ML22207A216
| ML22207A216 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/26/2022 |
| From: | Mel Gray Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Gray M | |
| References | |
| IR 2022010 | |
| Download: ML22207A216 (9) | |
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'
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
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
Nine Mile Point 1 Liquid Poison - #11 SQUIB
EV-42-35
Nine Mile Point 1 Main Steam System - INBOARD IV
IV-01-01
Nine Mile Point 1 Combustible Gas Control System - DW V&P
INBOARD IV
IV-201-32
Nine Mile Point 1 Feedwater System - INBOARD IV
IV-31-07
Nine Mile Point 1 Reactor Water Cleanup System - RETURN
INBOARD IV
IV-33-01R
Nine Mile Point 1 Emergency Cooling System - OUTBOARD IV
IV-39-06
Nine Mile Point 1 Emergency Cooling System - INBOARD IV
IV-39-07R
Nine Mile Point 1 Emergency Cooling System - OUTBOARD IV
IV-39-09R
Nine Mile Point 1 Core Spray - INBOARD IV
IV-40-01
Nine Mile Point 1 Control Rod Drive System - SDV DRAIN
OUTBOARD IV
IV-44.2-17
Nine Mile Point 1 Containment Spray - SUCTION IV
IV-80-01
Nine Mile Point 1 Containment Spray - INLET OUTBOARD IV
IV-80-15
Nine Mile Point 1 Containment Spray - SUCTION IV
IV-80-21
Nine Mile Point 1 Waste Disposal System - DWEDT INBOARD
IV
IV-83.1-09
Nine Mile Point 1 Automatic Depressurization System -
(PSV-A) ADS-3
PSV-01-102A
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
PLANT
SYS
ID
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
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
Nine Mile Point 2 Main Steam System - Main Steam Isolation
Valve; Inboard Isolation
2MSS*AOV6D
Nine Mile Point 2 Main Steam System - Main Steam Isolation
Valve; Outboard Isolation
2MSS*AOV7D
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
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