RS-12-026, Submittal of Relief Requests Associated with the Fifth Inservice Testing Interval

From kanterella
(Redirected from RS-12-026)
Jump to navigation Jump to search

Submittal of Relief Requests Associated with the Fifth Inservice Testing Interval
ML12046A334
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 02/15/2012
From: Gullott D
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-12-026
Download: ML12046A334 (25)
v • d • e


Text

~~~~~--~~----~-----------------------------------

Exelon Generation Exelon Generation Company, Company,LLC LLC www.exeloncorp.com www.exeloncorp.com 4300 Winfield Road 4300 Road Nuclear Warrenville, IL Warrenville, 60555 IL 60555 February 15, February 15, 2012 2012 10 10 CFR CFR 50.55a RS-1 2-026 RS-12-026 U. S. Nuclear U. Nuclear Regulatory Regulatory Commission Commission AATTN:

TIN: Document Control Control Desk Washington,D.C.

Washington, D.C. 20555-0001 Quad Cities Nuclear Power Station, Quad Station, Units Units 1 and 2 Renewed Facility Facility Operating Operating License LicenseNos. Nos. DPR-29 DPR-29 and and DPR-30 DPR-30 NRC Docket Nos. Nos. 50-254 and and 50-265

Subject:

Submittal Submittal of of Relief Requests Associated with the Fifth Fifth Inservice Testing Interval The purpose of this letter is to letter is to request approval approval of of proposed proposed relief relief requests in accordance accordance with with 1010 CFR CFR 50.55a, "Codes and 50.55a, "Codes and standards."

standards." The attached relief relief requests are associated associated with with the Fifth 10 - Year Inservice Testing (IST)

Fifth 10-Year (1ST) Program Program Interval Interval for for Quad Quad Cities Nuclear Station (QCNPS).

Power Station (QCNPS). The TheFifth Fifth 10 -Year Interval 10-Year Intervalbegins begins on on February February 18,18, 2013 and is is required by 10 CFR 50.55a(f)(4) required by 10 CFR 50.55a(f)(4) to comply with with the requirements of the American Society Society of of Mechanical Engineers (ASME)

Mechanical Operation and (ASME) Operation and Maintenance (OM) (OM) Code (2004(2004 Edition Edition through 2006 through 2006 Addenda).

The QCNPS QCNPS IST 1STFifth Fifth 10-10-year year Interval will will be in in effect effect from from February February 18,18, 2013 to to February 17, 2023.2023. Accordingly, Accordingly, we werequest requestapproval approval of of the the enclosed enclosed relief relief requests requests byby February February 18, 2013.

Should Should you you have any questions concerning concerning this letter,letter, please please contact Joseph Joseph A. A. Bauer Bauer at 630-630-657-2804.

Respectfully, Respectfully, 72fJ~---

David M. M. Gullott Gullott Manager Manager - Licensing Licensing Exelon Generation Generation Company, LLC LLC

Attachment:

Cities Nuclear Quad Cities Nuclear Power Power Station Station Inservice InserviceTesting TestingProgram Program Fifth Fifth 10-Year Interval Proposed Relief Interval Proposed Relief Requests Requests cc:

cc: Regional Administrator Administrator -- NRC NRC Region Region IIIIII NRC NRC Senior SeniorResident Resident Inspector Inspector -- Quad QuadCities CitiesNuclear NuclearPower PowerStation Station

ATTACHMENT Quad Cities Nuclear Power Station Inservice Testing Program Program Fifth Fifth 10-Year 10-YearInterval Interval Proposed Relief Requests Des! nator Designator Descri ption Description Comments RV-01 Use of Tolerances for OM Code Test New relief request Frequencies RV-02 Use of Code Case OMN-1 (MOV Testing) New relief request RV-03 Pressure Isolation Valve (PIV) Leak Test New relief request Frequency Consistent Consistent withwith Appendix Appendix J, J, Option Option BB RV-04 High Pressure Coolant Injection System Exhaust Approved for Fourth Fourth Line Line Drain Drain Pot Pot to to Gland Gland Seal Seal Condenser Condenser IST Interval 1ST Solenoid Valve Cannot be Stroke Timed RV-05 Class 1 Pressure Relief Valves Test Frequency Approved for Fourth from 5-Year Test from Test Interval Interval to Six-Year Test Test IST Interval 1ST Interval with 6-Month Grace Grace RV-06 Main Steam Main Steam Safety Safety Valve Set Point Point Testing, Approved for Fourth Additional Testing Requirements Requirements IIST ST Interval RV-07 Main Steam Isolation Main Isolation Valve Valve Technical Approved for Fourth Specification Stroke Stroke Time Time Limits Limits in in Lieu Lieu of of ASME ASME IST Interval 1ST OM ISTC Stroke Stroke Time Time Limits Limits Page 1 of 24

10 CFR 50.55a Number RV-01 SO.SSa Request Number RV-01 Relief Requested In Accordance with 10 CFR 50.55a(a)(3)(ii)

SO.SSa(a)(3)(ii)

Hardship or Unusual Difficulty Difficulty Without Compensating Increase Increase in Level Level ofof Quality Quality or or Safety Safety Page 1 of 4 ASME Code 1. Components ASME Code Components Affected Affected All Pumps and Valves contained within All Pumps the Inservice Testing Program scope.

within the scope.

Applicable2.Code Edition Applicable Codeand EditionAddenda and Addenda ASME OM Code 2004 Edition through 2006 2006 Addenda Addenda Applicable3. Code Requirement Applicable Code Requirement This request applies to to the the frequency frequency specifications specifications of of the the ASME ASME OM OM Code.

Code. The The frequencies for tests given in the ASME OM Code do do not not include include aa tolerance tolerance band.

ISTA-3120(a) - "The frequency for the inservice testing shall be be inin accordance with the requirements requirements of of Section Section IST."

1ST."

ISTB-3400 -- Frequency of Inservice TestsTests I STC-3510 -

ISTC-3510 Exercising Test Frequency ISTC-3540 -- Manual Valves ISTC-3630(a) - Frequency ISTC-3700 - Position Verification Testing I STC-5221 (c)

ISTC-5221 (3) --

(c)(3) "At least "At least one one valve valve from fromeach each group group shall shall be be disassembled disassembled and examined at at each eachrefueling refueling outage; outage; all all valves valves in in aa shall be group shall be disassembled and examined examined at at least least once once every 8 years."

Appendix I,1,1-1320 I-1320 -- Test Frequencies, Class 11 Pressure Pressure Relief Relief Valves Valves Appendix I,I, 1-1330 Appendix 1-1330 - Test Frequencies, Class 1 Nonreclosing Pressure Pressure Relief Relief Devices Appendix Appendix I,I, 1-1340 1-1340 -- Test Frequencies Frequencies -- Class Class 11 Pressure PressureRelief ReliefValves Valves that that are are used for used for Thermal Thermal Relief Relief Application Application Appendix Appendix I,I, 1-1350 1-1350 - Test Frequencies - Class 2 and 3 PressurePressure Relief Relief Valves Valves Page 2 of 24

10 CFR 50.55a SO.SSa Request Request Number NumberRV-01 RV-01 Page 2 of of44 Appendix I,1,1-1360 1-1360 - Test Frequencies - Class 2 and 3 Nonreclosing Nonreclosing Pressure Pressure Relief Devices 1-1370 -

Appendix I,1,1-1370 Test Frequencies Frequencies -- ClassClass 22 and and 33Primary Primary Containment Containment Vacuum Relief Relief Valves Appendix I, 1-1380 1-1380 - Test Frequencies Frequencies -- Class Class22and and33Vacuum VacuumReliefRelief Valves Valves Except for Primary Containment Containment VacuumVacuum Relief Relief Valves Valves Appendix I, 1-1390 1-1390 - Test Frequencies Frequencies -- Class Class 11 Pressure PressureRelief Relief Valves Valves that that are are used for used for Thermal Thermal Relief Relief Application Application Appendix Appendix11, II, 11-4000(a)(1) - Performance Improvement Activities Interval Interval Appendix II, II-4000(b)(1)(e) 11-4000(b)(1)(e) - Optimization of Condition Monitoring Monitoring Activities Activities Interval 4.

4. Reason for Request

Pursuant to Pursuant to 1010 CFR CFR 50.55a, SO.SSa,"Codes "Codesand andstandards,"

standards,"paragraph paragraph (a)(3)(ii),

(a)(3)(ii),relief reliefisis requested from requested from the frequency specifications of the the ASME ASMEOM OMCode.Code. The basis of the of the relief relief request request is is that that the the Code Code requirement requirement presents presents an undue hardship hardship without without aa compensating compensating increase increaseininthethelevel levelofofquality qualityororsafety.

safety.

ASME ASME OM OMCode Code Section IST establishes the 1ST establishes theinservice inservicetest testfrequency frequencyfor forall all components within within thethe scope scope of of the the Code.

Code. The The frequencies frequencies (e.g.,

(e.g., quarterly) quarterly) have always been been interpreted interpreted as as"nominal" "nominal" frequencies frequencies (generally (generally asasdefined definedin inthe the Table 3.2 of of NUREG NUREG 1482, Revision Revision 1) 1) and and Owners Ownersroutinely routinely applied applied thethe surveillance extension time time period (i.e.,

(Le., grace grace period) period) contained contained in in the the plant plant Technical Specifications (TS) Surveillance Surveillance Requirements Requirements (SRs).

(SRs). The TheTS TStypically typically allow for allow for aa less less than or equal equal toto 25%

2S% extension extension of of the the surveillance surveillance testtestinterval interval toto accommodate plant accommodate plant conditions conditions thatthat may maynot notbebesuitable suitablefor forconducting conducting the the surveillance (SR surveillance (SR 3.0.2).

3.0.2). However, However, regulatory issues have been regulatory issues been raised raised concerning the the applicability applicability of the TS TS "Grace "Grace Period" Period" to to ASME ASME OM OM Code Code required required inservice test frequencies frequencies irrespective irrespective of of allowances allowances provided provided under underTS TS Administrative Controls (Le.,

Administrative Controls (i.e., TS TS S.S.6, 5.5.6, "Inservice "Inservice Testing Testing Program," invokes SR 3.0.2 for various OM OM Code frequencies).

The lack of a tolerance band band on on the theASME ASME OM OM Code inservice test test frequency frequency restricts operational flexibility. There may be operationalflexibility. be aa conflict conflict where a surveillance surveillance testtest could be required (i.e.,

could (Le., its Frequency Frequency couldcould expire),

expire), but where itit is not possible or or not desired thatthat itit be be performed performed untiluntil sometime sometime after afteraaplant plantcondition condition or or associated Limiting associated Limiting Condition Conditionfor forOperation Operation(LCO)(LCO)isiswithin withinits itsapplicability.

applicability.

Therefore, to avoid this conflict, the surveillance test should conflict, the should bebeperformed performedwhen whenitit can be and and should should be be performed.

performed.

Page 3 of 24

10 CFR 50.55a RequestRequest NumberNumberRV-01 RV-01 Page 3 of of4 4 The NRC recognized this potential issue issue inin the the TS TSby byallowing allowing aa frequency frequency tolerance as described described in in TS TS SR SR 3.0.2.

3.0.2. The Thelacklackof ofaasimilar similar tolerance tolerance applied applied toto OM Code OM Code testing testing places places an unusual hardshiphardship on on the the plant plant to adequately adequately schedule work schedule work taskstaskswithout withoutoperational operationalflexibility.

flexibility.

Thus, just as with TS required with TS required surveillance surveillance testing, testing, somesome tolerance tolerance is needed to to allow adjusting allow adjusting OM OM Code Code testing testing intervals intervals toto suit suit the the plant conditions conditions and other maintenance and maintenance and testing testing activities.

activities. This Thisassures assuresoperational operationalflexibility flexibility when when scheduling surveillance tests that that minimize minimize the conflicts between the need conflicts between need toto complete the surveillance surveillance and and plant plant conditions.

conditions.

5. Proposed Alternative and Basis for Use Proposed Use ASME ASME OM OMCodeCodeestablishes establishes component component test test frequencies that are based based either either on elapsed timetime periods (e.g., quarterly, 2 years, etc.) or on the occurrence of of conditions or plant conditions or events events (e.g., cold shutdown, refueling outage, upon detection refueling outage, of a sample sample failure, failure, following maintenance, etc.).

following maintenance, etc.).

a. Components whose test frequencies are based based on on elapsed elapsedtime time periods periods shall be tested tested atatthe thefrequencies frequenciesspecified specifiedininASME ASMEOM OM Code CodeSection Section IST with 1ST with aa specified specified timetime period period between tests testsas asshown shownininthe thefollowing following table.

Specified Time Period Between Tests Frequency (all values (all values are are 'not toto exceed'; no minimum periods are specified) specified)

Quarterly 92 days (or every 3 months)

Semiannually 184 days (or every 6 months)

Annually 366 days (or every year) x calendar years x Years where 'x' 'x' is is aa whole wholenumber numberofofyears years>_ ~2

b. The specified
b. specified time period period between tests may may be be extended extendedas asfollows:

follows:

i.i. For periods periods specified specified as as less than 2 years, years, the the period period maymay bebe extended by by up to 25% for any given given test.

test. This This is is consistent consistentwith with QCNPS TS Section 5.5.6, 5.5.6, "Inservice "Inservice Testing Program."

Program."

ii. Period ii. Period extensions may also be applied to accelerated test test frequencies (e.g.,

(e.g., pumps pumpsin in Alert Alert Range).

Range).

Page 4 of 24

10 CFR 50.55a RequestRequest Number Number RV-01 RV-01 Page 4 of4 of 4 periods specified iii. For periods specified as as greater than or equal to 2 years, the the period may be extended period extended by by up up toto 66 months months forfor any given test.

c. Components whose test frequencies are based based onon the occurrence occurrence of of plant conditions or events (e.g., cold shutdown, refueling refueling outage, uponupon detection of a sample failure, following maintenance,maintenance, etc.)etc.) may may not not have have their period between tests extended except except as as allowed allowed by by the the ASME ASME OM OM Code.

Duration6. of Duration Proposed of Proposed Alternative The proposed alternative will be utilizedutilized for for the entire entire Fifth Fifth 120 120 month month Interval Interval beginning February February 18,18, 2013.

2013.

Precedent

7. Precedent Generic relief has not been specifically relief has specifically granted to apply apply a tolerance band to to the the ASME ASME OMOMcode code required required test test frequencies.

frequencies. The The NRCNRC has haspreviously previously accepted accepted the application application of of TS TS SR SR 3.0.2 3.0.2 tolerances tolerances to to selected OM OM CodeCode frequencies frequencies as denoted in in TS 5.5.6.

The prior NRC NRC acceptance acceptance of of the the practice practice of of applying applying TS tolerances tolerances toto ASME ASME OM code OM code required required test frequencies providesprovides equivalent precedence precedencefor for accepting accepting and approving approving this this relief relief request.

References

8. References
a. Section 1.4 -- Frequency Quad Cities TS Section Frequency
b. Quad Cities TS Section 5.5.6 - Inservice InserviceTesting Testing Program Program
c. Quad Cities TS SR 3.0.2 - SpecifiedSpecified Frequency Frequency(25% (25%Grace GracePeriod)

Period)

d. Quad Cities TS SR 3.0.4 -- Mode Mode Entry Entry Requirements Requirements Page 5 of 24

10 CFR SO.SSa 50.55a Request NumberNumber RV-02RV-02 Relief Requested In Accordance with 10 CFR 50.55a(a)(3)(i)

SO.SSa(a)(3)(i)

Alternate Provides Acceptable Level Level of of Quality Quality and and Safety Safety Page 1 of ofS5

1. ASME Code Components Affected Affected All Quad Cities Nuclear Power Station (QCNPS) (QCNPS) motor-operated motor-operatedvalves valves(MOVs) (MOVs) scoped into into the Inservice Inservice Testing Program that that are are also alsoincluded included in in the the scope scopeof of the QCNPS QCNPS MOV MOV Testing Program.Program.

Applicable2.Code Applicable Edition Code and EditionAddenda and Addenda ASME OM Code 2004 Edition through 2006 2006 Addenda Addenda Applicable3. Code Requirement Applicable Code Requirement ISTC-31 00 requires ISTC-3100 requires that any any MOV that has undergone MOV that undergone maintenance maintenancethat that could could affect its performance performance after afterthe the preservice preservice test be tested tested in in accordance accordancewith with I STC-331 0.

ISTC-3310.

ISTC-331 0requires ISTC-3310 requiresthat thataa new new reference reference value be determined determined or orthe theprevious previous reference value be reconfirmed reconfirmed by an inservice test test after after aa MOV MOV has been been replaced, repaired, or has undergone undergone maintenance maintenancethat thatcould could affect affect thethe valve's valve's performance.

ISTC-3510 requires that active ISTC-3510 active Category CategoryA A and and BB MOVs MOVs be be exercised exercisednominally nominally every 3 months.

ISTC-3521 requires that active Category ISTC-3521 CategoryA A and and BBMOVs MOVs be be exercised exercisedduringduringcold cold shutdowns if if itit is is not not practicable practicable to to exercise exercise the valves valves at at power, power, or orthatthatactive active Category A and B B MOVs be exercised exercised during during refueling refueling outages outagesififitit isis not not practicable to exercise the valves during during cold shutdowns.

ISTC-3700 requires that valves with ISTC-3700 with remote position indicators be observedobserved locally at locally at least least once every 2 years years to to verify verify that valve operation is accurately accurately indicated.

ISTC-5120 requires that MOVs be stroke-time tested when exercised in accordance with ISTC-3510.ISTC-3510.

Page 6 of 24

10 CFR 10 CFR 50.55a 50.55a Request Number RV-02 Page 2 of 5 Page 4.forReason Reason4. Requestfor Request In accordance In accordance with with 10 CFR 50.55a(a)(3)(i),

SO.SSa(a)(3)(i), relief is requested requested fromfrom thethe requirements of the OM requirements Code, Subsection ISTC-3000, OM Code, ISTC-3000, excluding excluding ISTC-3600, "Leak Testing "Leak Testing Requirements,"

Requirements," and the requirements requirements of of Subsection Subsection ISTC-5120.

ISTC-S120.

The proposed alternative alternative provides an acceptable acceptablelevel level of of quality quality and safety.

QCNPS proposes to adopt the requirements QCNPS requirements of of Code Case Case OMN-1 OMN-1 (as delineated in in the 2004 2004 ASME ASME OM Code through through 2006 2006 Addenda)

Addenda)in in lieu lieu of of the the performance of stroke time testing and position indication testing as described indication testing described by by ASME OM ASME OMISTCISTC2004 2004through through20062006addenda.

