ML091970599
ML091970599 | |
Person / Time | |
---|---|
Site: | Limerick ![]() |
Issue date: | 07/16/2009 |
From: | Cowan B Exelon Generation Co, Exelon Nuclear |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
Download: ML091970599 (19) | |
Text
Exelon Nuclear www.exeloncorp.com Exelon~
200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.55a July 16, 2009 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF*85 NRC Docket Nos. 50-352 and 50*353
Subject:
Submittal of Relief Requests Associated with the Third Inservice Testing Interval
References:
- 1) Letter from P. Cowan (Exalon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Submittal of Relief Requests Associated with the Third Inservice Testing Interval," dated February 18, 2009
- 2) Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to C. Pardee (Exelon Generation Company, LLC), "Limerick Generating Station, Units 1 and 2 - Request for Additional Information Regarding Relief Requests Associated with the Third Inservice Testing Interval (TAC NOS. ME0742 Through ME0751)," dated June 10, 2009 In the Reference 1 letter, Exelon Generation Company, LLC submitted for your review relief requests associated with the third Inservice Testing (1ST) interval for Limerick Generating Station (LGS), Units 1 and 2. The third interval of the LGS, Units 1 and 21ST program complies with the ASME OM Code, 2004 Edition. The third ten-year interval for LGS, Units 1 and 2 is scheduled to begin on January 8, 2010 and conclude on January 7, 2020. In the Reference 2 letter, the U.S. Nuclear Regulatory Commission staff requested additional information.
Attachment 1 contains our response. Attachment 2 provides revised relief requests, and Attachment 3 contains Piping and Instrumentation Diagrams M*47, Sheets 1 and 2 to facilitate staff review. There are no regulatory commitments contained within this letter.
If you have any questions concerning this letter, please contact Mr. Tom Loomis at (610) 765-5510.
Sincerely, tf'~CWJ Pamela B. Cowan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Response To Request for Additional Information LGS, Units 1 and 21ST Program July 16, 2009 Page 2 Attachments: 1) Response to Request for Additional Information - Relief Requests Associated with the Third Ten-Year Interval for Limerick Generating Station, Units 1 and 2
- 2) Revised Relief Requests
- 3) Piping and Instrumentation Diagrams M-47, Sheets 1 and 2 cc: S. J. Collins, Regional Administrator, Region I, USNRC E. M. DiPaolo, USNRC Senior Resident Inspector, LGS P. J. Bamford, Project Manager [LGS] USNRC R. R. Janati, Commonwealth of Pennsylvania
Attachment 1 Response to Request for Additional Information - Relief Requests Associated with the Third Ten-Year Interval for Limerick Generating Station, Units 1 and 2
Response To Request for Additional Information LGS, Units 1 and 21ST Program Page 1 Question:
Request for Relief 11-PRR-1 Rev. 1:
- 1. A replacement for Code Case OMN-9, Code Case OMN-16, is included in the OMB-2006 addenda, with applicability specified that includes the proposed third 1ST interval code of record, (ASME OM Code, 2004 edition). This code case has been approved for use by the OM Committee with a new expiration date of June 1, 2009, and provides more up-to-date references and requirements. Please explain why Code Case OMN-9 was requested to be used instead of Code Case OMN-16, or provide a revised request that references Code Case OMN-16.
Response
Relief Request 11-PRR-1, Revision 1 has been revised to request relief to use Code Case OMN-16. Attachment 2 provides a revised relief request.
Question:
Request for Relief GVRR-5 Rev. 3:
- 1. Please discuss why the requirements of ISTC 5221 (c) can not be implemented and why relief is not required from the requirements of ISTC 5221 (c).
- 2. Please discuss why the requirements of ISTC 5222 can not be utilized for testing of the identified check valves.
Response
Upon further review, Relief Request GVRR-5, Revision 3 is being withdrawn. Condition monitoring will be used to achieve code compliance.
Question:
Request for Relief 47-VRR-2 Rev. 0:
- 1. Please provide a discussion of why relief is required from the identified ASME OM Code requirements for each component identified.
Response
Applicable Code Requirement:
- a. ISTC-3510 requires that active Category B valves shall be exercised nominally every three months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222.
Response To Request for Additional Information LGS, Units 1 and 21ST Program Page 2
- b. ISTC-3560 requires valves with fail safe actuators be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-3510.
