ML22207A216

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Information Request to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000220/2022010 and 05000410/2022010
ML22207A216
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 07/26/2022
From: Mel Gray
NRC/RGN-I/DORS
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
Gray M
References
IR 2022010
Download: ML22207A216 (9)
v • d • e


See also: IR 05000220/2022010

Text

July 26, 2022

Mr. David P. Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - INFORMATION

REQUEST TO SUPPORT TRIENNIAL BASELINE DESIGN-BASIS CAPABILITY

OF POWER-OPERATED VALVES INSPECTION; INSPECTION REPORT

05000220/2022010 AND 05000410/2022010

Dear David Rhoades:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region I staff will conduct a team inspection at Nine Mile Point Nuclear Station, Units 1 and 2.

Paul Cataldo, a Senior Reactor Inspector from the NRCs Region I Office, will lead the

inspection team. The inspection will be conducted in accordance with Inspection Procedure

71111.21N.02, Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a

Requirements, dated October 9, 2020 (ADAMS Accession No. ML20220A667).

The inspection will assess the reliability, functional capability, and design bases of risk-important

power-operated valves (POVs) as required by Title 10 of the Code of Federal Regulations

(10 CFR) 50.55a, and Appendix A and B requirements. The inspectors will select a sample of

POVs based on risk insights, safety significance, and operating margin.

During a video conference on July 20, 2022, with Jeremy Aiello, Regulatory Specialist, Sean

Guthrie, Engineering Analyst, and Peter Logar, Engineering Programs Manager, we confirmed

arrangements for an information gathering visit and the two-week onsite inspection. Depending

on site access conditions, the information gathering visit and the inspection weeks may be

performed onsite, remotely, or a hybrid approach. Additionally, the schedule is as follows:

Information gathering visit: Week of August 29, 2022

Onsite weeks: Weeks of October 17 and October 31, 2022

The purpose of the information gathering visit is to meet with members of your staff and to

become familiar with your programs and procedures intended to ensure compliance with 10

CFR 50.55a for POVs. The lead inspector will review aspects of the programs including any

specific applicable regulatory commitments made by your facility and your use of NRC

Regulatory Guides or industry standards. Dave Werkheiser, a Region I Senior Risk Analyst, will

support Paul Cataldo during the information-gathering visit to review probabilistic risk

assessment data and identify the final POV samples to be examined during the inspection.

D. Rhoades

2

Experience with previous design basis team inspections of similar depth and length has shown

this type of inspection is resource intensive, both for NRC inspectors and licensee staff. In order

to minimize the inspection impact on the site and to ensure a productive inspection for both

parties, we have enclosed a request for information needed for the inspection.

It is important that all of these documents are up-to-date and complete in order to minimize the

number of additional documents requested during the preparation and onsite portions of the

inspection. Insofar as possible, this information should be provided electronically to the lead

inspector by the information gathering week of August 29, 2022. Recognizing the timeframe, my

staff will work with your staff to prioritize our document requests so these activities can be

accomplished, as much as possible, in the normal course of your activities. Additional

documents may be requested during the information gathering visit and/or during team

preparation week (the week prior to the first onsite inspection week). The inspectors will

minimize your administrative burden by specifically identifying only those documents required

for the inspection.

If there are any questions about the inspection or the material requested in the enclosure,

please contact the lead inspector at 603-395-5536 or via e-mail at Paul.Cataldo@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number

3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a

request for information or an information collection requirement unless the requesting document

displays a currently valid Office of Management and Budget Control Number.

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

Mel Gray, Chief

Engineering Branch 1

Division of Operating Reactor Safety

Docket Nos. 05000220 and 05000410

License Nos. DPR-63 and NPF-69

Enclosure:

Document Request for Design Bases

Assurance Inspection

cc: Distribution via ListServ

Melvin K.

