ML22067A084
| ML22067A084 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/07/2022 |
| From: | Emanuelson M Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LMT-22-007 | |
| Download: ML22067A084 (5) | |
Text
Submission Date: March 07, 2022 Submitted By: Mary Emanuelson Document Sensitivity: Non-Sensitive Licensee: Xcel Energy Plant Unit(s) and Docket No(s): Monticello (05000263)
Project
Title:
10 CFR 50.55a Request Associated with the Monticello Sixth Inservice Testing Ten-Year Interval OMN-28 (L-MT-22-007)
Proposed Alternative Number or Identifier:
VR-08 Request Type:
Inservice Inspection (ISI) or Inservice Testing (IST)
Inservice Testing (IST)
Requested Completion Date:
February 28, 2023 Brief Description of Proposed Alternative Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter 'NSPM'),
hereby requests NRC authorization of this 10 CFR 50.55a request to support the implementation of the sixth IST ten-year interval for Monticello Nuclear Generating Plant (MNGP). Proposed Relief Request VR-08 requests to adopt ASME Code Case OMN-28, 'Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation'. This submittal makes no new commitments and no revisions to existing commitments.
Proposed Duration of Alternative (in terms of ISI/IST Program Interval with Start and End Dates):
This request, upon approval, will be applied to the MNGP sixth IST ten-year interval starting October 1, 2022, and is scheduled to end May 31, 2032.
Applicable ASME Code Requirements ISTC-3700, 'Position Verification Testing', states that valves with remote position indicators shall be observed locally at least once every two 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. Position verification for active Motor Operated Valves (MOVs) shall be tested in accordance with Mandatory Appendix III, 'Preservice and Inservice Testing of Active Electric Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants', of this Division.Mandatory Appendix III, subparagraph III-3300, 'Inservice Test', (e) states that remote position indication shall be verified locally during inservice testing or maintenance activities.10 CFR 50.55a(b)(3)(xi) imposes the following ASME OM condition for use of the 2012 or later editions of the OM Code for 'Valve Position Indication': '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, WEB-BASED PROPOSED ALTERNATIVE SUBMISSION 10 CFR 50.55a(z)(1)
Licensee
Contact:
Mary Emanuelson mary.emanuelson@xcelenergy.com (612) 330-5850
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'.
Applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV Code), or ASME Operation and Maintenanceâ-of Nuclear Power Plants (OM Code), Edition and Addenda American Society of Mechanical Engineers (ASME) OM Code, Operation and Maintenance of Nuclear Power Plants, 2017 Edition with no Addenda.
Current ISI or IST Program Interval Number and Start/End Dates MNGP is currently on its fifth IST ten-year interval that is scheduled to end on September 30, 2022. The MNGP sixth IST ten-year interval begins on October 1, 2022.
Applicable ASME Code Components and/or System Description The valves covered and affected by this 10 CFR 50.55a(z)(1) alternative are those valves equipped with remote position indication that have been determined to be stem-disk separation non-susceptible valve(s) as defined in ASME Code Case OMN-28, Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation.
The tables below provide the list of valves that are within the scope of Alternative Request OMN-28 (Note 1)
MOVs, Motor Operated Valves MV, Manual Valves Component ID Component ID Component ID Component ID MO-1426 MO-2015 MO-2068 MO-2-53A MO-1751 MO-2020 MO-2071 MO-2-53B MO-1752 MO-2021 MO-2075 MO-3502 MO-1753 MO-2022 MO-2076 MO-4085A MO-1754 MO-2023 MO-2078 MO-4085B MO-2002 MO-2029 MO-2096 MO-4086 MO-2003 MO-2030 MO-2100 MO-4229 MO-2006 MO-2032 MO-2101 MO-4230 MO-2007 MO-2033 MO-2102 MO-1986 MO-2008 MO-2034 MO-2106 MO-1987 MO-2009 MO-2035 MO-2107 MO-1988 MO-2010 MO-2036 MO-2373 MO-1989 MO-2011 MO-2061 MO-2374 MO-1741 MO-2012 MO-2062 MO-2397 MO-1742 MO-2013 MO-2063 MO-2398 MO-1749 MO-2014 MO-2067 MO-2407 MO-1750 Component ID CS-13-1 CS-13-2 RHR-6-1 RHR-6-2
AOVs, Air Operated Valves Note 1: OMN-28 may be applied to all valves in the IST program that meet OMN-28 requirements in the future.
Reason for Request
In accordance with 10 CFR 50.55a(z)(1), NSPM is requesting approval to adopt ASME OM Code Case OMN-28, Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation for those valves that can be defined, categorized, and documented by engineering justification as stem-disk separation non-susceptible valves(s).