Additional Justification:
In order to exercise the Category B valves in accordance with ISTC-3510, and test the fail safe actuators as required by ISTC-3560, the air operated inlet and outlet valves would need to be exercise tested at power nominally every three months. The air operated inlet and outlet scram valves, XV-47-1 (2)-26 and XV-47-1 (2)-27, open on a signal from the Reactor Protection System to permit rapid insertion of the control rods (scram). These valves can only be tested by scramming the control rod drive. Exercise testing at power will result in rapid insertion of control rods causing potential reactivity transients and wear of the control rod drive mechanisms.
Accordingly, relief was requested to test the valves in accordance with Limerick Generating Station (LGS), Units 1 and 2 Technical Specification (TS) Surveillance Requirement (SR) 4.1.3.2
("Control Rod Maximum Scram Insertion Times"), and in conformance with Generic Letter 89-04, Position 7. Generic Letter 89-04 is discussed in NUREG-1482, Revision 1 f'Guidelines for lnservice Testing at Nuclear Power Plants"):
"The recommendations herein supplement the guidance and technical positions in GL 89-04. Note that specific relief is required to implement the guidance in GL 89-04. However, relief justification may refer to the positions in the GL with clarifying information to clearly show how it would apply to a licensee's situation."
As a proposed alternative, the valve testing will be performed in accordance with the TS SR 4.1.3.2 as discussed below:
The maximum scram insertion time of the control rods shall be demonstrated through measurement and, during single control rod scram time tests, the control rod drive pumps shall be isolated from the accumulators:
- a. For all control rods prior to thermal power exceeding 40% of rated thermal power with reactor coolant pressure greater than or equal to 950 psig, following core alterations or after a reactor shutdown that is greater than 120 days.
- b. For specifically affected individual control rods following maintenance on or modification to the control rod or control rod drive system which could affect the scram insertion time of those specific control rods in accordance with either "1" or "2" as follows:
1.a Specifically affected individual control rods shall be scram time tested at zero reactor coolant pressure and the scram insertion time from the fully withdrawn position to notch position 05 shall not exceed 2.0 seconds, and 1.b Specifically affected individual control rods shall be scram time tested at greater than or equal to 950 psig reactor coolant pressure prior to exceeding 40% of rated thermal power.
- 2. Specifically affected individual control rods shall be scram time tested at greater than or equal to 950 psig reactor coolant pressure.
Response To Request for Additional Information LGS, Units 1 and 21ST Program Page 3
- c. For at least 10% of the control rods, with reactor coolant pressure greater than or equal to 950 psig, on a rotating basis, and in accordance with the Surveillance Frequency Control Program.
Scram time testing of the control rods demonstrates that the valves identified in the relief request will perform their safety function. These valves are required to open to provide drive water and create an exhaust path for insertion of the control rods. Failure of a valve to open would result in the control rod not scramming in accordance with the TS requirements. It is noted that TS SR 4.1.3.2.a is performed at least once per refueling cycle, TS SR 4.1.3.2.b is performed following maintenance or modification to the control rod or control rod drive system, and TS SR 4.1 .3.2.c is performed once per 120 days of power operation in conformance with the Surveillance Frequency Control Program. Generic Letter 89-04, Position 7 states that the rod scram test frequency identified in the TS may be used as the valve testing frequency to minimize rapid reactivity transients and wear of the control rod drive mechanisms.
Attached for your information is Piping and Instrumentation Diagrams M-47, sheets 1 and 2 (Attachment 3).
The relief request has been revised (Attachment 2) as shown by the revision bars in the margin to provide additional justification for this response as well as the responses below.
Applicable Code Requirement
- c. ISTC-5131 (a) requires that active valves shall have their stroke time measured when exercised in accordance with ISTC-3500.
Additional Justification:
ISTC-5131 (a) applies to the Category B air operated inlet and outlet scram valves (XV-47-1(2)-26 and XV-47-1 (2)-27). Stroke timing of the air-operated valves is impractical since they are not equipped with indication of the open and closed positions. Insertion of the control rod is verified by control room panel lights and not valve position. Accordingly, code compliant stroke time testing cannot be performed to meet the ISTC-5131 (a) requirement. As a proposed alternative, scram time testing as described in GL 89-04, Position 7 will be performed in accordance with LGS, Units 1 and 2 TS SR 4.1.3.2.
Applicable Code Requirement
- d. ISTC-351° requires that active Category C check valves shall be exercised nominally every three months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222.
- e. ISTC-5221 (a)(2) requires check valves (47-1 (2)-14) that have a safety function in only the open direction shall be exercised by initiating flow and observing that the obturator has traveled to either the full open position or to the position required to perform its intended function(s), and verify closure.