Gray

Digitally signed by Melvin

K. Gray

Date: 2022.07.26

13:53:24 -04'00'

ML22207A216

X

SUNSI Review

X

Non-Sensitive

Sensitive

X

Publicly Available

Non-Publicly Available

OFFICE

RI/DORS

RI/DORS

NAME

PCataldo

MGray

DATE

7/25/22

7/26/22

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

Enclosure

Inspection Report: 05000220/2022010 and 05000410/2022010

Onsite Inspection Dates:

Weeks of October 17, 2022, and October 31, 2022

Inspection Procedure:

Inspection Procedure 71111.21N.02, Design-Basis Capability of

Power-Operated Valves Under 10 CFR 50.55a Requirements

Lead Inspector:

Paul Cataldo, Senior Reactor Inspector

603-395-5536

Paul.Cataldo@nrc.gov

I.

Information Gathering Visit

During this visit, we plan to obtain sufficient insights to finalize power-operated valve (POV)

samples for this inspection. We would like to meet with POV specialists to discuss the

upcoming inspection and our sample selection process. The primary valve types to be

reviewed for this inspection include motor-operated valves (MOVs) and air-operated valves

(AOVs); and additional valve types include hydraulic-operated valves (HOVs), and solenoid-

operated valves (SOVs). During this visit, the lead inspector will: (a) discuss the scope of the

planned inspection; (b) identify additional information needed to review in preparation for the

inspection; (c) ensure that the information to be reviewed is available at the beginning of the

inspection; and (d) verify that logistical issues will be identified and addressed prior to the

teams arrival. Depending on the local COVID environment and potential travel restrictions,

this visit may be either onsite, performed remotely through a series of Microsoft Teams, or a

hybrid of the two. If performed onsite, please reserve a room during the site visit with a

telephone, wireless internet access, and a licensee computer with access to procedures,

corrective action program documents, as well as access to a printer.

II. Information Requested for Selection of Power-Operated Valves

The following information is requested by the week of August 29, 2022, to facilitate

inspection preparation. Feel free to contact the lead inspector if you have any questions

regarding this information request. Please provide the information electronically in pdf files,

Word, Excel, or other searchable formats, utilizing your typical Sharepoint file-sharing

applications. The files should contain descriptive names and be indexed and/or hyperlinked

to facilitate ease of use. Information in lists should contain enough information to be easily

understood by someone who has knowledge of light water reactor technology and POVs:

1. A word-searchable Updated Final Safety Analysis Report, TS, and TRM. If not available

in a single file for each unit, please ensure a collective table of contents is provided.

2. Site (and corporate if applicable) procedures associated with implementation of the MOV

program required by 10 CFR 50.55a(b)(3)(ii) and/or ASME OM Code Mandatory

Appendix III; and the site (corporate) procedures for the AOV program.

3. Site evaluation, response(s), and activities regarding NRC Generic Letter (GL) 95-07,

Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

4. Site evaluation, response(s), and activities regarding NRC GL 96-05, Periodic

Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves.

5. Site evaluation to NRC IN 2006-26, Failure of Magnesium Rotors in Motor-Operated

Valve Actuators, NRC IN 2008-20, Failure of Motor Operated Valve Actuators with

Magnesium Alloy Rotors, and any actions/current plant activities associated with

BWROG-TP-09-005, Inspection of Motor Operated Valve Limitorque AC Motors with

Magnesium Rotors.

6. Site evaluation and/or activities regarding NRC Information Notice 2012-14, MOV

Inoperable due to Stem-Disc Separation.

7. List of corrective action documents related to the MOV and AOV programs since

January 1, 2018 (include document No., title/short description, date).

8. List of corrective action documents related to each of the 30 POVs listed below since

January 1, 2018 (include document No., title/short description, date).

9. List of significant modifications, repairs, or replacement of safety-related POVs

completed since January 1, 2018, including date completed (include document No., title,

date completed). If the result is zero, or minimal, please provide a list of modifications on

the same population of valves, looking back an additional 5 years.

10. List of POVs removed from the In-Service Test program since January 1, 2018.

11. Any self-assessments or quality assurance type assessments of the MOV and AOV

programs (performed since January 1, 2018). If none, please provide the most recent

version.

12. Most recent POV (e.g., MOV, AOV, SOV) program health report(s).

13. List and electronic copy of all Emergency Operating Procedures.

14. List of Abnormal Operating Procedures.

15. Identify and provide the edition of the ASME Operation and Maintenance of Nuclear

Power Plants (OM Code) that is the Code of Record for the current 10-year Inservice

Test Program interval, as well as any standards (EPRI/JOG, etc.) to which the station

has committed with respect to POV capability and testing.