Proposed NRC amendments to 50.55a(b)(3)(xi) will allow schedule flexibility for valves determined to be not susceptible to stem-disc separation by specifying that position verification testing required by ISTC-3700 may be performed on a 10-year interval (rather than the 2-year interval specified in ISTC-3700) where justification is documented and available for NRC review (Reference 1). Such documentation would be required to demonstrate that the stem-disk connection is not susceptible to separation based on the internal design and evaluation of the stem-disk connection using plant-specific and industry operating experience, and vendor recommendations. This allows design information and performance data to be applied in demonstrating that a valve is not susceptible to stem-disk separation.
The ASME Code committees have prepared Code Case OMN-28, Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation. This Code Case has not been approved for use in Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 4, December 2021. This Code Case has been approved by ASME and is listed in the Applicability Index from ASME Codes and Standards, as applicable through the 2020 Edition of the ASME OM Code.
XP-8 Component ID Component ID Component ID Component ID CV-3-32A AO-2-80A AO-2382E CV-3311 CV-3-32B AO-2-80B AO-2382F CV-3312 CV-3-32C AO-2-80C AO-2382G CV-3313 CV-3-32D AO-2-80D AO-2382H CV-3314 CV-3-33A AO-2-86A AO-2382K CV-2371 CV-3-33B AO-2-86B AO-2383 CV-2372 CV-3-33C AO-2-86C AO-2386 CV-2082A CV-3-33D AO-2-86D AO-2387 CV-2104 CV-2046A AO-2377 AO-2896 CV-2790 CV-2065 AO-2378 AO-4539 CV-2791 CV-1478 AO-2379 AO-4540 CV-1994 CV-7956 AO-2380 CV-2384 CV-1995 AO-2541A AO-2381 CV-2385 CV-1996 AO-2541B AO-2382A CV-3267 CV-1997 AO-2561A AO-2382B CV-3268 CV-1728 AO-2561B AO-2382C CV-3269 CV-1729
This Code Case mirrors the philosophy and methodology of the proposed NRC modifications to 50.55a(b)(3)
(xi) for valves determined to be non-susceptible to stem-disc separation. The Code Case differs in that it proposes a 12-year rather than a 10-year interval. In accordance with 10 CFR 50.55a(z)(1), the relaxation of the prescribed intervals for performing ISTC-3700 supplemental position verification requirements in accordance with the 50.55a(b)(3)(xi) condition would provide an acceptable level of quality and safety for valves meeting the OMN-28 definition of stem-disk separation non-susceptible valve(s).
Full Description of Proposed Alternative In lieu of compliance with ISTC-3700, NSPM proposes to implement the ASME OM Code Case OMN-28 on the basis that it provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a, Codes and standards, paragraph (z)(1).
Description of Basis for Use The valves covered by this code case are those stem-disk separation non-susceptible valves with remote position indication within the scope of Subsection ISTC, including its mandatory appendices and their verifications methods and frequencies, in accordance with regulatory requirements.
Valves with remote position indication within the scope of ASME OM Code, Subsection ISTA, paragraph ISTA-1100, not satisfying the scope and provisions of this code case shall meet the valve position verification requirements in ASME OM Code, Paragraph ISTC-3700, in accordance with regulatory requirements.
To categorize a valve as not susceptible to stem-disk separation, the valve shall have a documented justification that the stem-disk connection is not susceptible to separation based on the internal design, service conditions, applications, and evaluation of the stem-disk connection using plant-specific and industry operating experience, and vendor recommendations.
Valves with remote position indicators that are not susceptible to stem-disk separation shall be verified to accurately represent valve operation as discussed in paragraph 1.4, Position Verification Testing Requirements for Valves Not Susceptible to Stem-Disk Separation, of the Code Case.
Code Case OMN-28 was approved for use by the ASME on March 4, 2021.
No deviations from the Code Case are being proposed.
Describe Hardship or Unusual Difficulty NOT APPLICABLE Any Additional Information (submission attachments listed here)
NOT USED (No Attachments)
Precedents Braidwood Station, Units 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach
Bottom Atomic Power Station, Units 2 and 3; and R.E. Ginna Nuclear Power Plant - Safety Evaluation for Proposed Alternative to Use ASME Code Case OMN-28 (EPID L-2021-LLR-0056), dated September 3, 2021 (ADAMS Accession Number ML21230A206).
References
- 1. Federal Register / Vol. 86, No. 57 / Friday, March 26, 2021 / Proposed Rules
- 2. ASME OM Code Case OMN-28, Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation.