Letter Sequence Response to RAI |
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TAC:MD8932, Control Rod Notch Testing Frequency and SRM Insert Control Rod Action (Approved, Closed) |
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Category:Letter type:RS
MONTHYEARRS-19-045, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2019-04-0101 April 2019
Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
RS-19-034, Fitness for Duty Performance Data Report-Annual 2018 (Cover Letter)2019-02-25025 February 2019
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RS-18-136, Advisement of Leadership Changes for Exelon Generation Company, LLC2018-11-28028 November 2018
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RS-18-081, Advisement of Leadership Changes Update2018-06-18018 June 2018
Advisement of Leadership Changes Update
RS-18-061, Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)2018-05-0202 May 2018
Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)
RS-18-038, Annual Property Insurance Status Report2018-03-30030 March 2018
Annual Property Insurance Status Report
RS-18-025, Submittal of Fitness for Duty Performance Data Reports for the Year 20172018-02-28028 February 2018
Submittal of Fitness for Duty Performance Data Reports for the Year 2017
RS-17-167, Regulatory Commitment Change Summary Report2017-12-20020 December 2017
Regulatory Commitment Change Summary Report
RS-17-172, Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues2017-12-19019 December 2017
Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues
RS-17-118, Advisement of Leadership Changes2017-09-21021 September 2017
Advisement of Leadership Changes
RS-17-077, Advisement of Leadership Changes2017-06-0707 June 2017
Advisement of Leadership Changes
RS-17-070, Response to NRC Regulatory Issue Summary 2017-03, Preparation and Scheduling of Operator Licensing Examinations2017-05-0303 May 2017
Response to NRC Regulatory Issue Summary 2017-03, Preparation and Scheduling of Operator Licensing Examinations
RS-17-053, Response to Request for Additional Information Regarding Generic Letter 2016-012017-04-27027 April 2017
Response to Request for Additional Information Regarding Generic Letter 2016-01
RS-17-057, Update to Correspondence Addressees and Service Lists2017-04-20020 April 2017
Update to Correspondence Addressees and Service Lists
RS-17-045, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2017-03-30030 March 2017
Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
RS-16-046, Annual Property Insurance Status Report2017-03-29029 March 2017
Annual Property Insurance Status Report
RS-17-009, Board Resolutions Associated with Foreign Ownership, Control, or Influence2017-03-0101 March 2017
Board Resolutions Associated with Foreign Ownership, Control, or Influence
RS-17-023, Submittal of Annual 2016 Fitness for Duty Performance Data Reports2017-02-27027 February 2017
Submittal of Annual 2016 Fitness for Duty Performance Data Reports
RS-16-258, Notice of Merger of Subsidiary Non-Qualified Nuclear Decommissioning Trust Entities Into Their Parent Company2016-12-22022 December 2016
Notice of Merger of Subsidiary Non-Qualified Nuclear Decommissioning Trust Entities Into Their Parent Company
RS-16-207, Co., LLC, Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools.2016-11-0303 November 2016
Co., LLC, Response to Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools.
