RS-06-015, Commitments and Plans Related to Extended Power Uprate Operation

Commitments and Plans Related to Extended Power Uprate Operation

ML060270526
Person / Time
Site:	Dresden, Quad Cities
Issue date:	01/26/2006
From:	Jury K Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-06-015
Download: ML060270526 (5)

Text

RS-06-015 January 26, 2006 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Commitments and Plans Related to Extended Power Uprate Operation

References:

1 . Letter from Keith R . Jury (Exelon Generation Company, LLC) to U . S. NRC, "Commitments and Plans Related to Extended Power Uprate Operations,"

dated November 18, 2005

2. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. NRC, "Response to Quad Cities Steam Dryer Open Issues," dated December 22, 2005

3. Letter from U .S. NRC to C . Crane (Exelon Generation Company, LLC),

"Commitments Related to Extended Power Uprate Operations ; Quad Cities, Units 1 and 2," dated December 23, 2005 In Reference 1, Exelon Generation Company, LLC (EGC) updated regulatory commitments regarding operation of Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, at extended power uprate (EPU) conditions .

EGC has conducted extensive detailed quantitative assessments of the structural adequacy of the QCNPS replacement steam dryers . The results of this analytical work have been, and continue to be, shared with the NRC. EGC met with the NRC on November 8 and 9, 2005, to discuss technical evaluations related to qualification of the Quad Cities replacement steam dryers for EPU operation. In summary, the detailed evaluations of the QCNPS replacement steam dryers, using the acoustic circuit model and finite element analysis of derived steam dryer loads, demonstrated that adequate structural margin exists for the replacement steam dryers at all operating conditions, up to and including the full licensed power level of 2957 megawatts-thermal (MWt) . Prior to meeting adjournment, the NRC detailed a list of 10 open items that

January 26, 2006 U . S . Nuclear Regulatory Commission Page 2 remained with respect to evaluation of the QCNPS steam dryers and their suitability for long-term EPU operation. EGC agreed to provide information to address the 10 open items.

EGC submitted in Reference 2 the information to resolve the 10 open items from the November 8 and 9, 2005, meeting . As described in Reference 3, EGC will continue to work with the NRC to discuss how the information in Reference 2 resolves the 10 open items via a telephone conference call(s), and once the open items are closed, mutually agree on an acceptable date for a management meeting. Therefore, commitment 10 in the attachment to this letter reflects the above approach .

In addition, as a result of the degradation of the QCNPS electromatic relief valve (ERV) actuators identified during forced outages on both units during December 2005 and January 2006, EGC is providing specific commitments related to the ERVs . These commitments are outlined in the attachment to this letter.

The attachment to this letter outlines the remaining committed actions that support operation of the DNPS and QCNPS units at EPU conditions . The commitments in the attachment supersede those described in Reference 1, and represent our commitments in their entirety .

If you have any questions conce g this submittal, please contact Mr. Thomas G. Roddey, at (630) 657-2811 .

Respectfully, Keith R. Jury Director - Licensing and Regulatory Affairs Attachment : Summary of Commitments

ATTACHMENT Summary of Commitments The following table identifies commitments being made by Exelon Generation Company, ILLC (EGC). Any other actions discussed in this letter represent intended or planned actions by EGC . They are described for the NRC's information and are not regulatory commitments.

Committed Date Commitment or Outage 1 EGC will continue to conduct daily monitoring of moisture carryover Ongoing and other key reactor and plant parameters while operating at full power at Dresden Nuclear Power Station (DNPS) Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS) Units 1 and 23o provide an early indication of potential dryer structural integrity issues . If indications of steam dryer damage or structural integrity concerns are identified, EGC will reduce power at a minimum to the pre-extended power uprate (EPU) level on the affected unit and evaluate and disposition the issue in accordance with the corrective action process.

