section 170.11(d) states:
All fee exemption requests must be submitted in writing to the Chief Financial Officer in accordance with § 170.5, and the Chief Financial Officer will grant or deny such requests in writing.
In your letter requesting an exemption from fees associated with the staffs review of Electric Power Research Institute (EPRI) Technical Report 3002023774, EPRI MOV [Motor-Operated Valve] Performance Prediction Methodology (PPM), Version 4.1, you state that the PPM software was built in response to NRC Generic Letter (GL) 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance, (June 28, 1989). Further, you indicate that the EPRI MOV PPM is the only NRC-approved method to conservatively predict the dynamic thrust and torque operating requirements for MOVs to perform their design-basis safety functions in nuclear power plants.
N. Camilli Initially, licensees of nuclear power plants used the EPRI MOV PPM in earlier versions of EPRI Technical Report 3002023774 to address and close out NRC GL 89-10. Since the closure of GL 89-10, licensees have applied the EPRI MOV PPM as part of their ongoing programs to meet the regulatory requirements in Part 50, Domestic Licensing of Production and Utilization Facilities, in Title 10, Energy, of the Code of Federal Regulations in Section 55a, Codes and standards, (10 CFR 50.55a) in paragraph (b)(3)(ii), OM Condition: Motor-Operated Valve (MOV) testing, to establish a program to ensure that MOVs continue to be capable of performing their design-basis safety functions. Nuclear power plant licensees also use the EPRI MOV PPM in satisfying their regulatory commitments to meet the NRC recommendations in GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves, (September 18, 1996) to establish a program to verify on a periodic basis that safety-related MOVs continue to be capable of performing their safety functions. Further, the combined license (COL) holder under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, for the Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, used the EPRI MOV PPM as part of its program for the qualification of MOVs to perform their safety functions in meeting the provisions of ASME Standard QME-1, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants, as accepted in NRC Regulatory Guide 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants. Other applicants for nuclear power plants have specified the use of ASME QME-1 Standard, which references the EPRI MOV PPM, for the qualification of MOVs to perform their design-basis safety functions at their facilities.
In addition, the NRC staff has incorporated EPRI Technical Report 3002023774 into its inspection programs as described below. The NRC staff established a light-water operating reactor inspection program for the operations phase in Inspection Manual Chapter (IMC) 2515.
The baseline inspection program element, described in Appendix A of IMC 2515, is to be performed at all operating reactors. Supplemental inspections are described in Appendix B of IMC 2515 and are performed as a result of performance issues that are identified by performance indicators, baseline inspections, or event analysis. One supplemental inspection procedure (IP) is IP 62708, Motor-Operated Valve Capacity, whose objective is to assess the extent of performance issues and the adequacy of the licensees evaluation associated with MOVs of nuclear power plants licensed under 10 CFR Part 50 or Part 52. IP 62708 directs inspectors to review the methods used for selecting, setting, and adjusting MOV switches. NRC inspectors are directed to the safety evaluation associated with EPRI MOV PPM (dated March 15, 1996), and several supplements to the safety evaluation.
For new nuclear power plants, the NRC staff prepared IP 73758, Part 52, Functional Design and Qualification, and Preservice and Inservice Testing Programs for Pumps, Valves and Dynamic Restraints, (February 6, 2020) to evaluate the establishment, implementation, and results of the functional design and qualification of pumps, valves, and dynamic restraints (snubbers) by COL holders for nuclear power plants in accordance with 10 CFR Part 52. IP 73758 is also used by NRC inspectors to evaluate the establishment, implementation, and results of preservice testing and Inservice testing programs for pumps, valves, and dynamic restraints by COL holders for nuclear power plants in accordance with 10 CFR Part 52. IP 73758 includes provisions for NRC inspectors to evaluate the implementation of the EPRI MOV PPM by COL holders for Part 52 nuclear power plants to verify the functional design, qualification, and testing of MOVs to perform their design-basis safety functions. Recently, the NRC staff used IP 73758 in evaluating the implementation of the EPRI MOV PPM by the COL holder for Vogtle Units 3 and 4 in demonstrating the capability of MOVs to perform their design-basis safety functions to support the startup of those reactors.