RS-16-160, Request for Exemption from Specific Provisions in 10 CFR 73.55(p) (1)(i) and (p)(1)(ii) Related to the Suspension of Security Measures in an Emergency or During Severe Weather2016-08-16016 August 2016
Request for Exemption from Specific Provisions in 10 CFR 73.55(p) (1)(i) and (p)(1)(ii) Related to the Suspension of Security Measures in an Emergency or During Severe Weather
RS-16-140, Request for Approval of Certified Fuel Handler Training Program Relevant to Clinton, Quad Cities, and Oyster Creek Stations2016-07-18018 July 2016
Request for Approval of Certified Fuel Handler Training Program Relevant to Clinton, Quad Cities, and Oyster Creek Stations
RS-16-156, Response to NRC Regulatory Issue Summary 2016-09, Preparation and Scheduling of Operator Licensing Examinations2016-07-18018 July 2016
Response to NRC Regulatory Issue Summary 2016-09, Preparation and Scheduling of Operator Licensing Examinations
RS-16-120, Fleet: Letter from K. Murdoch (the Northern Trust Company) to W. M. Dean (U.S. NRC) Notice of Disbursement from Decommissioning Trusts2016-05-0404 May 2016
Fleet: Letter from K. Murdoch (the Northern Trust Company) to W. M. Dean (U.S. NRC) Notice of Disbursement from Decommissioning Trusts
RS-16-065, Advisement of Leadership Changes for Exelon Generation Company, LLC2016-05-0303 May 2016
Advisement of Leadership Changes for Exelon Generation Company, LLC
RS-16-094, Property Insurance Status Report for Braidwood Station, Byron Station, Calvert Cliffs, Clinton Power, Dresden Nuclear, LaSalle County, Limerick Generating, Nine Mile Point, Oyster Creek, Peach Bottom, Quad Cities, R.E Ginna, Three Mile Isl2016-04-25025 April 2016
Property Insurance Status Report for Braidwood Station, Byron Station, Calvert Cliffs, Clinton Power, Dresden Nuclear, LaSalle County, Limerick Generating, Nine Mile Point, Oyster Creek, Peach Bottom, Quad Cities, R.E Ginna, Three Mile Isla
RS-16-071, Annual Property Insurance Status Report2016-04-0101 April 2016
Annual Property Insurance Status Report
RS-16-069, Unit 1 - Report on Status of Decommissioning Funding for Shutdown Reactors and Reactors within 5 Years of Shutdown2016-03-31031 March 2016
Unit 1 - Report on Status of Decommissioning Funding for Shutdown Reactors and Reactors within 5 Years of Shutdown
RS-16-008, Response to NRC Regulatory Issue Summary 2015-16, Revision 1, Planned Licensing Action Submittals for All Power Reactor Licensees.2016-02-29029 February 2016
Response to NRC Regulatory Issue Summary 2015-16, Revision 1, Planned Licensing Action Submittals for All Power Reactor Licensees.
RS-16-041, Proposed Alternative to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1.2016-01-28028 January 2016
Proposed Alternative to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1.
RS-16-011, Update to Correspondence Addressees and Service Lists2016-01-0606 January 2016
Update to Correspondence Addressees and Service Lists
RS-15-321, Submittal of Regulatory Commitment Change Summary Report in Response to NRC Order EA-02-0262015-12-17017 December 2015
Submittal of Regulatory Commitment Change Summary Report in Response to NRC Order EA-02-026
RS-15-245, Submittal of Supplement to Foreign Ownership Control or Influence Package2015-11-18018 November 2015
Submittal of Supplement to Foreign Ownership Control or Influence Package
RS-15-229, Advisement of Leadership Changes for Exelon Generation Company, Llc., NRC, Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package, Dated July 2, 20142015-08-11011 August 2015
Advisement of Leadership Changes for Exelon Generation Company, Llc., NRC, Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package, Dated July 2, 2014
RS-15-118, Supplemental Information for Request for Relaxation of Condition V(A)(A.1 (1) of Confirmatory Order EA-13-0682015-04-13013 April 2015
Supplemental Information for Request for Relaxation of Condition V(A)(A.1 (1) of Confirmatory Order EA-13-068
RS-15-109, Proposed Alternative to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 12015-04-0606 April 2015
Proposed Alternative to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1
RS-15-104, Annual Property Insurance Status Report2015-04-0101 April 2015
Annual Property Insurance Status Report
RS-15-094, (EGC) - Submittal of Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2015-03-31031 March 2015
(EGC) - Submittal of Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
RS-15-082, Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors2015-03-0202 March 2015
Response to Request for Additional Information License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors
RS-15-079, Fitness for Duty Performance Data Reports - Annual 20142015-02-27027 February 2015
Fitness for Duty Performance Data Reports - Annual 2014
RS-15-066, Advisement of Leadership Changes for Exelon Generation Company, LLC2015-02-10010 February 2015
Advisement of Leadership Changes for Exelon Generation Company, LLC
RS-15-052, (EGC) Response to NRC Regulatory Issue Summary 2014-13, Planned Licensing Action Submittals for All Power Reactor Licensees.2015-01-30030 January 2015
(EGC) Response to NRC Regulatory Issue Summary 2014-13, Planned Licensing Action Submittals for All Power Reactor Licensees.