2 EGC will meet with the NRC to present the planned inspection scope Prior to the start for QCNPS Unit 2 resulting from the identification of electromatic of the relief valve (ERV) actuator degradation during the December 2005 Spring 2006 and January 2006 faced outages and the resultant extent of refueling outage condition evaluations. for QCNPS Unit 2 3 During the next scheduled refueling outage on QCNPS Unit 2, EGC Spring 2006 will inspect the 3E ERV turnbuckle tack welds and threads. refueling outage for QCNPS Unit 2 4 During the next scheduled refueling outage on QCNPS Unit 2, EGC Spring 2006 will inspect the currently installed ERV actuators . EGC will evaluate refueling outage the results of the inspection and determine appropriate actions for for QCNPS QCNPS Unit 1 and DNPS . Unit 2 5 During the next scheduled refueling outage on QCNPS Unit 2, EGC Spring 2006 will perform a general visual inspection of the reactor pressure vessel refueling outage internals, steam, and feedwater systems, including inspection and for QCNPS disassembly if needed of the most susceptible components. The Unit 2 scope of the inspections will be based upon the results of the EPU vulnerability team effort . If the inspections indicate potential degradation of the reactor pressure vessel internals, steam, or feedwater systems and components, EGC will evaluate and disposition the issue in accordance with the corrective action process . EGC will implement the lessons learned and recommendations from assessment of the vulnerability of other plant equipment to adverse flow effects from EPU operation at DNPS and QCNPS.

ATTACHMENT Summary of Commitments Committed Date Commitment or Outage 6 EGC will perform future inspections of the DNPS and QCNPS steam Ongoing dryers using guidance contained in BWRVIP-139, "BWR Vessel and Internals Project Steam Dryer Inspection and Flaw Evaluation Guidelines," dated April 2005 .

7 EGC will evaluate results of the Spring 2006 QCNPS Unit 2 steam Within 30 days of dryer inspection, and determine appropriate action for QCNPS Unit 1 . completing the The acceptance criteria will be that no structurally significant cracking Spring 2006 is identified that would limit operation. refueling outage for QCNPS Unit 2 8 Where lessons learned from evaluations or inspections conducted Fall 2006 pursuant to commitments described in this letter indicate significant refueling outage potential degradation of the steam dryer, EGC will take appropriate for DNPS Unit 3 actions up to and including shutting down the applicable unit to Spring 2007 conduct inspections or modifications on an expedited basis. refueling outage for QCNPS Unit 1 9 Each QCNPS unit will remain at a pre-EPU power level until the ERV Prior to operation root cause evaluation is complete, necessary corrective actions of the respective implemented, and a meeting has been held with the NRC to discuss QCNPS unit at these actions. EPU power levels 10 Following resolution of the remaining open hems from the November Acceptable date 8 and 9, 2005, technical meeting, EGC will meet with NRC mutually agreed management to discuss the results and conclusions of evaluations on by EGC and performed supporting EPU operation for QCNPS Units 1 and 2 . the NRC Where NRC management leading the meeting is not satisfied with the results and conclusions of those evaluations, EGC will voluntarily return the affected QCNPS unit(s) to pre-EPU power levels if EGC is unable to resolve those concerns within a timeframe agreed to by the NRC, but no sooner than 14 days (which would allow the requisite time for further technical analysis and independent reviews) .

ATTACHMENT Summary of Commitments Committed Date Commitment or Outage 11 Within 21 days following resolution of any concerns identified as part Within 21 (Jays of commitment 10, EGC will formally request the return of the following affected QCNPS unit(s) to EPU operation . Where no concerns are resolution of any identified under commitment 10, EGC will formally request NRC concerns acceptance for continuous EPU operation of the QCNPS. identified as part of commitment 10 12 During the next scheduled refueling outages on DNPS Units 2 and 3, Fall 2006 EGC will inspect the currently installed ERV actuators. EGC will refueling outage evaluate the results of the inspections and determine appropriate for DNPS Unit 3 actions for the DNPS and QCNPS units . Fall! 2007 refueling outage for DAPS Unit 2