addenda. The Theprovision provision toto allow allow for motor control center control center testing, testing, as contained in in Section 6.1 of Code Case Case OMN-1, OMN-1, is excluded from this request.

from this Proposed

5. Alternative Proposed Alternative and and Basis for Use The QCNPS MOV testing program MOV testing program was developed developed as asaaresult resultofofNRC NRCGeneric Generic Letter (GL)

Letter (GL) 89-10, 89-10, "Safety "Safety Related Related Motor Motor Operated Operated ValveValve Testing and Surveillance," and and GL GL 96-05, 96-0S,"Periodic "PeriodicVerification Verification of of Design Design Basis BasisCapability Capabilityofof Safety Related RelatedMotor MotorOperated OperatedValves,"

Valves,"utilizing utilizingTopical TopicalReport ReportMPR-1 MPR-1807, 807, "Joint BWR, "Joint BWR,Westinghouse Westinghouse and Combustion Engineering Owners' Group Program on on Motor-Operated Motor-OperatedValve Valve(MOV)

(MOV) Periodic PeriodicVerification,"

Verification,* Revision Revision 2. 2.

QCNPS isis currently QCNPS currently utilizing utilizing MPR-2524-A, MPR-2S24-A, "Joint Owners' Owners' GroupGroup(JOG)

(JOG)Motor Motor Operated Valve Operated Valve Periodic Periodic Verification Verification Program Summary," (November 2006) as as guidance guidance forfor the MOVMOV Program. The Theadoption adoptionofofOMN-1OMN-1 will will consolidate testing testing between thethe station's station'sIST 1STandandMOV MOV Programs.

Programs.

Section 4.2.5 4.2.S "Alternatives "Alternatives to to Stroke-Testing,"

Stroke-Testing," of of NUREG-1482, NUREG-1482, "Guidance"Guidancefor for Testing at Nuclear Power Inservice Testing Power Plants,"

Plants," Revision Revision 1, 1, states states in part that as an an alternative to MOV stroke-time testing, MOV stroke-time testing, AS ASME-developed ME-developed Code Case CaseOMN-1,OMN-1 ,

which provides periodic which provides periodic exercising exercising and and diagnostic diagnostic testing testing for foruse use inin assessing assessing the the operational readiness of of MOVs, MOVs, may may be be used.

used. Section Section 4.2.5 4.2.S recommends recommendsthat that licensees licensees implement implement ASME ASME Code Case CaseOMN-1OMN-1 as as ananalternative alternativeto tothetheMOV MOV stroke-time testing.

testing. TheThe periodic periodic exercising exercising and and diagnostic diagnostic testing testing requirements requirements in OMN-1 providean OMN-1 provide an improved improvedmethod methodfor forassessing assessing the operational operational readiness readiness of MOVs.

MOVs.

Code Case CaseOMN-1 OMN-1 was was revised revised inin the the 2006 2006Addenda Addendatotothe theASME ASME OM OM Code Code--

2004. Most Mostof of the the revisions revisions areareenhancements enhancementssuch suchasas clarification clarificationofofvalve valve remote position position indication indication requirements requirements and andball/plug/diaphragm ball/plug/diaphragmvalve valvetesttest requirements, and and the theexpansion expansionofofrisk-informed risk-informed provisions.

provisions. However, However,there there was was one one significant significant revision revision in Section 6.1, "Acceptance Criteria," that states Criteria," that states that that motor control center (MCC) acceptable ifif correlation with (MCC) testing is acceptable with testing at the MOV MOV hashas been established.

established.MCC MCCdiagnostic diagnostictesting testingwaswasnot notspecifically specifically addressed addressedininthe theoriginal originalversion versionofofOMN-1.

OMN-1. Historically, Historically, diagnostic diagnostictesting testingof of MOVs MOVs has been conducted conducted usingusing at-the-valve at-the-valve tests. AlthoughAlthough there there may maybe be potential benefits of testing conducted at at the the MCC, MCC, the the ASME ASME OM OM CodeCode does does notnot Page 77 of Page of 24 24

10 CFR 10 CFR SO.SSa 50.55a Request Number RV-02 Page 33 of S Page 5 address any address any method method forfor the correlation correlation of of MCC-based MCC-based measurements measurements to diagnostictest diagnostic test measurements measurements conducted conducted at-the-valve.

at-the-valve. For For these these reasons, QCNPS has has excluded excluded the theprovision provisionfor for MCC MCC testing testing from from this this relief relief request.

request.

Therefore, the Therefore, the MCC MCC testtest method method will willnotnotbe beused used asas an acceptance acceptancecriterion criterion to to determine the operational readiness of readiness of MOVs.MOVs.

following positions describe how QCNPS interprets The following interprets andand complies complies with with the the various requirements of OMN-1 various OMN-1 (ASME OMb Code-2006).

1. OMN-1,
1. OMN-1, Section 3.1 3.1 allows for the use of testing that was conducted prior prior toto the implementation of OMN-1 OMN-1 if it meets the requirements requirements of of the the Code Code Case.

Case.

QCNPS intends to utilize the testing credited under under its its GL GL 89-10/96-05 89-10/96-05 responses to responses to satisfy satisfy the the requirement requirement for for aa one-time one-time testtesttoto verify verify the capacity of each of each individual individual or or group group of of MOV's MOV'ssafety-related safety-related design design basis requirements.

2. OMN-1,
2. OMN-1, Section 3.2 requires that each MOV be tested during during thethe preservice preservice implementing inservice test period or before implementing inservice inspection.

inspection. QCNPSQCNPS intends intends to utilize the utilize the testing testing credited under its GL 96-05 response to satisfy this requirement.

OMN-1,Section

3. OMN-1, Section 3.3(b) 3.3(b)states states that inservice tests shall be conducted conducted in in the the as-found condition, and activities shall not be conducted conducted ifif they mightmight invalidate the invalidate the as-found as-found condition condition for forinservice inservicetesting.

testing. QCNPS maintenance maintenance activities that would activities that would affect affect the the as-found as-found condition condition of of the the valve, valve, such such as motor motor operator preventive preventive maintenance maintenanceor orstem stemlubrication, lubrication, arearetypically typically scheduled scheduled to occur occur inin conjunction conjunction with with the the performance performanceofofthe theMOV MOVPeriodic PeriodicVerification Verification Testing, and are are performed performed afterafter as-found testing.

testing. Any Anyother otheractivities activities that that could affect the could affect the as-found test results are are not not performed performed untiluntil after the as-found testing testing has been been conducted.

conducted.

4. OMN-1 Section 3.3(c) requires the OMN-1 Section the inservice inservice testtestprogram programtotoinclude includeaamix mixof of static and dynamic MOV performance testing.

MOV performance testing. QCNPS QCNPS has hasutilized utilized the JOG JOG program's program's mix mix of static andand dynamic dynamic MOV MOV performance performance testing testing (i.e.,

(Le., MPR-MPR-2524-A) to develop its current MOV testing program. Additionally, MOV testing Additionally, QCNPS will continue to will continue to utilize utilizethe the existing existing engineering engineering standards, standards, which which areare consistent consistent withwith the JOGJOG standards, standards,totojustify justifyany anychanges changestotothe themix mixofof required MOV performance testing. The use MOV performance use ofof such such an anevaluation evaluationwill will serve to ensure ensure QCNPS QCNPS continues continuesto tomeet meetthisthisrequirement.

requirement.

5. OMN-1, Section 3.3(e) requires that Remote OMN-1, Section Remote Position Position Indication Indication shall be be verified locally during verified locally during inservice inservice testing testing or maintenance maintenance activities.

activities. QCNPS QCNPSwill will continue to to verify verify the operability of of each each MOV's position position indication indication system system as as part of each MOV's MOV's diagnostic test. InInaddition, addition,thethefunction function of of each eachMOV's MOV's position indication indication system system will will be verified verified during the performance performanceof of maintenance maintenanceactivities activities affecting affecting remote remoteposition position indication.

indication.

Page 88 of Page of 24 24

50.55a Request Number RV-02 10 CFR SO.SSa Page 4 of 5S OMN-1, Section

6. OMN-1, Section 3.3.1 3.3.1 (b)

(b) requires requires MOV MOVinservice inservicetesting testing toto be be conducted conducted every 2 refueling cycles or or 3 years years(whichever (whicheverisislonger),

longer), ifif insufficient data insufficient data exists to determine inservice test frequencies. QCNPS QCNPShas hassufficient sufficientMOVMOV testing data data to to justify its current justify its current testing testing frequencies, frequencies, and therefore meets meets this this requirement. IfIf inin the the future, future, modification modification or or replacement replacement results in in the necessity to re-baseline necessity re-baseline aavalvevalve oror group group of of valves, thethe requirements requirements of of OMN-1, Section OMN-1, Section 3.3.1(b) 3.3.1 (b) or or 3.7.2.2(c) 3.7.2.2(c) asasapplicable, applicable,will will be befollowed.

followed.

OMN-1, Section

7. OMN-1, Section 6.4.4 requires requires that that calculations calculations for for determining determining the the MOV's MOV's functional margin functional margin are are evaluated to to account account for for potential potential performance-related performance-related degradation. The TheQCNPS QCNPSMOV MOVProgram, Program,including including Exelon's Exelon's MotorMotor Operated Operated Valve Valve Design Database Database(MIDAS)

(MIDAS) Software (or similar updated product), product), takes takes into account into account performance-related degradation, degradation, to to calculate calculatevalvevalve margin.