Response To Request for Additional Information LGS, Units 1 and 21ST Program Page 4 Additional Justification:
ISTC-3510 and ISTC-5221 (a)(2) apply to the scram discharge riser check valves. The scram discharge riser check valve 47-1(2)-14 is flow actuated as a result of XV-47-1(2)-27 opening.
These valves can only be tested by scramming the control rod drive in order to demonstrate that the safety function is exercised. Exercise testing at power will result in rapid insertion of control rods causing potential reactivity transients and wear of the control rod drive mechanisms. Testing will be performed in accordance with LGS, Units 1 and 2 TS SR 4.1 .3.2.
Applicable Code Requirement
- f. ISTC-3510 requires that active Category C check valves shaH be exercised nominally every three months, except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3570, ISTC-5221 , and ISTC-5222.
- g. ISTC-5221 (a)(3) requires check valves (47-1 (2)-38) that have a safety function in only the close direction shall be exercised by initiating flow and observing that the obturator has traveled to at least the partially open position, and verify that on cessation or reversal of flow, the obturator has traveled to the seat.
Additional Justification:
Upon further review, these check valves (47-1 (2)-38) are being removed from this relief request.
As discussed in GL 89-04, Position 7, normal control rod motion will verify that the check valves move to their safety position. Code compliance can be achieved without this relief request.
Question:
Request for Relief 47-VRR-2 Rev. 0:
- 2. The relief request states that reverse flow verification of 47-1 (2)-38 is demonstrated by normal control rod motion. Please clarify how scram insertion time testing demonstrates the valve close function required by the ASME OM Code.
Response
Upon further review, these check valves (47-1 (2)-38) are being removed from this relief request.
As discussed previously, Code compliance can be achieved without this relief request.
Question:
Request for Relief 47-VRR-2 Rev. 0:
- 3. The relief request states that testing is performed with reactor coolant system pressure greater than or equal to 950 [pounds per square inch gauge] psig. Please address how the requirements of ISTC 3100 and ISTC 3310 will be met.
Response To Request for Additional Information LGS, Units 1 and 21ST Program Page 5
Response
ISTC-3100 ("Preservice Testing") provides the ASME Code requirements for preservice testing.
Preservice testing is accomplished by complying with the actions provided in Limerick Generating Station, Units 1 and 2 TS SR 4.1.3.2.b. Additionally, this TS section is used for compliance with ISTC-3310 ("Effects of Valve Repair, Replacement, or Maintenance on Reference Values") to demonstrate the operability of the valves following repair and/or replacement.
Attachment 2 Revised Relief Requests
Revised Relief Requests Associated with the Third Ten-Year Interval for Limerick Generating Station, Units 1 and 2 Relief Request No. Description Il-PRR-l, Revision 1 Use of Code Case OMN-16 ESW Pump Test Using Pump Curves 47-VRR-2, Revision 0 Control Rod Drive Scram Valves and Check Valves
RELIEF REQUEST NO. II-PRR-l, REVISION 1 Use of Code Case OMN-16 ESW Pump Test Using Pump Curves Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Components Affected:
Pump(s): Emergency Service Water OAP548 OCP548 OBP548 ODP548 Type: Vertical Line Shaft Driver: Motor Group: A Code Class: 3
- 2. Applicable Code Edition:
The applicable code edition is the ASME OM Code, 2004 Edition. The new interval is scheduled to begin on January 8,2010 and conclude on January 7,2020.
- 3. Applicable Code Requirement(s):
ISTB-5221 and 5223 require inservice testing to be conducted with the pump operating at specified test reference conditions. Further, ISTB-5221(b) and 5223(b) require the resistance of the system be varied until the flow rate or differential pressure equals its reference value, at which point the other parameter (differential pressure or flow rate) be determined and compared to its reference value.
4. Reason for Request
Pursuant to 10 CPR 50.55a, "Codes and Standards," paragraph (a)(3)(i), relief is requested to use Code Case OMN-16, "Use of a Pump Curve for Testing," which is not included in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," dated June 2003.
The Emergency Service Water (ESW) System includes a large number of variable heat loads. In addition, the temperature of the system is seasonally dependent and can vary significantly.
Therefore, it is extremely difficult to vary the resistance of the system to establish flow or differential pressure conditions at any fixed reference point. Operations personnel would need to assume local manual control of automatic room cooler valves and equipment modulating valves.
