ML13249A189

ILRT Extension LAR Pre-submittal Meeting Slides

ML13249A189
Person / Time
Site:	Braidwood
Issue date:	09/04/2013
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
Joel Wiebe, NRR/DORL 415-6606
References
Download: ML13249A189 (10)

Text

License Amendment Request Pre-Submittal Meeting Integrated Leak Rate Test Interval Extension Exelon Generation Company, LLC Braidwood Station, Unit 2 September 19, 2013

Agenda I. History / Background II. Problem Statement III. Proposed Request IV. Justification V. Conclusions VI. Proposed Schedule VII. Additional Insights VIII. NRC Feedback / Questions 1

History / Background

• On April 2, 2008, the NRC issued an amendment for Braidwood and Byron Stations approving a one-time Integrated Leak Rate Test (ILRT) interval extension of 5 years (i.e., from 10 to 15 years)

• The revised Technical Specification (TS) 5.5.16, Containment Leak Rate Testing Program, notes a specific date by which each units next ILRT (i.e., Type A test) must be performed

- The last Braidwood Unit 2 ILRT was performed on May 4, 1999

- For Braidwood Unit 2, TS 5.5.16 states: Type A test shall be performed no later than May 4, 2014

• TS Limiting Condition of Operation (LCO) 3.6.1 states that the Containment shall be OPERABLE, in MODES 1, 2, 3, and 4

- Containment operability is demonstrated by performing testing in accordance with TS 5.5.16 as specified in surveillance requirement (SR) 3.6.1.1 2

Problem Statement

• TS 5.5.16 specifies that for Braidwood Unit 2, Type A test shall be performed no later than May 4, 2014

- Unit 2 is scheduled to shutdown for refueling on May 3, 2014

- Unit 2 ILRT is scheduled to be performed during the refueling outage; however, will not be completed by May 4, 2014

- TS 5.5.16 (strictly applied) would still be violated given this timeline

• Braidwood Unit 2 will be out of the MODE of Applicability for TS 3.6.1 which requires an OPERABLE containment (i.e., the unit will be in MODE 5) by end of day May 3, 2014 (prior to the TS 5.5.16 requirement to perform the ILRT)

• Exelon Generation Company, LLC (EGC) is requesting a license amendment to preclude violating TS 5.5.16

- The latitude afforded by SR 3.0.1; i.e., SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs will not be utilized 3

Proposed Request

• EGC requests NRC approval of a change to the ILRT date specified in TS 5.5.16 to ensure the TS ILRT date is consistent with the ILRT date in the outage schedule

• Specifically, it is requested that the NRC approve an extension of the Braidwood Unit 2 ILRT performance date as noted below:

4

Justification

• The Unit 2 refueling outage is scheduled to begin on May 3, 2014

• The Unit 2 ILRT, assuming target dates are met, will be performed on

~May 21, 2014; a 17-day extension from the current TS due date

• Given the planned schedule, Unit 2 will be out of the MODE of Applicability of TS 3.6.1 which requires an OPERABLE containment (i.e., the unit will be in MODE 5 or 6) during the entire period of the requested extension

• TS 5.5.16 states that the Containment Leakage Rate Testing Program is conducted in accordance with NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J

- NEI 94-01, Section 9.2.2, Initial Test Intervals, states:

If the test interval ends while primary containment integrity is either not required or it is required solely for shutdown activities, the test interval may be extended indefinitely.

However, a successful Type A test shall be completed prior to entering the operating mode requiring primary containment integrity.

- Extending the Unit 2 ILRT interval past May 4, 2014, while the unit is in an outage, is consistent with this NEI guidance 5

Conclusions

• As shown in the previous discussion, an extension to the ILRT date specified in TS 5.5.16 does not challenge containment integrity and meets the intent of the one-time 5 year ILRT extension

• Extending the ILRT date will not:

- involve a significant increase in the probability or consequences of an accident previously evaluated

- create the possibility of a new or different kind of accident; or

- involve a significant reduction in a margin of safety

• There is reasonable assurance that the health and safety of the public will not be endangered by the proposed action as containment integrity is not required during the requested extension period

• Issuance of the proposed amendment will not be inimical to the common defense and security

• The proposed action would meet the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9); and not require an environmental assessment 6

Proposed Schedule

• EGC will submit the proposed LAR on or before October 18, 2013

• Based on the current ILRT date specified in TS 5.5.16 (May 4, 2014),

EGC respectfully requests NRC approval of the requested change by May 2, 2014 7

Additional Insights

• Based on the previous information, specifically:

- Containment operability is demonstrated by performing testing in accordance with SR 3.6.1.1 (which references TS 5.5.16)

- If the ILRT is treated as a SR, the latitude of SR 3.0.1 could be applied (i.e., SRs shall be met during the MODES or Conditions specified in the TS Applicability for the LCO)

- Given the projected schedule, Unit 2 will not be in the MODE of Applicability during the entire period of the requested extension

- Extending the ILRT interval is consistent with NEI 94-01 guidance

- As long as the unit is out of the MODE of Applicability prior to the required ILRT date, the intent of TS 5.5.16 is met

• As an alternative, EGC would be amenable to submitting a letter to the NRC committing to complete the Unit 2 ILRT prior to entering MODE 4 (i.e., the MODE of Applicability for containment operability) following the May 2014 refueling outage 8

NRC Feedback / Questions 9