margin.

8. The provision of motor control control center testing contained contained in in Section Section 6.1 6.1

("Acceptance Criteria")

Criteria") is excluded from this request request("i.e.,

("Le., Motor Motor control center testing isis acceptable center acceptableifif correlation correlation with with testing at the MOV MOV has been been established").

6. Proposed Duration of Duration of ProposedAlternative Alternative The proposed alternative identified in in this this relief relief request shall be utilized utilized during during the Fifth 10-Year 10-Year IST1ST Interval Interval beginning February February 18, 18, 2013.

Precedent7. Precedent Similar relief Similar relief has has been approved approved for for LaSalle LaSalle County County Station, Station,Units Units 11andand2,2,Relief Relief Request RV-02, Request RV-02, in NRC Safety in NRC Safety Evaluation Evaluationdateddated September September 26, 2007 (Reference 1);

(Reference 1); Peach PeachBottom BottomAtomic Atomic Power Power Station, Station, Units Units 22andand3,3,Relief Relief Request GVRR-1, Request GVRR-1, in NRC NRC Safety Evaluation dated September Evaluation dated September3, 3, 2008 2008 (Reference 2);

(Reference 2); and and Clinton Clinton Power Power Station, Station, Unit Unit 11 Relief Relief Request RequestNo. No.2201 2201 inin NRC Safety NRC Safety Evaluation Evaluation dateddated June 10, 2010 (Reference (Reference 3). 3).

References

8. References
1. from R.

Letter from R. Gibbs (U.S. NRC) to C. M. M. Crane (Exelon (Exelon Generation),

Generation),

"Relief Requests "Relief Requests for the LaSalle County County Station, Station, Units Units 11 andand2, 2,Third Third 10 Year Pump and and Valve Valve Inservice Inservice Testing Testing Program Program(TAC (TAC Nos.Nos. MD5988, MD5988, MD5989, MD5992, MD5989, MD5992, MD5993, MD5993, MD5994, MD5994, MD5995),"

MD5995),"dated dated September September 26, 26, 2007

2. Letter from H. Chernoff (U.S. NRC) NRC) toto C.

C. G.

G. Pardee Pardee (Exelon (Exelon Generation),

Generation),

"Peach Bottom Atomic Power Station, Units 2 and 3 - Requests Requests for for Relief Relief Associated with the Fourth Fourth Inservice Inservice Testing Testing Interval Interval (TAC (TACNos. Nos. MD7461 MD7461 and MD7462)," dated SeptemberSeptember 3, 2008 3,2008 Page 9 of 24

50.55a Request 10 CFR 50.55a Request Number Number RV-02 RV-02 Page 5 of of 55

3. Letter from from S. Campbell (U.S. NRC)NRC) to M.M. Pacilio (Exelon Generation),

"Clinton Power Station, "Clinton Power Station, Unit Unit No.1 No. 1 -- Safety Evaluation of Relief Request Relief Request Nos. 2201, 2202 2202 and and3201, 3201,forforthe theThird Third 10-Year 10-YearInservice InserviceTesting Testing Interval," dated June Interval," dated June 10, 2010 10,2010 Page 10 of 24

10 CFR 50.55a Request Number RV-03 Relief Requested In Accordance with 10 CFR 50.55a(a)(3)(i)

In 50.55a(a)(3)(i)

Alternate Provides Acceptable Level of Quality and Safety Page 1 of 3 11 ASME Code Component(s) Affected Component Number System Code Class Category Cateqory 11(2)-1001-047-MO (2)-1001-047-MO RHR 11 A 11(2)-1001-050-MO (2)-1 001-050-MO RHR 11 A 1 1(2)-1001-029A-MO (2)-1 001-029A-MO RHR 11 A 1 1(2)-1001-029B-MO (2)-1 001-0298-MO RHR 11 A 1 1(2)-1001-068A (2)-1 001-068A RHR 11 AlC A/C 11(2)-1001-0688 (2)-1 001-0688 RHR 11 AlC A/C 1(2)-1402-009A 1(2)-1402-009A CS 11 AlC A/C 11(2)-1402-0098 (2)-1402-0098 CS 11 AlC A/C 11(2)-1402-025A-MO (2)-1402-025A-MO CS 1 1 A 11(2)-1402-025B-MO (2)-1402-0258-MO CS 11 A

2 Applicable Code Edition and Addenda

ASME OM Code 2004 Edition Edition through 2006 Addenda

3 Applicable Code Requirement

ISTC-3630 (Leakage Rate for Other Than Containment Isolation ISTC-3630 Isolation Valves) states Valves) states that Category A valvesvalves with with aa leakage leakage requirement not based based on on an an Owner's Owner's Appendix JJ program, 10 CFR 50, Appendix program, shallshall be be tested to verify theirseat verify their seat leakages areare within acceptable limits. Valve closure within acceptable limits. Valve closure before before seat leakage testing shall leakage testing shall be by be by using the valve valve operator operator with with no no additional additional closing closing force applied.

applied.

ISTC-3630(a) (Frequency)Tests ISTC-3630(a) (Frequency) Tests shall shall bebe conducted conducted at at least once every 2 years.

4 Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and Standards", paragraph (a)(3)(i), relief is requested requested fromfrom the the requirement requirement of ASME ASME OM OMCodeCode ISTC-3630(a).

ISTC-3630(a). The The basis ofof the relief relief request is that the proposed alternative alternative would provide an would provide an acceptable acceptable level of quality and safety.

safety.

ISTC-3630 requires that leakage leakage raterate testing testingfor for Pressure PressureIsolation IsolationValves Valves(PIVs)

(PIVs) be performed performed at least least once every 2 years. PIVs are not specifically includedin once every 2 years. PIVs are not specifically included in the scope scope forfor performance-based performance-basedtesting testing as asprovided providedforfor inin 10 10 CFR CFR 5050 Appendix J Option B. 8. While While the the motor-operated motor-operatedPIVs PIVsaffected affectedby bythis thisRelief Relief Request Request areare also alsoContainment Containment Isolation Isolation Valves Valves (CIVs) and tested in accordance (CIVs) and accordance with Appendix J Program, the with the Appendix the check check valve valve PIVs PIVs are arenotnotCIVsCIVs and andnot notwithin within Appendix J scope. The the Appendix Theconcept conceptbehind behindthetheOption OptionB8alternative alternativeforfor Page 11 of 24

10 CFR 10 CFR 50.55a 50.55a Request Request Number Number RV-03 RV-03 Page 22 of3 Page of 3 containment isolation containment isolationvalves valves isis that thatlicensees licensees should be allowed allowed to adopt cost effective methods effective methods for for complying complying with with regulatory regulatory requirements. Additionally, Additionally, NEI 94-01, NEI 94- 01, "Industry Guideline for "Industry Guideline forImplementing Implementing Performance-Based Performance -Based Option Option of 10 CFR Part 10 CFR Part 50, Appendix J," describes the risk-informed basis for J," describes the risk-informed basis for the extended extended test intervals under Option test Option B. B. That That justification justification shows shows thatthat for valves valves which which havehave demonstrated good performance demonstrated performance by by passing passingtheir their leakleak rate rate tests testsfor for two two consecutive cycles, consecutive cycles,further further failures failures appear appear to to bebe governed governedby bythetherandom randomfailurefailure rate of rate ofthe thecomponent.

component. NEI 94- 01 also presents the NEI 94-01 the results results of of a comprehensive comprehensive risk analysis, risk analysis, including including the statement statementthat that "the "the risk risk impact associated associatedwith with increasing [leak rate] test intervals increasing intervals is is negligible negligible(less (lessthan than0.1 0.1% %ofoftotal totalrisk)."

risk)."

The valves valves identified identified in this relief request are all all in in water applications. The PIV testing is performed performed with water pressurized with water pressurized to pressurespressureslower lowerthan thanfunction function maximumpressure maximum pressure differential.

differential. However, However, the the observed observed leakage leakage isis adjusted adjusted to to the function maximum pressure differential function maximum value in differential value in accordance accordance with with ISTC-3630(b)(4). This relief relief request request is intended to provide provide for a performance-based performance-based scheduling of PIV PIV tests tests at at QCNPS.

QCNPS. The The reason reasonfor for requesting requesting this this relief relief is dose dose reduction / ALARA. Recent historical historical data was was usedusedtotoidentify identifythat that PIV PIV testing alone eacheach refuel refuel outage outageincurs incurs aatotal total dose doseofofapproximately approximately 600 600milliRem.

milliRem.

Assuming all PIVs remain all of the PIVs remain classified classified as good performers performers the extended test test intervals would intervals would provide providefor foraasavings savings of of approximately approximately 1.2 1.2 Rem over a 4-1/2 4-1/2 year year period.

NUREG 0933, NUREG 0933, "Resolution "Resolution of of Generic Generic Safety Issues," Issues," Issue Issue105 105(Interfacing (Interfacing Systems Systems LOCA LOCA at LWRs) LWRs) discussed discussed the need need for for PIV PIV leak rate testing based based primarily primarily on on three three pre-1980 pre-1980 historical historical failures failures of of applicable applicable valves valvesindustry-wide.

industry-wide.

These These failures failures all all involved human errors in involved human in either operations or maintenance.

None of thesethese failures involved inservice equipment involved inservice equipment degradation.