N. Camilli Regulatory Issue Summary (RIS) 2000-03, Resolution of Generic Safety Issue [GSI] 158:
Performance of Safety-Related Power-Operated Valves [POVs] Under Design Basis Conditions, (March 15, 2000) stated that the NRC staff would continue to monitor the activities of nuclear power plant licensees to ensure that POVs are capable of performing their specified safety-related functions under design-basis conditions following the close-out of GSI 158.
Consistent with RIS 2000-03, the NRC staff prepared IP 71111.21N.02, Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements (January 1, 2020) to conduct NRC team inspections at all nuclear power plants to assess the reliability, functional capability, and design basis of risk-important POVs (including MOVs) as required by 10 CFR 50.55a and applicable 10 CFR Part 50, Appendix A and Appendix B, requirements. At the end of 2022, the NRC staff completed its inspections of POV programs at each nuclear power plant to verify the capability of those valves to perform their safety functions. The NRC staff references the EPRI MOV PPM in IP 71111.21N.02 because of the industry-wide use of that methodology by nuclear power plant licensees to provide reasonable assurance that MOVs are capable of performing their design-basis safety functions. The NRC staff prepared Information Notice (IN) 2021-01, Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Design-Basis Capability of Power-Operated Valves at Nuclear Power Plants, (May 6, 2021) and its Supplement 1 with the same title (July 24, 2023) to alert nuclear power plant licensees to the lessons learned from the POV inspections. The NRC staff discusses important aspects regarding the implementation of the EPRI MOV PPM in IN 2021-01 and Supplement 1 to provide reasonable assurance of the capability of MOVs to perform their safety functions at nuclear power plants. Some of the improvements to the EPRI MOV PPM in Version 4.1 address lessons learned from the POV inspections using IP 71111.21N.02 at nuclear power plants.
Based on the continued use of the EPRI MOV PPM by nuclear power plant licensees to provide reasonable assurance of the capability of MOVs to perform their design-basis safety functions in accordance with NRC regulations and regulatory guidance, and by NRC staff and inspectors in evaluating licensee programs to provide reasonable assurance of MOV design-basis capability, the NRC staff concludes that the review of EPRI Technical Report 3002023774, EPRI MOV Performance Prediction Methodology (PPM), Version 4.1, is a generic methodology that provides reasonable assurance of the safe operation of nuclear power plants, and supports regulatory improvements and efforts important to the NRC staffs mission.
Therefore, I conclude that EPRIs request for NRC review of EPRI Technical Report 3002023774, EPRI MOV Performance Prediction Methodology (PPM), Version 4.1, meets the criteria under 10 CFR 170.11(a)(1)(ii) because the guidance will assist the NRC in generic regulatory improvements or efforts; therefore, the fee exemption request is approved.
N. Camilli If you have any technical questions regarding this matter, please contact Ms. Lois James at 301-415-3306. Please contact Mr. Billy Blaney, of my staff, at 301-415-5092 for any fee-related questions.
Sincerely, Signed by Osborne, Howard on 10/11/23 Howard K. Osborne Chief Financial Officer
N. Camilli
SUBJECT:
RESPONSE TO REQUEST FOR A FEE EXEMPTION FOR NRC REVIEW OF EPRI TECHNICAL REPORT 3002023774, EPRI MOV PERFORMANCE PREDICTION METHODOLOGY (PPM), VERSION 4.1, DATED: OCTOBER 11, 2023 DISTRIBUTION: OCFO-23-00161 NAridi, OCFO MVelasquez, OCFO LJames, NRR RidsNrrOd Resource ADAMS Accession Number: ML23256A163 Package; ML23256A166 Letter OFFICE OCFO/DOB NRR/DORL NRR/DORL OGC NAME BBlaney GGeorge VCusumano BHarris*NLO DATE 09/13/2023 09/13/2023 09/15/2023 09/29/2023 OFFICE OCFO/DOC OCFO/DOB OCFO/DOB OCFO/DOB NAME RRevinzon ARossi RAllwein MSchofer DATE 09/29/2023 10/02/2023 10/02/2023 10/05/2023 OFFICE CFO CFO NAME DDAbate HOsborne DATE 10/11/2023 10/11/2023 OFFICIAL RECORD COPY