ML061520145

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RAI Related to Request for Relief from the ASME on Code for the Third Inservice Test Interval
ML061520145
Person / Time
Site: Byron  Constellation icon.png
Issue date: 06/13/2006
From: Robert Kuntz
Plant Licensing Branch III-2
To: Crane C
Exelon Generation Co
Kuntz, Robert , NRR/DLPM, 415-3733
References
TAC MC9642, TAC MC9643, TAC MC9752, TAC MC9753, TAC MC9754, TAC MC9755, TAC MC9756, TAC MC9757, TAC MC9758, TAC MC9759, TAC MC9762, TAC MC9763, TAC MC9764, TAC MC9765
Download: ML061520145 (7)


Text

June 13, 2006 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BYRON STATION, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR RELIEF FROM THE ASME OM CODE FOR THE THIRD INSERVICE TEST INTERVAL (TAC NOS. MC9642, MC9643, MC9752, MC9753, MC9754, MC9755, MC9756, MC9757, MC9758, MC9759, MC9762, MC9763, MC9764, AND MC9765)

Dear Mr. Crane:

By letter to the Nuclear Regulatory Commission (NRC) dated December 12, 2005, Exelon Generation Company, LLC submitted a request for relief from the American Society of Mechanical Engineers Operation and Maintenance Code for the third inservice test interval, for Byron Station, Unit Nos.1 and 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on May 31, 2006, it was agreed that you will provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3733.

Sincerely,

/RA/

Robert F. Kuntz, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-454 and 50-455

Enclosure:

Request for Additional Information cc w/encl: See next page

June 13, 2006 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BYRON STATION, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR RELIEF FROM THE ASME OM CODE FOR THE THIRD INSERVICE TEST INTERVAL (TAC NOS. MC9642, MC9643, MC9752, MC9753, MC9754, MC9755, MC9756, MC9757, MC9758, MC9759, MC9762, MC9763, MC9764, AND MC9765)

Dear Mr. Crane:

By letter to the Nuclear Regulatory Commission (NRC) dated December 12, 2005, Exelon Generation Company, LLC submitted a request for relief from the American Society of Mechanical Engineers Operation and Maintenance Code for the third inservice test interval, for Byron Station, Unit Nos.1 and 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on May 31, 2006, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3733.

Sincerely,

/RA/

Robert F. Kuntz, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-454 and 50-455

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNRRPMMRKuntz RidsNrrLADClarke RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr ADAMS Accession Number: ml061520145 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC NAME RKuntz:mw DClarke DCollins DATE 6/12/2006 6/12/2006 6/13/2006 OFFICIAL RECORD COPY

Byron Station Units 1 and 2 cc:

Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Dwain W. Alexander, Project Manager Westinghouse Electric Company Post Office Box 355 Pittsburgh, PA 15230 Joseph Gallo Gallo & Ross 1025 Connecticut Ave., NW, Suite 1014 Washington, DC 20036 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Drive Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, IL 61010-9750 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 Attorney General 500 S. Second Street Springfield, IL 62706 Byron Station Plant Manager Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Site Vice President - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Senior Vice President of Operations Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Chairman Will County Board of Supervisors 302 North Chicago Street Will County Board Courthouse Joliet, Illinois 60434

Byron Station Units 1 and 2 Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood and Byron Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

Enclosure REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2 DOCKET NOS. 50-454 AND 50-455 Note:

The code provided in parenthesis after each question refers to the request for additional information (RAI) categorization codes listed at the end of the RAI.

In reviewing the Exelon Generation Companys (Exelons) submittal dated December 29, 2005, related to a request for relief from the American Society of Mechanical Engineers Operation and Maintenance Code for the third inservice test interval, for Byron Station, Unit Nos. 1 and 2, the NRC staff has determined that the following information is needed in order to complete its review:

1.

Relief request RP-2 (Category 1.b)

Provide pump data that compares pump performance to the acceptance criteria identified in Table ISTB-5100-1 for the Comprehensive pump test for each of the last three cycles.

2.

Relief request RP-3 (Category 1.b)

Provide pump data that compares pump performance to the acceptance criteria identified in Table ISTB-5100-1 for the Comprehensive pump test for each of the last three cycles.

3.

Relief request RP-4 (Category 1.b)

Provide pump data that compares pump performance to the acceptance criteria identified in Table ISTB-5100-1 for the Comprehensive pump test for each of the last three cycles.

4.

Relief request RP-6 (Category 1.b)

Provide discussion on how this relief request provides an acceptable level of quality.

The discussion provided describes the proposed alternative, but does not describe how it provides an acceptable level of quality.

5.

Relief request RV-1 (Category 2.a)

This relief request proposes an alternative that would provide an acceptable level of quality and safety for the exercising test frequency of four valves. The discussion provided describes the impracticality of the actions necessary to stroke these valves.

Provide a discussion as to how the change of stroking the valves quarterly to stroking them once every 18 months with a 25 percent allowance for flexibility in scheduling provides a similar level of quality and safety. Include information regarding the environmental and chemical effects on the ability to stroke the valves.

RAI CATEGORIES (Select only one, most dominant category for each RAI question) 1.

More information is needed because of:

a. complexity of request
b. first-of-a-kind nature of request
c. NRC change in regulatory significance or focus
d. NRC questions on previously used methodology or guidance
e. licensee change to previously used methodology
f. licensee reduction in current safety margin 2.

The review can not be completed without additional explanation or clarification of:

a. input variables or analytical assumptions
b. methodology used or results obtained
c. applicability or bounding nature of third party analyses or data correlations
d. differences from NRC guidance documents (SRP, RG, etc.)
e. no significant hazards consideration discussion
f. environmental considerations discussion
g. applicable regulatory requirements discussion
h. information that appears to be incorrect and needs to be corrected
i. response to previous RAI appears inadequate 3.

Reviewer requesting information even though the question is, or the question asks for:

a. not directly related to the request
b. inconsistent with applicable codes, standards, RGs, or SRP sections
c. information accessible from readily available sources and was explicitly referenced
d. information does not appear needed given the precedent cases discussed in the request
e. information that is not safety significant or pertinent to the regulatory finding
f. information that is known to engineers who work in the general technical area
g. going beyond the current licensing basis and doesnt need to be asked
h. a formal commitment 4.

Other (please specify)