This requires access to Emergency Core Cooling System (ECCS) room coolers and other safety related equipment causing numerous entries into Radiological Controlled Areas (RCAs) to adjust flow to a fixed reference point in order to perform this quarterly test, which will also result in additional dose.
Establishment of multiple sets of reference values would not improve the capability to set either variable at a fixed point.
Page lof3
RELIEF REQUEST NO. 11-PRR-1, REVISION 1 Use of Code Case OMN-16 ESW Pump Test Using Pump Curves Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
1ST of these pumps has used reference curves during the preceding Ten Year Intervals.
- 5. Proposed Alternative and Basis for Use:
In order to monitor the ESW pumps for degradation and assure their operational readiness, reference curves as described in Code Case OMN-16 will be used for inservice testing. Pump testing is performed quarterly using these pump curves. Flow, normally in the range of 3000 to 4100 gpm, is measured and total dynamic head is calculated from the pump discharge pressure and the level of the Spray Pond (i.e., suction). The test point is then compared to the pump curve and determined to be within the acceptance range of Table ISTB-5221-1 (0.95 to 1.10 Pr for Group A Test or 0.95 to 1.03 Pr for Comprehensive Test), which is also plotted on the pump curve.
Corrective action, if required, shall meet the requirements of ISTB-6200.
These pump curves were prepared during flow balancing activities shortly before commercial operation of LGS, Unit 2. They include many empirical data points taken over the entire operating range of the pumps, essentially from shutoff head to approximately 1.5 times the maximum flow required for safe shutdown or accident mitigation. Manufacturer's representatives witnessed and concurred with the development of these curves. These curves exceed the requirements of OMN-16 for a minimum of 3 data points and at least one data point for each 20% of the maximum pump curve range for the portion of the maximum pump curve established by the reference curve.
Vibration readings are taken in accordance with ISTB-3540. In addition to the Code-required vibration readings, several additional readings are taken and analyzed in accordance with the LGS Predictive Maintenance Program. Since these pumps show little variation in vibration over their normal operating range, the acceptance criteria for vibration testing complies with the requirements of Table ISTB-5221-1.
The reference pump curves for inservice testing are considered acceptable in meeting the intent of the ASME O&M Code-2004 Paragraphs ISTB-5221 and 5223.
- 6. Duration of Proposed Alternative:
Duration will be for the third ten-year interval for LGS, Units 1 and 2, which is scheduled to begin on January 8,2010 and conclude on January 7,2020.
Page 2 of3
RELIEF REQUEST NO. II-PRR-l, REVISION 1 Use of Code Case OMN-16 ESW Pump Test Using Pump Curves Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 7. Precedents:
- 1) Letter from T. Hiltz (U.S. Nuclear Regulatory Commission) to Vice President of Operations (Arkansas Nuclear One, Entergy Operations, Inc), "Arkansas Nuclear One, Unit No.1 -
Approval of Relief Request for Arkansas Nuclear One Unit 1 Fourth 10-Year Pump and Valve Inservice Testing Program (TAC NOS. MD7709 and MD7710)," dated April 30, 2008
- 2) Letter from J. Clifford (U. S. Nuclear Regulatory Commission) to J. Hutton (PECO Energy Company), "Second 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests Nos. 90-PRR-1, Revision 0; GPRR-3, Revision 2; 11-PRR-1, Revision 0; GVRR-4, Revision 2; GVRR-5, Revision 2; 20-VRR-1, Revision 2; and 41-VRR-6, Revision 0, for Limerick Generating Station, Units 1 and 2 (TAC NOS. MA8077 and MA8079)," dated November 28, 2000 Page 3 of3
RELIEF REQUEST NO. 47-VRR-2, REVISION 0 Control Rod Drive Scram Valves and Check Valves Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
- 1. ASME Code Components Affected:
Valves: Inlet and Outlet Scram Valves XV-47-1-26 (all 185 RCUs) XV-47-2-26 (all 185 RCUs)
XV-47-1-27 (all 185 RCUs) XV-47-2-27 (all 185 RCUs)
Category: B Type: Air Operated Valves: Scram Discharge Riser Check Valve 47-1-14 (all 185 RCUs) 47-2-14 (all 185 RCUs)
Category: C Type: Self-Actuated Code Class: 2
- 2. Applicable Code Edition:
The applicable code edition is the ASME OM Code, 2004 Edition. The new interval is scheduled to begin on January 8,2010 and conclude on January 7,2020.
- 3. Applicable Code Reguirement(s):
Relief is requested from the following requirements:
ISTC-3510 requires that active Category B valves shall be exercised nominally every three months, except as provided by ISTC -3520, ISTC- 3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222.