degradation. The The performance of PIV PIV leak leak rate ratetesting testing provides providesassurance assurance of acceptable seat seat leakage leakage with with the valve in a closed closed condition.

condition. Typical Typical PIV PIV testing does doesnot notidentify identify functional problems problems whichwhich maymay inhibit inhibit the valves valves ability ability to re-position re-position from open open to closed. For Forcheck checkvalves, valves,suchsuchfunctional functionaltesting testingisisaccomplished accomplishedper perASME ASME OM OM Code ISTC-3522 and ISTC-3520. Power-operated Power-operatedvalves valvesare areroutinely routinelyfullfull tested per stroke tested perASME ASME OM OM Code Code to to ensure ensuretheir theirfunctional functional capabilities.

capabilities. At At QCNPS, these these functional functional tests tests for for motor motor operated operated PIVs PIVs areare performed performed on on aa quarterly frequency. The Thefunctional functionaltestingtestingofofthe thePIV PIVcheck checkvalvesvalveswill will be be monitored through through aa Condition Condition Monitoring Monitoring Plan Plan in in accordance accordancewith withISTC-5222, ISTC-5222, "Condition-Monitoring "Condition-Monitoring Program," and and Mandatory MandatoryAppendix AppendixII, II,"Check "CheckValve Valve Condition Monitoring MonitoringProgram."

Program." Performance of the separate separate22year yearPIV PIVleak leak rate testing testing does doesnot notcontribute contributeany anyadditional additional assurance assuranceofoffunctional functionalcapability; capability; itit only only determines the seat seat tightness tightness of of the the closed closed valves.

valves.

55 Proposed Proposed Alternative Alternative and and Basis Basisfor forUseUse QCNPS QCNPS proposes proposestotoperformperformPIV PIVtesting testingatatintervals intervalsranging rangingfrom fromeveryeveryrefuel refueltoto every every third refuel. The specific interval for each valve would be a functionof third refuel. The specific interval for each valve would be a function ofits its performance performance and andwould would be beestablished establishedininaamanner mannerconsistent consistent withwiththetheCIVCIV Page Page 12 12 of of 24 24

10 CFR 50.55aSO.SSa Request Request Number Number RV-03 RV-03 Page 3 of of3 3 process under process under10 10CFRCFR50 AppendixJ,J,Option 50Appendix OptionB. B. InInfact, fact,all allof ofthe theMOVs MOVs listed listed are also also classified classified as asCIVs CIVs and and are areleakleakrate ratetested testedwith withair airat atintervals intervals determined by by 10 10 CFR CFR 50 Appendix JJ Option 50 Appendix Option B B (hereto referred referred to as as Option Option B).B).

The MOVMOV PIVPIV testing testing would would be be scheduled scheduled to to coincide coincide withwith the CIVCIV testing, testing, at whatever interval whatever interval required required for for Option Option B. B. AAconservative conservativecontrol controlwillwill be be established established suchsuchthat thatififany anyvalvevalvefails fails either eithertheir theirCIVCIV test test or or their their PIV PIV test, thethe test interval test interval for both tests tests will will be reduced reduced consistent consistentwith with Appendix Appendix J, J, Option Option BB requirements until good performance is reestablished.

until good The primary basisbasis for for this relief relief request request is is the the historically historically good good performance performanceof of the PIVs.

PIVs. TheTheonly only recorded recorded seat seatleakage leakagefailures failuresofofPIVsPIVsatatQCNPS QCNPSwere wereininfact fact determined to be be aa result result ofof the the test test methodology methodology and and not not due dueto to any anyphysical physical condition condition of the valves.

Additional basis for for this this relief relief request request is is provided provided below:below:

  • Low likelihood of valve mispositioning mispositioning during during power power operations operations (procedures, interlocks).
  • Air test vs. water test -- degrading degrading seat seat conditions conditions tend tend toto be beidentified identified sooner with air testing.
  • Relief valves in Relief in the lowlow pressure pressure (LP) (LP) piping these relief piping - these relief valves valves maymaynotnot provide Inner-System Inner-System Loss Loss of of Coolant Coolant Accident Accident (ISLOCA) mitigation for inadvertent PIV PIV mispositioning mispositioning but but their their relief reliefcapacity capacity can can accommodate accommodate conservative PIV seat leakage rates.

PIV seat rates.

  • Alarms that identify identify highhigh pressure pressure (HP) to LP LP leakage leakage - Operators are highly highly trained trainedto to recognize recognize symptoms of a present present or incipient incipient ISLOCA ISLOCA and to take appropriate appropriate actions.

6 Duration of Proposed AlternativeAlternative The proposed alternative will will bebe utilized utilized forfor the the entire entire Fifth Fifth 120 120month monthInterval Interval beginning February February 18, 18, 2013.

2013.

7 Precedents This relief relief request request waswas approved approvedfor for Fermi Fermi Power PowerStation Stationforfor the theThird Third 120120 month month Interval. Letter fromfrom R. R. Pascarelli (U.S. NRC) NRC) to J. Davis Davis (Detroit (Detroit Edison),

"Fermi-2 Evaluation "Fermi-2 Evaluation of of In-Service In-Service Testing Testing Program Relief Relief Requests RequestsVRR-01 VRR-011, 1, VRR-012,2,and VRR-01 and VRR-013,"

VRR-01 3,"dated datedSeptember September 28,2010.

28, 2010.

Page 13 of 24

10 CFR 50.55a Request Number RV-04 Relief Requested In Accordance with 10 CFR 50.55a(f)(5)(iii)

In Inservice Testing Impracticality Page 1 of 3 ASME Code 1. Components ASME Code Components Affected Affected Component Number System Code Class Cateqory Category 1-2301-032-SO 1-2301-032-S0 HPCI 2 B 2-2301-032-SO 2-2301-032-S0 HPCI 2 B B

Applicable2.Code Edition Applicable Codeand EditionAddenda and Addenda ASME OM Code 2004 Edition Edition through 2006 2006 Addenda Addenda Applicable3. Code Requirement Applicable Code Requirement ISTC-5150, Solenoid-Operated Solenoid-Operated Valves Valves Impracticality

4. of Compliance Impracticality of Compliance Pursuant to 10 Pursuant 10 CFR CFR 50.55a, 50.55a, "Codes "Codesand andstandards,"

standards,"paragraph paragraph (f)(5)(iii),

(f)(5)(iii),relief relief is is requested from requested from the requirement of ASME ASME OM OMCodeCode ISTC-5150.

ISTC-5150. The basis of the relief request relief request is that the Code Code requirement requirement isis impractical.

impractical.

These solenoid These solenoid valves function function as as a backup to the exhaust exhaust lineline drain pot steam During normal trap. During normal operation operation of of the the HPCI turbine using high quality steam, the HPCI turbine the from the drain path from the drain drain potpot toto the the torus torus via via the the steam steam trap is adequate adequateto to condensate from remove condensate from the turbine turbine exhaust exhaust line.

line. However, However,duringduring HPCIHPCI turbine turbine operation with low low pressure pressure and andlow low quality quality steam steam (e.g.,

(e.g.,during duringcertain certainHPCI HPCI surveillance tests), condensate condensatecollects collectsin in the the drain drain pot pot faster fasterthan thanitit can can be be drained through the trap. Under Underthese theseconditions, conditions,solenoid solenoidvalve valve1(2)-2301-032 1(2)-2301-032 opens opens automatically automatically to drain drain to to the the gland seal condenser condenserupon uponreceipt receiptof of aasignal signal from from a drain pot level switch when the drain drain pot pot level level reaches reachesthe thehigh-level high-level alarm set set point.

point. AAhigh high level level condition condition alarms alarms aa control control room room annunciator.

annunciator.

These These valves valves arearenot notequipped equippedwith with hand handswitches switchesor orposition position indicators indicators and and thethe valves are are totally totally enclosed, enclosed, so sovalve valve position position cannot cannotbe beverified verified by by direct direct observation. Therefore, Therefore, itit is is impractical impractical to exercise and stroke stroke time time these thesevalves valves in accordance accordance with with Code requirements.

Valve actuation may may bebeindirectly indirectly verified verified by removing removing the the HPCI HPCI system systemfrom from service, service, filling the drain pot with filling the with water until the high level alarm is received, until the received, and and observing that the high high level level alarm clears.

clears. ItItisisimpractical impractical to to assign assignaamaximum maximum limiting stroketime limiting stroke timetotothese these valves valves using this test method because becausethe thetime timefor for the alarm alarm toto clear clear would would depend dependprimarily primarily onon variables variables such suchasasthe therate rateofoffilling filling and the level level of the drain pot when when the filling fillingisissecured.

secured. The steamsteam line line drain drain pot Page 14 14 of of 24 24

10 CFR 50.55a Request Request NumberNumber RV-04RV-04 Page 2 of of3 3 is not equipped equipped with with direct level indication; therefore, the time required for the indication; therefore, alarm to clear clear may mayvary varysignificantly.

significantly.

Failure of Failure of these these valves valves toto perform perform theirtheir safety safety function function would be indicated indicated by by aa drain pot highhigh level level alarm.

alarm. Additionally, condensate entrapped in the steam Additionally, condensate steam would cause significant would cause fluctuations ininexhaust significant fluctuations exhaust steam steam header header pressure.

pressure.

Burden Caused

5. Burden ByCaused Compliance By Compliance Compliance with with the quarterly exercising and stroke stroke timing timing requirements requirementsof ofthe the Code would require either system modifications modifications to replace these thesevalves valveswith with ones of ones of testable design, design, or or to purchase purchase non-intrusive non-intrusive test equipment and develop develop new test methods and procedures.

