ML17306A014
| ML17306A014 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Nine Mile Point, Oyster Creek, Clinton, Quad Cities, FitzPatrick, LaSalle |
| Issue date: | 11/01/2017 |
| From: | David Helker Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML17306A014 (7) | |
Text
Exelon Generation.,
200 hdun Way Ki:nn.:tt Squa11;, PA 191-18
\\\\'\\\\\\I C\\don.:111 p t:Olll 1 O CFR 50.55a(z)
November 1, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRG Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRG Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRG Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRG Docket Nos. 50-373 and 50-374 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRG Docket Nos. 50-220 and 50-41 O Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 USNRC Docket No. 50-219 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR 29 and DPR 30 NRG Docket Nos. 50-254 and 50-265 Submittal of Relief Request for an Alternative to the ASME Code - Revise Main Steam Isolation Valve Partial Stroke Testing Frequency Pursuant to 1 O CFR 50.55a(z)(1 ), Exelon Generation Company, LLC (Exelon) hereby requests approval of the attached relief request associated with the inservice testing (IST) programs for Clinton Power Station, Unit 1; Dresden Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; and Quad Cities Nuclear Power Station, Units 1 and 2.
U.S. Nuclear Regulatory Commission Proposed Relief Request for MSIV Partial Stoke Testing Frequency November 1, 2017 Page2 The relief request proposes authorization to exercise valves on a limited basis, in accordance with the Surveillance Frequency Control Program, that are currently restricted to cold shutdown testing requirements in accordance with ISTC-3521 (b}. The basis for this request is provided in the Attachment.
This relief request is for the current and/or next IST interval for Clinton Power Station, Unit 1 (third interval); Dresden Power Station, Units 2 and 3 (fifth interval); James A.
FitzPatrick Nuclear Power Plant (fourth and fifth intervals); LaSalle County Station, Units 1 and 2 (fourth interval); Nine Mile Point Nuclear Station, Units 1 and 2 (fourth and third intervals, respectively); Oyster Creek Nuclear Generating Station (fifth interval); and Quad Cities Nuclear Power Station, Units 1 and 2 (fifth interval).
Exelon requests approval of this request by April 30, 2018, to permit incorporation of this testing into the Surveillance Frequency Control Program at each station.
There are no regulatory commitments contained in this letter.
If you have any questions regarding this letter, please contact David Neff at (610) 765-5631.
Respectfully,
- .,c,r~
David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Description and Assessment of the Proposed Alternative to the ASME Code to Revise Main Steam Isolation Valve Partial Stroke Testing Frequency cc:
USNRC Regional Administrator - NRC Region I USNRC Regional Administrator - NRC Region Ill USNRC Project Manager, NRR - Clinton Power Station USNRC Project Manager, NRR - Dresden Power Station USNRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant USNRC Project Manager, NRR - LaSalle County Station USNRC Project Manager, NRR - Nine Mile Point Nuclear Station USNRC Project Manager, NRR - Oyster Creek Nuclear Generating Station USNRC Project Manager, NRA-Quad Cities Nuclear Power Station USNRC Senior Resident Inspector - Clinton Power Station USNRC Senior Resident Inspector - Dresden Power Station USNRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant USNRC Senior Resident Inspector - LaSalle County Station USNRC Senior Resident Inspector - Nine Mile Point Nuclear Station USNRC Senior Resident Inspector-Oyster Creek Nuclear Generating Station USN RC Senior Resident Inspector - Quad Cities Nuclear Power Station A. L. Peterson, NYSERDA Illinois Emergency Management Agency - Division of Nuclear Safety (w/o att))