16. Identify which of the valves listed in items #17 and #18 (below) are located in harsh

environment areas and subject to Environmental Qualification (EQ) requirements.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

17. For each of the MOVs listed on pages 5 and 6, please provide the information listed in

the table below.

Item

Parameter/Information*

1

MOV Identification

2

Safety Function

3

Valve manufacturer, type, and size

4

Actuator manufacturer, type, and size

5

Motor manufacturer, type (AC/DC), and size

6

Valve ASME Class

7

Risk Significance (RAW, Birnbaum, FV, etc)

8

Control Switch Trip (CST) Application (Close/Open)

9

Design-Basis Differential Pressure (DBDP) and Flow (Close/Open)

10

Rising-Stem Valve: Assumed Valve Factor (VF)

11

Quarter-Turn Valve: Assumed bearing torque coefficient

12

Assumed Stem Friction Coefficient (SFC)

13

Assumed Load Sensitive Behavior (LSB) (%)

14

% Uncertainties (e.g., diagnostic equipment, CST repeatability, etc.)

15

Calculated Required Thrust/Torque (Close/Open)

16

Least Available Output (e.g., actuator, CST, rating, spring pack, weak link)

17

Test Conditions (e.g., fluid differential pressure (DP), system pressure, flow, and temperature;

ambient temperature; and motor voltage) (Close/Open)

18

Thrust and torque required to overcome dynamic conditions (Close/Open)

19

Rising-Stem Valve: Measured VF (Close/Open)

20

Rising-Stem Valve: Available VF (Close/Open)

21

Measured SFC (Close/Open)

22

Measured LSB (%)

23

Quarter-Turn Valve: Measured bearing torque coefficient (Close/Open)

24

Determined % Margin (Close/Open)

25

Basis for Design-Basis Capability:

25.a

Dynamic test performed at design-basis DP/flow conditions

25.b

Extrapolation of dynamic test data

25.c

Justification from normal operation at or above design-basis conditions

25.d

Industry dynamic test methodology (such as EPRI MOV PPM)

25.e

Grouped with similar valves dynamically tested at plant

25.f

Grouped with similar valves dynamically tested at other plants

25.g

Valve qualification testing (such as ASME QME-1-2007)

25.h

Other (such as large, calculated margin)

  • Specify Not Applicable (NA) as appropriate

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

18. For each of the AOVs/SOVs/HOVs listed on pages 5 and 6, please provide the

information listed in the table below.

Item

Parameter/Information*

1

AOV/SOV/HOV Identification

2

Safety Function

3

Fail safe position (open/close)

4

Valve manufacturer, type, and size

5

Actuator manufacturer, type, and size

6

Valve ASME Class

7

Risk Significance

8

Design-Basis Differential Pressure (DBDP) and Flow (Close/Open)

9

Rising-Stem Valve: Assumed Valve Factor (VF)

10

Quarter-Turn Valve: Assumed bearing torque coefficient

11

% Uncertainties (e.g., diagnostic equipment, CST repeatability, etc.)

12

Calculated Required Thrust/Torque (Close/Open)

13

Minimum allowable air pressure (Beginning/End Stroke)

14

Maximum allowable air pressure (Beginning/End Stroke)

15

Minimum allowable spring preload (Beginning/End Stroke)

16

Maximum allowable spring preload (Beginning/End Stroke)

17

Least Available Actuator Output (e.g., actuator capability, actuator limit, valve weak link

limitation)

18

Test Conditions (e.g., fluid differential pressure (DP), system pressure, flow, and temperature;

and ambient temperature) (Close/Open)

19

Thrust and torque required to overcome dynamic conditions (Close/Open)

20

Rising-Stem Valve: Measured VF (Close/Open)

21

Quarter-Turn Valve: Measured bearing torque coefficient (Close/Open)

22

Determined Margin (%) (Least margin for air stroke operation, spring stroke operation,

maximum spring load, and structural capability)

23

Basis for Design-Basis Capability:

24.a

Dynamic test performed at design-basis DP/flow conditions

24.b

Extrapolation of dynamic test data

24.c

Justification from normal operation at or above design-basis conditions

24.d

Industry dynamic test methodology

24.e

Grouped with similar valves dynamically tested at plant

24.f

Grouped with similar valves dynamically tested at other plants

24.g

Valve qualification testing (such as ASME QME-1-2007)

24.h

Other (such as large, calculated margin)

  • Specify Not Applicable (NA) as appropriate

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

PLANT

SYS

ID

POV

Nine Mile Point 1 Liquid Poison - #11 SQUIB

EV-42-35

Squib

Nine Mile Point 1 Main Steam System - INBOARD IV

IV-01-01

MOV

Nine Mile Point 1 Combustible Gas Control System - DW V&P

INBOARD IV

IV-201-32

AOV

Nine Mile Point 1 Feedwater System - INBOARD IV

IV-31-07

MOV

Nine Mile Point 1 Reactor Water Cleanup System - RETURN

INBOARD IV

IV-33-01R

MOV

Nine Mile Point 1 Emergency Cooling System - OUTBOARD IV

IV-39-06

AOV

Nine Mile Point 1 Emergency Cooling System - INBOARD IV

IV-39-07R

MOV

Nine Mile Point 1 Emergency Cooling System - OUTBOARD IV

IV-39-09R

MOV

Nine Mile Point 1 Core Spray - INBOARD IV

IV-40-01

MOV

Nine Mile Point 1 Control Rod Drive System - SDV DRAIN

OUTBOARD IV

IV-44.2-17

AOV

Nine Mile Point 1 Containment Spray - SUCTION IV

IV-80-01

MOV

Nine Mile Point 1 Containment Spray - INLET OUTBOARD IV

IV-80-15

AOV

Nine Mile Point 1 Containment Spray - SUCTION IV

IV-80-21

MOV

Nine Mile Point 1 Waste Disposal System - DWEDT INBOARD

IV

IV-83.1-09

MOV

Nine Mile Point 1 Automatic Depressurization System -

(PSV-A) ADS-3

PSV-01-102A

SOV

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

PLANT

SYS

ID

POV

Nine Mile Point 2 Reactor Building Closed Loop Cooling -

RCS Pump A Cooling Water Return

2CCP*MOV15A MOV

Nine Mile Point 2 Containment Atmosphere Monitoring - CMS

from Suppression Chamber to H2O2 Analyzer

2CMS*SOV26C SOV

Nine Mile Point 2 Primary Containment Purge System -

Suppression Chamber Vent - Exhaust

2CPS*AOV109

AOV

Nine Mile Point 2 High Pressure Core Spray - HPCS Injection

Valve

2CSH*MOV107 MOV

Nine Mile Point 2 Low Pressure Core Spray - LPCS Injection

Valve

2CSL*MOV104 MOV

Nine Mile Point 2 Drywell Floor Drains - DWFD Tank Line

2DFR*MOV120 MOV

Nine Mile Point 2 Reactor Core Isolation Cooling - RCIC Turbine

Steam Supply (F063); Outboard Isolation

2ICS*MOV121

MOV

Nine Mile Point 2 Main Steam System - Main Steam Isolation

Valve; Inboard Isolation

2MSS*AOV6D

AOV

Nine Mile Point 2 Main Steam System - Main Steam Isolation

Valve; Outboard Isolation

2MSS*AOV7D

AOV

Nine Mile Point 2 Residual Heat Removal - Shutdown Cooling

Supply; PIV

2RHS*MOV113 MOV

Nine Mile Point 2 Residual Heat Removal - Containment Spray to

Drywell; Outboard Isolation

2RHS*MOV15A MOV

Nine Mile Point 2 Spent Fuel Pool Cooling - SFC Pump 1A

Discharge Inter-Connection Valve

2SFC*HV18A

AOV

Nine Mile Point 2 Service Water System - SWP To RHR Pumps

2RHS*P1B, C Seal Cooler

2SWP*AOV20B AOV

Nine Mile Point 2 Service Water System - SWP From Diesel

Generator Cooler, EG1

2SWP*MOV66A MOV

Nine Mile Point 2 Reactor Water Cleanup System - RWCU

Return to FWS; Outboard Isolation

2WCS*MOV200 MOV

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