Proposed 6. Alternative Proposed Alternative and Basis for Use Use A functional verification A functional verificationtest test isis conducted conducted on the the drain drain pot potlevel level limit limit switches switches and and the associated associated control control room room annunciators at least least once once every every 92 92 days.

days. Valve Valve actuation will be indirectly will be verified by indirectly verified by removing removing the the HPCI HPCI system system from service, filling the drain filling the drain pot pot with with water water until untilthe the high high level level alarm alarm isis received, andand observing observing a positive draining of of the the HPCI HPCI draindrain potpot asas indicated indicated by a level increase in level increase in gland gland seal condenser condenserand andthe thehigh high level level alarm alarm clears.

The following The following provisions provisions of ISTC-5153 ISTC-5153,, Stroke Test Test Corrective Corrective Action Action still still apply:

apply:

  • If a valve fails to exhibit exhibit the the required changechange of of obturator obturator position, position, the the valve shall be immediately declared inoperable. inoperable.
  • Valves Valves declared inoperable may be repaired, replaced, or the data may may be analyzed to determine determine the the cause causeof ofthe thedeviation deviation and andthethevalve valveshown shown to be operating acceptably.
  • Valve operability based upon upon analysis shall shall have thethe results results of of the analysis recorded recorded in in the record of tests (see (see ISTC-9120).

ISTC-9120).

  • Before returning Before returning aa repaired repaired or or replacement valve valve to to service, service, a test demonstrating satisfactory operation shall shall be be performed.

performed.

Duration of

7. Proposed Duration of Proposed AlternativeAlternative The proposed alternative will will bebe utilized utilized for for the the entire entire Fifth Fifth 120 120month monthInterval Interval beginning February 18, 18, 2013.

2013.

Page 15 of 24

10 CFR 50.55a SO.SSa Request Request Number Number RV-04 RV-04 Page 3 ofof33

8. Precedents This relief relief request was previously previously approved approved for for Quad Quad Cities Cities Nuclear NuclearPower Power Station Units Units 1 and and 22 for for the the Fourth Fourth 120 120month monthInterval Interval(Relief (Relief Request RequestRV-23A)

RV-23A) in in letter letterfrom from A.

A. Mendiola (U.S. NRC)NRC) to C. Crane Crane (Exelon (Exelon Generation),

Generation),"Quad "Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth 10-Year Inservice Testing Units and 2- Fourth 10-Year Inservice Testing Program Relief Relief Requests," dated dated February February20, 2004.

20,2004.

Page Page 16 of 24

CFR 50.55a 10 CFR SO.SSa Request Request Number Number RV-05 RV-OS Relief Requested Requested In Accordance Accordance with with 10 10 CFR CFR 50.55a(a)(3)(i)

SO.SSa(a)(3)(i)

Alternate Provides Acceptable Acceptable LevelLevel of of Quality Quality and and Safety Safety Page 1 of 4

1. ASME Code Component(s) AffectedAffected Nuclear Power Quad Cities Nuclear Station (QCNPS) Units Power Station Units 1 and 2, Main Main Steam Safety Safety Valves (MSSVs):

Valves Model: 3777Q; Manufacturer:

(MSSVs): Model: Dresser Manufacturer: Dresser Component Number Number System Code Class Category Cateqory 1-0203-004A 1-0203-004A Main Main Steam 1 1 C 1-0203-0048 1-0203-004B Main Main Steam 1 1 C 1-0203-004C 1-0203-004C Main Main Steam 1 1 C 1-0203-004D 1-0203-0040 Main Main Steam 1 1 C 1-0203-004E 1-0203-004E Main Steam Main 1 1 C 1-0203-004F 1-0203-004F Main Main Steam 1 1 C 1-0203-004G 1-0203-004G Main Steam Main 1 1 C 1-0203-004H Main Main Steam 1 1 C 2-0203-004A Main Steam Main Steam 1 1 C 2-0203-004B Main Steam Main Steam 1 1 C 2-0203-004C Main Steam Main Steam 1 1 C 2-0203-0040 2-0203-004D Main Steam Main Steam 1 1 C 2-0203-004E Main Steam Main Steam 1 1 C 2-0203-004F Main Steam Main Steam 1 1 C 2-0203-004G Main Steam Main Steam 1 1 C 2-0203-004H Main Steam Main Steam 1 1 C Applicable 2.Code Edition Applicable Codeand EditionAddenda and Addenda ASME OM Code 2004 Edition through 2006 Addenda Applicable 3. Code Requirement Applicable Code Requirement ASME OM ASME OM Code, Code, Appendix Appendix I,I, "Inservice "Inservice Testing Testing ofof Pressure Pressure Relief Relief Devices Devicesinin Light-Water Reactor Light-Water Reactor Nuclear Nuclear Power Plants," Section 1-1320, Frequencies, 1-1320, "Test Frequencies, Class 11 Pressure PressureRelief ReliefValves,"

Valves," paragraph paragraph(a),

(a),"5-Year Test Interval."

"5-YearTest Interval."

Page 17 of 24

10 CFR 50.55a Request Number Number RV-05 RV-05 Page 2 of of4 4

4. Reason for Request

50.55a(f)(4) directs 10 CFR 50.55a(f)(4) directs aa licensee to meet meet inservice inservice testing requirements requirements for for ASME ASME Code Code Class 11 valves valves set setforth forth in in the the ASME ASME OM OM Code and addenda. addenda.

QCNPS is committed to to the the 2004 2004Edition Edition through through 2006 2006Addenda Addendaofofthe theASME ASME OM Code.

OM Section ISTC-3200, "Inservice Testing," Testing," statesstates thatthat inservice inservice testing testing shall shall commence when commence when the thevalves valvesare arerequired requiredtotobe beoperable operabletotofulfill fulfill their their required required function(s). Section ISTC-5240, ISTC-5240, "Safety "Safety and and Relief Relief Valves,"

Valves," directs directs thatthat safety safety and relief relief valves meet meet the the inservice inservice testing testing requirements requirementsset setforth forthininAppendix Appendix II of the of the ASME ASME OM OM Code.

Code. Appendix Appendix I,I, Section Section I-1320(a) 1-1320(a) of of the the ASME ASME OM Code states that states that Class Class 11pressure pressurerelief relief valves valves shallshall be betested testedatatleast leastonce onceevery everyfivefive years, starting starting with initialelectric with initial electricpower powergeneration.

generation. This This section section also states states aa minimum of minimum of20 20 percent percent of of the the pressure pressure relief relief valves are are tested testedwithinwithin anyany 24 24 month interval interval and that the the test testinterval interval for for any any individual individual valve shall not exceed exceed five years.

five years. TheThe required required test ensuresensuresthat thatthe the MSSVs, MSSVs, which which are located on each of the of the main main steam lines between between the the reactor reactorvessel vesseland andthe thefirst firstisolation isolation valve valve withinthe within the drywell, drywell,will willopenopenatatthe thepressures pressuresassumed assumed in the safety analysis.

The Dresser Dresser Model Model 3777Q MSSVs have shown acceptable acceptabletest testhistory historyat at QCNPS as described described in in Section Section 55 below.

below.

The physical locations of the MSSVs cause causethem themto tointerfere interferewith with oneone another another during transport during transport of of the the valves valves in in and and out of of containment.

containment. In In order to create aa transport path, QCNPS elects elects toto remove, remove, test testandandrebuild rebuild at atleast leasthalf halfofof the the during each refueling subject valves during outage. This refueling outage. This ensures ensurescompliance compliancewith with the ASME ASME OM OMCodeCode requirements requirements for for testing testing Class 1 pressure pressurerelief relief valves valves within within a five-year interval.

To support thesethese replacements, replacements,four fourspare spareMSSVs MSSVsare arerequired requiredtotobe becertified certified prior to prior to the the refuel refuel outage outage during which which they they willwillbebeinstalled.

installed. TheseThese sparespareMSSVsMSSVs are certified tested immediately certified tested immediately after after refurbishment refurbishment and and placed placed into into stores.

stores. In In order to meet the 55 year year test-to-test test-to-test interval interval requirement, each each spare spareMSSV MSSV requires a second secondrecertification recertification test test just just before before aarefuelrefuel outage outagetotomitigate mitigatethe the valve spent in stores. Extending time the valve Extendingthe thetesting testinginterval interval to to 66 years yearswithwith aa grace period period ofof 6 months months to to coincide coincide with with a refueling outage (i.e., (Le., 6.5 years years total) total) would allow additional would allow additional time time for forthethe spare spare MSSVs to reside reside in in stores storesafteraftertheir their certification tests certification tests without an additional additional recertification recertification test test immediately immediately prior prior toto installation. This extension would reduce the the number numberof of recertification recertification test actuations of the sparespare MSSVsMSSVs and and limit limit thethe potential potential of of disc/seat disc/seat damage and and subsequent seat subsequent seat leakage leakage due due toto these theseadditional additional tests.