RS-15-051, Update to Correspondence Addressees and Service Lists2015-01-22022 January 2015
Update to Correspondence Addressees and Service Lists
RS-14-350, Submission of Standard Practice Procedures Plans2014-12-16016 December 2014
Submission of Standard Practice Procedures Plans
RS-14-340, Advisement of Leadership Changes for Exelon Generation Company, LLC2014-12-0202 December 2014
Advisement of Leadership Changes for Exelon Generation Company, LLC
RS-14-315, Dissolution of Exelon Ventures Company, LLC2014-10-27027 October 2014
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RS-14-277, Proposed Alternative to Utilize Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 12014-09-24024 September 2014
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RS-14-190, Revision to Registration of Exelon Generation Company, LLC as an Authorized User of NRG-Licensed Transport Package2014-07-0808 July 2014
Revision to Registration of Exelon Generation Company, LLC as an Authorized User of NRG-Licensed Transport Package
RS-14-160, Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package2014-07-0202 July 2014
Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package
RS-14-164, (EGC) Response to NRC Regulatory Issue Summary 2014-05, Preparation and Scheduling of Operator Licensing Examinations2014-05-29029 May 2014
(EGC) Response to NRC Regulatory Issue Summary 2014-05, Preparation and Scheduling of Operator Licensing Examinations
2019-04-01
[Table view] |
Text
Exelon Nuclear www.exeloncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 RS-09-064 September 4, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Oyster Creek Nuclear Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219
Subject:
Oyster Creek Nuclear Generating Station - Response to Request for Additional Information Regarding Control Rod Drive Notch Testing Frequency (TAC NO.
MD8932)
References:
(1) Letter from P. B. Cowan (AmerGen Energy Company, LLC) to U.S. Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency, Clarification of SRM Insert Control Rod Action, and Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process," dated June 9,2008 (2) Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, IISupplement to License Amendment Request RE:
Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency, Clarification of SRM Insert Control Rod Action, and Clarification of a Frequency Example Using the Consolidated Line Item Improvement Process, II dated March 30, 2009 (3) Letter from E. Miller (U.S. Nuclear Regulatory Commission) to C. Pardee (Exelon Generation Company, LLC), IIThree Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding Control Rod Drive Control System Replacement License Amendment (TAC NO. MD8932),"
dated August 28, 2009 By letter dated June 9, 2008 (Reference 1), AmerGen Energy Company, LLC (now Exelon Generation Company, LLC (Exelon)) requested a change to the Technical Specifications to implement TSTF/CLIIP-475. Reference 2 involved additional information requested by the NRC associated with the proposed change. Subsequently, the NRC determined that additional information is needed to complete its review (Reference 3). Exelon's response to the NRC question in Reference 3 is provided in Attachment 1 to this letter.
U.S. Nuclear Regulatory Commission September 4, 2009 Page 2 Exelon has determined that the information provided in this response does not change the proposed Technical Specifications marked-up pages (Reference 2) and does not impact the conclusions of the No Significant Hazards Consideration as stated in Reference 1.
There are no regulatory commitments contained in this letter.
A copy of this letter and its attachments are being provided to the designated State official and the chief executive of the township in which the facility is located.
Should you have any questions concerning this letter, please contact Frank J. Mascitelli at (610) 765-5512.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of September 2009.
Respectfully, Pamela B. Cowan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Oyster Creek Nuclear Generating Station - Response to Request for Additional Information Regarding Control Rod Drive Notch Testing Frequency (TAC NO. MD8932) cc: S. J. Collins, Administrator, USNRC Region I M. S. Ferdas, USNRC Senior Resident Inspector, Oyster Creek C. Gratton, USNRC Project Manager, Exelon Fleet G. E. Miller, USNRC Project Manager, Oyster Creek Mayor of Lacey Township P. Baldauf, Assistant Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection
Attachment 1 Oyster Creek Nuclear Generating Station - Response to Request for Additional Information Regarding Control Rod Drive Notch Testing Frequency (TAC NO. MD8932)
Attachment 1 Oyster Creek Nuclear Generating Station - Response to Request for Additional Information Regarding Control Rod Drive Notch Testing Frequency Page 1 of 2 The following is the question received in a letter from E. Miller (U.S. Nuclear Regulatory Commission) to C. Pardee (Exelon Generation Company, LLC), "Oyster Creek Nuclear Generating Station-Request for Additional Information Regarding Control Rod Drive Rod Notch Testing Frequency (TAC NO. MD 8932),11 dated August 28,2009, followed by the corresponding Exelon response to the question.