R. R. Janati - Bureau of Radiation Protection, Commonwealth of Pennsylvania Director, Bureau of Nuclear Engineering, New Jersey, Dept. of Environmental Protection
ATTACHMENT Description and Assessment of the Proposed Alternative to the ASME Code to Revise Main Steam Isolation Valve Partial Stroke Testing Frequency Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30
Description and Assessment of the Proposed Alternative to the ASME Code to Revise Main Steam Isolation Valve Partial Stroke Testing Frequency Request in Accordance with 10 CFR 50.55a(z)(1)
- 1. ASME Code Components Affected ASME Code ASME OM Plant Valve Numbers Function Code Class Categorl Clinton Power Station, Unit 1 1B21-F022A, B, C and D MSIV 1
A 1 B21-F028A, B, C and D 2-0203-1 A, B, C and D Dresden Nuclear Power 2-0203-2A, B, C and D MSIV 1
A Station, Units 2 and 3 3-0203-1 A, B, C and D 3-0203-2A, B C and D James A. FitzPatrick Nuclear 29AOV-80A, B, C and D MSIV 1
A Power Plant 29AOV-86A, B, C and D 1B21-F022A, B, C and D LaSalle Units 1 and 2 1B21-F028A, B, C and D MSIV 1
A 2B21-F022A, B, C and D 2821-F028A, B, C and D Nine Mile Point Nuclear IV-01-03 and 04 MSIV 1
A Station, Unit 1 Nine Mile Point Nuclear 2MSS*AOV6A, B, C and D MSIV 1
A Station, Unit 2 2MSS*AOV7A, B, C and D Oyster Creek Nuclear V-01-07, 08, 09 and 10 MSIV 1
A Generating Station 1-0203-001 A, B, C and D Quad Cities Nuclear Power 1-0203-002A, B, C and D MSIV 1
A Station, Units 1 and 2 2-0203-001A, B, C and D 2-0203-002A, B, C and D
2. Applicable Code Edition and Addenda
Plant Interval Edition Start End Clinton Power Station, Third 2004 Edition July 1, 2010 June 30, 2020 Unit 1 Dresden Nuclear Power Fifth 2004 Edition through November 1, 2013 October 31, 2023 Station, Units 2 and 3 2006 Addenda James A. FitzPatrick Fourth 2001 Edition through October 1, 2007 May31,2018 Nuclear Power Plant 2003 Addenda James A. FitzPatrick Fifth 2004 Edition through June1,2018 September 30, 2027 Nuclear Power Plant 2006 Addenda LaSalle Units 1 and 2 Fourth 2004 Edition, through October 12, 2017 October 11, 2027 2006 Addenda Nine Mile Point Nuclear Fourth 2004 Edition January 1, 2009 December 31, 2018 Station, Unit 1 Nine Mile Point Nuclear Third 2004 Edition January 1, 2009 December 31, 2018 Station, Unit 2 Page 1 of 4
Description and Assessment of the Proposed Alternative to the ASME Code to Revise Main Steam Isolation Valve Partial Stroke Testing Frequency Request in Accordance with 10 CFR 50.55a(z)(1)
Plant Interval Edition Start End Oyster Creek Nuclear Fifth 2004 Edition, through October 14, 2012 October 13, 2022 Generating Station 2006 Addenda Quad Cities Nuclear 2004 Edition, through Power Station, Units 1 Fifth February 18, 2013 February 17, 2023 and 2 2006 Addenda
3. Applicable Code Requirement
ISTC-3520, "Exercising Requirements", Section ISTC-3521 (b) states "if full-stroke exercising during operation at power is not practicable, it may be limited to part-stroke during operation at power and full-stroke during cold shutdown".
4. Reason for Request
Pursuant to 10 CFR 50.55a, "Codes and Standards", paragraph (z)(1}, relief is requested from the requirement of ASME OM Code ISTC-3521 (b). The basis of the relief request is the proposed alternative would provide an acceptable level of quality and safety.
The existing lnservice Testing (IST} Program Cold Shutdown Justifications for full stroke testing, under ISTC-3521 (c) at each station listed in this request, will be modified to remove the existing quarterly partial stroke exercise testing of the Main Steam Isolation Valves (MSIV), under ISTC-3521{b). This will be done to address the potential for the valves to fully close inadvertently during the quarterly exercise testing.