In accordance with In with 10 CFR 50.55a, "Codes "Codes and andstandards,"

standards,"paragraph paragraph(a)(3)(i),

(a)(3)(i),

EGC requests requestsrelief relief from from the the five five year yeartest testinterval intervalrequirements requirementsofofASME ASMEOM OM Code, Appendix I, Section 1-1320(a) 1-1320(a) for for thethe Dresser Dresser ModelModel 3777Q MSSVs at QCNPS Units Units 11 and and 2. 2. QCNPS QCNPS requests requeststhat thatthethetest testinterval interval be be increased increasedfrom from Page 18 of 24

10 CFR 50.55a Request Request NumberNumber RV-05 RV-05 Page 3 of of4 4 five years to six years five years withwith aa grace graceperiod periodof of66months monthstotocoincide coincidewith with aarefueling refueling outage (i.e.,

(Le., 6.5 6.5 years years total).

total). Compliance Compliancewith with the the applicable applicable requirements requirementsof of the the ASME OM ASME OMCode Code for forthese these MSSVs MSSVs results in in unnecessary recertification testing of unnecessary recertification of the MSSVs MSSVs just prior prior to to aa refuel refuel outage outage without withoutaa compensating compensating increase in in the level of quality or safety.

5. Proposed Alternative and Basis for Use QCNPS proposes proposes that that ASME ASME Class 11 pressure pressurereliefrelief valves valves (i.e.,(Le., Dresser DresserModel Model 3777Q MSSVs)

MSSVs) at at QCNPS QCNPS shall shall bebe tested tested at least once once every every 66 years years with with a grace period of grace period of 6 months months to to coincide coincide with with a refueling refueling outage (i.e., (Le., 6.5 years years total).

total).

A minimum A minimum of of 20%

20% of ofthe the pressure pressure reliefrelief valves valves willwill be tested tested within within any any 2424--

month month interval interval and and that that this this 20%

20% shallshall consist consist of of valves valves that that have have not not been tested tested during during the current 6 year interval (with (with aa 66 month month grace),

grace), ifif they they exist. The test exist. The test interval for interval for any any individual individualvalve valveshall shallnot notexceed exceed 6.5 years. This ThisAlternative Alternative isis consistent consistent withwith thethe alternative alternative provided providedin in ASME ASME Code Code Case CaseOMN-1 OMN-17, 7, "Alternative Rules "Alternative Rules for for Testing Testing ASME ASME Class Class 1 Pressure PressureRelief Relief/Safety

/SafetyValves,"

Valves,"

Section 1, 'Test Section 1, Test Frequencies, Class 1 Pressure Relief Class 1 Pressure Relief Valves," Valves," Paragraph (a)

(a)

"72-month Interval."

Interval."

1ST IST history for the Dresser Model Model 3777Q MSSVs at QCNPS from from May May 1997 1997 to to the present present indicate indicate goodgood performance performance in in that that almost all tested tested MSSVs MSSVs(i.e.,(Le., 77 MSSV tests) that that have have beenbeeninstalled installedinineither eitherQCNPS QCNPSUnit Unit11or orUnit Unit22forfor two two operating cycles operating cycles have successfully successfullypassed passedthe theASME ASMEOM OM CodeCode and and Technical Technical Specification (TS)

Specification (TS) as-found lift setpoint acceptance lift setpoint acceptance criteriacriteria within within plus or minus 3% (the historical historical testtest data indicates 11 of of 77 77tests testsdiddidnotnotremain remainwithinwithin the the as-left as-left tolerance of plus or or minus 33%;  %; however, it was found in in the negative, more more conservative, direction).

conservative, direction).

QCNPS utilizes utilizes an an ASME ASME OM Code-certified off-site vendor to perform as-found off-site vendor and as-left testing, inspection, inspection, and and refurbishment refurbishment of of the the MSSVs.

MSSVs. An AnEGCEGC--

approved and qualified qualified procedure is used used for for disassembly disassembly and and inspection inspection of of the the MSSVs. This procedure requires that each MSSV MSSVs. MSSV be be disassembled disassembled and inspected upon removal removal from from service, service, independent of the as-found test results. results.

The procedure identifies identifies the critical critical components components that that are are required required to to be inspected for wear for wear and defects, and the the critical critical dimensions that are required required to be be measured during the inspection.

measured during inspection. IfIf components componentsare arefound foundworn worn or or outside outsideof of the the specified tolerance(s), the components componentsare areeither eitherreworked reworkedto towithin within the the specified specified tolerances, or or replaced.

replaced. All All parts partsthat thatarearedefective, defective, outside-of-tolerance, outside-of-tolerance, and andall all reworked/replaced components components are are identified, identified, andand EGCEGC is is notified notified of these these components by the off-site vendor. The MSSV off-site vendor. MSSV is is then then re-assembled, re-assembled, the as-left test is performed, test is performed, and and thethe MSSV MSSV is is returned returned to to QCNPS.

QCNPS.

Based upon upon the the unnecessary unnecessaryrecertification recertification testing testingof of the theMSSVs MSSVsjust justprior prior toto aa refuel outage outage to to comply comply with with the the ASME ASME OM Code Code coupled coupledwith with historical historicalMSSV MSSV test results results for for Dresser Model Model 3777Q MSSVs, MSSVs, QCNPS QCNPS has concluded that that this alternative provides an acceptable acceptable level level of of quality quality and safety.

Page 19 of 24

10 CFR 50.55a Request Request Number Number RV-05 RV-05 Page 4 ofof4 4

6. Proposed Duration of Duration of Proposed AlternativeAlternative The proposed alternative will be be utilized utilized for for the the entire entire Fifth Fifth 120 120 month month Interval Interval beginning February 18, 2013.

Precedents7. Precedents A similar relief A similar reliefrequest request was was previously previously approved for Quad Cities Nuclear Power Station Units 1 and and 22 for for the the Fourth Fourth 120 120month monthInterval Interval (Relief (Relief Request RequestRV-30F)

RV-30F) in in letter from from R.R. Gibbs Gibbs (U.S.

(U.S. NRC)

NRC) to to C.

C. Pardee "Dresden Pardee (Exelon Generation), "Dresden Nuclear Power Station Units Units 2 and and 33 -- Relief ReliefRequest RequestNo.No.RV-02C RV-02Cfromfrom 5-Year 5-Year Test Interval for Main Interval for Main Steam Steam Safety Valves and Quad Quad Cities Cities Nuclear Nuclear Power Power Station, Units 1 and 2 - ReliefRelief Requests RequestsNo. No.RV-30E RV-30EandandRV-30F RV-30Ffrom from 5-Year 5-Year Test Interval for Main Interval for MainSteam Steam Safety Safety Valves,"

Valves,"dated dated June June 27, 2008.

Page 20 of 24

10 CFR 50.55a SO.SSa Request Request Number Number RV-06 RV-06 Relief Requested Requested Accordance with In Accordance with 10 10CFR CFR 50. 55a(a)(3)(ii)

SO.SSa(a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Unusual Difficulty Compensating Increase in Level of Quality Quality oror Safety Safety Page 1 of 2 1.

1. ASME Code CodeComponents Components Affected Affected Component Number Number System Code Class Category Cateqory 1-0203-003A 1-0203-003A Main Steam Main 11 B/C 1-0203-004A 1-0203-004A Main Main Steam 1 1 C 1-0203-004B Main Steam Main 1 1 C 1-0203-004C Main Main Steam 1 1 C 1-0203-004D Main Steam Main 1 1 C 1-0203-004E Main Main Steam 1 1 C 1-0203-004F 1-0203-004F Main Main Steam 1 1 C 1-0203-004G 1-0203-004G Main Main Steam 1 1 C 1-0203-004H Main Main Steam 1 1 C 2-0203-003A Main Steam Main Steam 1 1 B/C 2-0203-004A Main Steam Main 1 1 C 2-0203-004B Main Steam Main Steam 1 1 C 2-0203-004C Main Main Steam Steam 1 1 C 2-0203-004D Main Main Steam Steam 1 1 C 2-0203-004E Main Steam Main Steam 1 1 C 2-0203-004F Main Main Steam Steam 1 1 C 2-0203-004G Main Steam Main Steam 1 1 C 2-0203-004H Main Main Steam 1 1 C Applicable 2.Code Edition Applicable Codeand EditionAddenda and Addenda ASME OM Code 2004 Edition through 2006 Addenda Applicable 3. Code Requirement Applicable Code Requirement Appendix I, 1-1350(c) 1-1350(c) -- Requirements for Testing Additional Additional Valves Valves Reason 4.for Reason Request for Request Pursuant toto 10 CFR 50.55a, 50.55a,"Codes "Codesandandstandards,"

standards,"paragraph paragraph (a)(3)(ii),

(a)(3)(ii), relief relief is is requested from from the requirement requirement of ASME OM OM Code, Appendix I, 1-1350(c).

Appendix I, 1-1350(c). The basis of the relief relief request is that that the the Code requirement requirement presents presents an undue hardship hardship without withoutaacompensating increase in compensating increase in the the level level of ofquality quality or or safety.

safety.

Valve 11(2)-0203-003A Valve (2)-0203-003A is is aa dual function safety/relief safety/relief valve valve manufactured manufactured by by Rock. The remaining Target Rock. valves are remaining valves are simple simple safety safety valves.

valves. These These mainmain steam steam safety valves valves are are used to terminate an abnormal pressure pressure increase increasein in the the reactor reactor Page 21 21 of 24

10 CFR 50.55a Request Number Number RV-06 RV-06 Page 2 of of22 vessel andand the the reactor reactor coolant coolant pressure pressureboundary boundary(i.e., (Le., they theyprovide provide overpressure protection).

overpressure protection).

The physical locations of the safety valves cause cause themthem to tointerfere interfere with with one another during transport of the the valves in and out of containment.