Question 1:
The model safety evaluation referenced in the license amendment request evaluates a reduction of the frequency for performing control rod notch testing for fully withdrawn control rods while the proposed change for Oyster Creek would decrease the frequency for both fully and partially withdrawn control rods. Please provide justification for why the decreased frequency of performing control rod notch testing in accordance with SR 4.2.0 for partially withdrawn control rods will adequately assure the necessary quality of the control rod system and its components. Additionally, please identify and discuss any differences in the frequency or method of performing scram time testing for fully and partially withdrawn control rods.
Response
Exelon has reviewed the model safety evaluation and determined that the evaluation and analysis provided for the fully withdrawn control rod drives is applicable to the partially withdrawn Control Rod Drives (CRDs). The operating experience related to the changes in CRD performance provided additional justification to reduce the notch test frequency for the partially withdrawn control rods. There is no difference in the design, operation or maintenance between a partially and fully withdrawn CRD. The only minor difference between a partially and fully withdrawn CRD is that the index tube of a partially withdrawn CRD rests on the collet at a different position than it does for the fully withdrawn CRD. Pressure and flow required for CRD motion is independent of notch position. In regards to control rod drive design and operation, there is no significant difference between the Oyster Creek Nuclear Generating Station (OCNGS) reactor core design, structure and operation and the typical reactor core on which the model safety evaluation is based that would affect the analysis or assumptions. The maintenance practices and methodologies are consistent with GE Energy-Nuclear recommendations for both partially and fully withdrawn CRDs.
As noted in the model safety evaluation after a review of the accumulation of operating experience, the NRC concluded that no known CRD failures have been detected during the notch testing exercises. The NRC staff concluded that the changes would reduce the number of control rod manipulations thereby reducing the opportunity for potential reactivity events while having a very minimal impact on the extremely high reliability of the CRD system. In addition, the model safety evaluation identified no difference in the predicted crack growth rate of the Collet Retainer Tube (CRT) between partially and fully withdrawn control rod drives. As stated in the model safety evaluation, CRT crack growth is dependent on the functions of water oxygen level, conductivity, material sensitization and applied loads and not on the position of the CRD. The proposed surveillance interval (31 days) remains short enough to be effective in detecting failed CRTs for partially withdrawn control rods.
Attachment 1 Oyster Creek Nuclear Generating Station - Response to Request for Additional Information Regarding Control Rod Drive Notch Testing Frequency Page 2 of 2 In regards to the scram time testing, there are no differences in the frequency or method of performing scram time testing for fully and partially withdrawn control rods. OCNGS Technical Specification 4.2.C.3 states that control rods shall be scram time tested liOn a frequency of less than or equal to once per 180 days of cumulative power operation, for at least 20 control rods, on a rotating basis, with reactor coolant pressure greater than 800 psig. The OCNGS scram time testing procedure requires the CRD to be fully II withdrawn prior to performing scram time testing. The primary assurance of scram system reliability is provided by scram time testing since it monitors the system scram operation, CRD structure and integrity, and the complete travel of the CRD, which CRD notch testing does not accomplish.
In addition, the NRC recently approved a similar license amendment request (Reference 1) for Nine Mile Point 1.
Reference 1:
ML090160353: Nine Mile Point Nuclear Station, Unit No.1 - Issuance of Amendment Re: Revision of Control Rod Notch Surveillance Test Frequency Using the Consolidated Line Item Improvement Process (TAC No. MD9539), dated February 11,2009.