Full closure of the valves, at power, will cause a reactivity event and potential loss of power production of the affected unit. Challenges like these, and their potential consequence, have also been recognized in NUREG 1482 Revision 2. The NUREG discusses activities generating these challenges and states they should be considered impracticable, thereby supporting the Cold Shutdown Justification (CSJ) principal arguments.
In each station's Technical Specifications (TS}, the frequency for the Reactor Protection System (RPS) Instrumentation Surveillance Requirement (SR) Channel Functional Test (CFT} is stated as "In accordance with the Surveillance Frequency Control Program (SFCP)." The specific TS SR for each station is provided in the table below. The only practical method to perform the RPS CFT for the MSIV position switch input into the RPS logic is to actually stroke the MSIV. There are no other TS compliant methods available without reducing reactor power and entering the normally inerted primary containment. This would result in unwarranted power reductions and personnel radiation exposures.
Page 2 of 4
Description and Assessment of the Proposed Alternative to the ASME Code to Revise Main Steam Isolation Valve Partial Stroke Testing Frequency Request in Accordance with 10 CFR 50.55a(z)(1)
Plant Technical S~ecifications Section for RPS CFT Clinton Power Station, Unit 1 3.3.1.1.9 Dresden Nuclear Power 3.3.1.1.18 Station, Units 2 and 3 James A. FitzPatrick Nuclear 3.3.1.1.8 Power Plant LaSalle Units, 1 and 2 3.3.1.1.9 Nine Mile Point Nuclear 4.2.7.C and 4.6.2.a(6)
Station, Unit 1 Nine Mile Point Nuclear 3.3.1.1.8 Station, Unit 2 Oyster Creek Nuclear 4.1.1.(10)
Generating Station Quad Cities Nuclear Power 3.3.1.1.18 Station, Units 1 and 2 The stations listed in this relief request have elected, due to recent documentation describing MSIV industry test failures, to utilize the SFCP for the CFT to extend the test frequency of the CFT, over a period of time, up to a refueling outage. A refueling outage test frequency would eliminate any stroking of MSIVs during power operation of the units.
It was realized that in order to utilize the SFCP for the MSIVs, the valves would have to be partial stroke exercised at power, for a number of years, to achieve the final goal of stroking at a refueling outage frequency. This methodology would allow for a progressively longer test interval until the final refueling outage testing interval was achieved. This could not be done with the CSJ in the IST Program, as the stroking of the valves in accordance with the SFCP would be in contradiction with the CSJ, which would not permit stroking of the valves during normal power operation.
5. Proposed Alternative and Basis for Use
Exelon proposes that the stations listed in this relief request continue partial stroke exercising the MSIVs for the sole purpose of supporting the requirements of the SFCP testing intervals that would require progressively longer surveillance intervals until the final refueling outage frequency was achieved. The CSJ would restrict any other stroking of the MSIVs. Both the CSJ and the SFCP are needed together to address the removal of the challenges of partial stroke exercising, as defined in the CSJ, to support safer and more reliable continued operation of the units.
Page 3 of 4
Description and Assessment of the Proposed Alternative to the ASME Code to Revise Main Steam Isolation Valve Partial Stroke Testing Frequency Request in Accordance with 1 O CFR 50.55a(z}(1}
Duration of Proposed Alternative This relief request will be applied for the duration of the inservice inspection intervals defined in Section 2 of this relief request including the current 10-year IST interval for each station and the next 10-year IST interval for James A. FitzPatrick Power Station.
- 6. Precedent Peach Bottom Atomic Power Station, Units 2 and 3 - Safety Evaluation of Relief Request Number 01A-VRR-4 Regarding the Fourth 10-Year Interval of the lnservice Testing Program, SE dated April 28, 2017 (ADAMS Accession No. ML17108A762)
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