containment. In In order order toto create aa transport transport path, path, atat least leasthalf half of of the subject subject valves are are removed, removed, tested tested and rebuilt during each rebuilt during each refueling refuelingoutage.

outage. This accelerated accelerated maintenance maintenance schedule provides schedule provides aa high high level level ofof assurance assurancethat thatthese thesesafety safetyvalves valveswill will perform perform their safety safety function.

function.

Quad Cities Nuclear Power Station Station does doesnotnothavehavethethefacilities facilitiesrequired requiredto to perform set-point perform set-pointtests tests on on large large relief reliefand and safety safety valves.

valves. TheseThese valves valves areare unbolted from from their their mounting mounting flanges, flanges, decontaminated, and and shipped shippedto toananoff-site off-site test test facility. Because of facility. Because of the the lengthy lengthy period period required required forfor removal, removal, transportation, testing and re-installation, re-installation, the removal removal and and testing testing of of additional additional valves valves due dueto to sample expansion expansion wouldwould delay delay unitunit start-up from refueling outages from refueling outages by at least several days. This This represents representsaasignificant significant hardship.

hardship.

The sample sample expansion expansionrequirements requirementsofofAppendixAppendixI Iwouldwouldrequire requiretwo twoadditional additional valves be tested tested ifif one one valve valve failed failed its set-point test. Since Sincethe thedual dualfunction function safety/relief valve safety/relief valve isistested tested each outage,outage, and and no noless lessthanthanfourfourof ofthe theremaining remaining valves are tested during each outage, the valves the valves valves already already being tested represent represent an increased samplesample population.

population. Therefore, Therefore, basedbasedon onthe thesample sampleexpansion expansion requirements already being met met for one valve, and the the hardship hardship associated associatedwith with pulling additional pulling additional valves, no additional valves will valves will be tested if only one valve tested if only one valve fails fails the set-point test.

Proposed 5. Proposed Alternative and Basis for Use Alternative The dual function safety/relief valve, valve, and at at least leasthalf halfof of the the eight eight safety safetyvalves, valves, will will bebe removed removed and and tested tested during each reactor reactor refueling refueling outage. IfIf only only one one ofof the eight safety safety valves valves fails fails its its set-point set-pointtest, test,additional additionalsafetysafetyvalves valveswill will not notbebe tested. IfIfmore morethan thanoneonesafety safetyvalve valvefails, fails, the thesample sampleexpansion expansioncriteria criteriaofof Appendix I, 1350(c) will be implemented.

will be implemented.

Duration of

6. Proposed Duration of ProposedAlternative Alternative The proposed alternative will be utilized for the entire Fifth Fifth 120 120 month Interval beginning February 18, 18, 2013.

2013.

Precedents7. Precedents This relief request was previously relief request previously approved for Quad Cities Cities Nuclear Power Power Station Units 1 and 22 for for the Fourth Fourth 120120 month month Interval Interval (Relief (Relief Request RequestRV-30B)

RV-30B) in letter from in from A.A. Mendiola Mendiola (U.S. (U.S. NRC)

NRC) to to C.

C. Crane Crane (Exelon Generation),

Generation), "Quad"Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Cities Fourth 10-Year 10-YearInservice Inservice Testing Testing Program Relief Program Requests," dated February Relief Requests," February 20, 2004.

20,2004.

Page 22 of 24

10 CFR 50.55a Request Number RV-07 Relief Requested In Accordance with 10 CFR 50.55a(a)(3)(i)

In 50.55a(a)(3)(i)

Alternate Provides Acceptable Level of Quality and Safety of 2 Page 1 of2

1. ASME Code ASME Code Components Components Affected Affected Component Number System Code Class Cateqory Category 1-0203-001 A-AO Main Steam Main Steam 11 A 1-0203-001 B-AO Main Steam Main Steam 11 A 1-0203-001 C-AO Main Steam Main Steam 11 A 1-0203-001 D-AO Main Steam Main Steam 11 A 1-0203-002A-AO 1-0203-002A-AO Main Steam Main Steam 11 A 1-0203-002B-AO Main Steam Main Steam 11 A 1-0203-002C-AO Main Steam Main Steam 11 A 1-0203-002D-AO Main Steam Main Steam 11 A 2-0203-001 A-AO Main Steam Main Steam 11 A 2-0203-001 B-AO Main Steam Main Steam 11 A 2-0203-001 C-AO Main Steam Main Steam 11 A 2-0203-001 D-AO Main Steam Main Steam 1 1 A 2-0203-002A-AO Main Steam Main Steam 1 1 A 2-0203-002B-AO Main Steam Main Steam 1 1 A 2-0203-002C-AO Main Steam Main Steam 1 1 A 2-0203-002D-AO Main Steam Main Steam 1 1 A Applicable 2.Code Edition Applicable Codeand EditionAddenda and Addenda ASME OM Code 2004 Edition Edition through 2006 Addenda Applicable 3. Code Requirement Applicable Code Requirement ISTC-5132(b) - - Stroke Test Acceptance Acceptance Criteria Criteria -- Valves Valves with with reference reference stroke stroke times of less less than than or or equal equal to to 10 10seconds secondsshallshallexhibit exhibitno nomore morethanthan+/-50%

+/-50%

change change inin stroke stroke time when compared to the reference value. value.

Reason 4. for Reason Request for Request Pursuant to 10 CFR 50.55a, "Codes "Codes and and standards,"

standards,"paragraph paragraph(a)(3)(i),

(a)(3)(i), relief relief is is requested requested from from the requirement requirement of of ASME ASME OM OM Code Code ISTC-5132(b).

ISTC-5132(b). The The basis basisof of the relief relief request is that the proposed proposed alternative alternative would would provide an acceptable acceptable level of quality and and safety.

safety.

The main main steam steam isolation isolation valves valves (MSIVs)

(MSIVs) open to to admit admit reactor reactor steam steam to to the the main turbine.

turbine. They close to provide containment and reactor isolation.

close to provide containment and reactor isolation.

The ISTC ISTC Code requirement requirement basesbases the the stroke stroke time time acceptance acceptancecriteria criteria on on aafixed fixed reference value taken from from aa baseline test. However, However,Technical TechnicalSpecifications Specifications Page 23 of 2424

10 CFR 10 CFR 50.55a 50.55a Request Request Number Number RV-07 RV-07 Page22 of Page of 22 (TS)Surveillance (TS) Surveillance Requirement Requirement (SR) (SR) 3.6.1.3.6 in TS 3.6.1.3, "Primary "Primary Containment Isolation Containment Isolation Valves Valves (PCIV's),"

(PCIV's),"establishes establishes an invariable acceptable acceptable stroke time stroke time range range forforthe MSIVsofof~>3 3seconds the MSIVs secondstotoS<55seconds.

seconds. This fixedfixed range range is more conservative is more conservative and and consistent than that that required required by by ISTC-5132(b)

ISTC-5132(b) since the range isis not range not dependent dependent on on a baseline value that may vary vary byby as as much as +/-1 +/-1 second.

second.

5.

Proposed Alternative

5. and Basis Proposed Alternative forfor and Basis Use Use TS SR 3.6.1.3.6 establishes TS establishes an an acceptable acceptablestroke stroketimetimerange rangeforfor the the MSIVs MSIVs of 3.0 seconds::;

3.0 seconds <_TTMsiv < 5.0 MSIV S 5.0 seconds.Quad seconds. Quad Cities Cities Nuclear Nuclear Power Station (QCNPS) willutilize will utilizethis thisrange range for forevaluating evaluating an an acceptable acceptableMSIV MSIV stroke stroketime time in in lieu lieu of of establishing an acceptance establishing acceptance band band based basedon onMSIV MSIV stroke stroke time time reference reference values.

values.

QCNPS has also also established establishedadditional additional limitations limitations on stroke time based based on on reactor power levels to ensure ensure that thatthetheTS TSSR SRlimits limitsare arealways alwaysmet. met.AnyAnyMSIVMSIV fails to that fails to meet the TS SR SR limits limits will be considered will be considered inoperable and and required required actions will continue to will continue to be in accordance accordancewith with ISTC-5133 ISTC-5133 -- Stroke Stroke Test TestCorrective Corrective Actions.

Duration of

6. Proposed Duration of ProposedAlternativeAlternative The proposed alternative will be utilized utilized for the entire entire Fifth Fifth 120 120 month month Interval Interval beginning February 18, 2013.

February 18, 2013.

Precedents7. Precedents This relief relief request waswas previously previously approved approved for for Quad Quad Cities Cities Nuclear Nuclear Power Power Station Units Units 11 and and 22 for for the the Fourth Fourth 120120month monthInterval Interval(Relief (Relief Request RequestRV-30C)

RV-30C) in letter from from A.

A. Mendiola Mendiola (U.S.

(U.S. NRC)

NRC) to to C.

C. Crane Crane (Exelon (Exelon Generation),

Generation),"Quad "Quad Cities Nuclear Power Station, Station, Units Units 11 and and 22 -- Fourth Fourth10-Year 10-YearInservice InserviceTesting Testing Program ReliefRelief Requests," dateddated February February20, 20, 2004.

2004.

Page 24 Page 24of of2424

Retrieved from "https://kanterella.com/w/index.php?title=RS-12-026,_Submittal_of_Relief_Requests_Associated_with_the_Fifth_Inservice_Testing_Interval&oldid=2105937"