ISTC-3560 requires valves with fail safe actuators be tested by observing the operation of the actuator upon loss of valve actuating power in accordance with the exercising frequency of ISTC-3510.
ISTC-5131(a) requires that active valves shall have their stroke time measured when exercised in accordance with ISTC-3500.
ISTC-3510 requires that active Category C check valves shall be exercised nominally every three months, except as provided by ISTC-3520, ISTC- 3540, ISTC-3550, ISTC-3570, ISTC-5221, and ISTC-5222.
Page 10f3
RELIEF REQUEST NO. 47-VRR-2, REVISION 0 Control Rod Drive Scram Valves and Check Valves Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
ISTC-5221(a)(2) requires check valves (47-1(2)-14) that have a safety function in only the open direction shall be exercised by initiating flow and observing that the obturator has traveled to either the full open position or to the position required to perform its intended function(s), and verify closure.
4. Reason for Request
Pursuant to 10 CPR 50.55a, "Codes and Standards," paragraph (a)(3)(i), relief is requested to use the guidance provided in Generic Letter 89-04, Position 7. Generic Letter 89-04, Position 7 discusses alternative testing of individual scram valves for control rods in Boiling Water Reactors. Position 7 states that use of these alternatives to satisfy valve testing requirements should be documented in the 1ST Program. NUREG-1482, Revision 1, Section 1.3, states that specific relief is required to implement the positions of Generic Letter 89-04.
- 5. Proposed Alternative and Basis for Use:
Each of the valves listed above represents 1 of 185 CRD Hydraulic Control Unit (HCU) valves.
In order to exercise the Category B valves in accordance with ISTC-3510, and test the fail safe actuators as required by ISTC-3560, the air operated inlet and outlet valves would need to be exercise tested at power nominally every three months. The air operated inlet and outlet scram valves, XV-47-1(2)-26 and XV-47-1(2)-27, open on a signal from the Reactor Protection System to permit rapid insertion of the control rods (scram). These valves can only be tested by scramming the control rod drive. Exercise testing at power will result in rapid insertion of control rods causing potential reactivity transients and wear of the control rod drive mechanisms.
Accordingly, relief is requested to test the valves in accordance with Limerick Generating Station (LGS), Units 1 and 2 Technical Specification (TS) Surveillance Requirement (SR) 4.1.3.2
("Control Rod Maximum Scram Insertion Times"), and in conformance with Generic Letter 89-04, Position 7. Generic Letter 89-04 is discussed in NUREG-1482, Revision 1 ("Guidelines for Inservice Testing at Nuclear Power Plants"):
"The recommendations herein supplement the guidance and technical positions in GL 89-04. Note that specific relief is required to implement the guidance in GL 89-04.
However, relief justification may refer to the positions in the GL with clarifying information to clearly show how it would apply to a licensees situation."
As a proposed alternative, the valve testing will be performed in accordance with the TS SR 4.1.3.2.
ISTC-5131(a) applies to the Category B air operated inlet and outlet scram valves (XV-47-1(2)-26 and XV-47-1(2)-27). Stroke timing of the air-operated valves is impractical since they are not equipped with indication of the open and closed positions. Insertion of the control rod is verified by control room panel lights and not valve position. Accordingly, code compliant stroke time Page 2 of3
RELIEF REQUEST NO. 47-VRR-2, REVISION 0 Control Rod Drive Scram Valves and Check Valves Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
--Alternative Provides Acceptable Level of Quality and Safety--
testing cannot be performed to meet the ISTC-5131(a) requirement. As a proposed alternative, scram time testing as described in GL 89-04, Position 7 will be performed in accordance with LGS, Units 1 and 2 TS SR 4.1.3.2.
ISTC-3510 and ISTC-5221(a)(2) apply to the scram discharge riser check valves. The scram discharge riser check valve 47-1(2)-14 is flow actuated as a result of XV-47-1(2)-27 opening.
These valves can only be tested by scramming the control rod drive in order to demonstrate that the safety function is exercised. Exercise testing at power will result in rapid insertion of control rods causing potential reactivity transients and wear of the control rod drive mechanIsms. Testing will be performed in accordance with LGS, Units 1 and 2 TS SR 4.1.3.2.
- 6. Duration of Proposed Alternative:
Duration will be for the third ten-year interval for LGS, Units 1 and 2, which is scheduled to begin on January 8,2010 and conclude on January 7,2020.
- 7. Precedents:
None Page 3 of3
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