RS-12-149, Response to Request for Additional Information Regarding Relief Requests Associated with the Fifth Inservice Testing Interval

Response to Request for Additional Information Regarding Relief Requests Associated with the Fifth Inservice Testing Interval

ML12257A163
Person / Time
Site:	Quad Cities
Issue date:	09/13/2012
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of New Reactors
References
RS-12-149, TAC ME7983, TAC ME7984, TAC ME7987, TAC ME7988, TAC ME7992, TAC ME7993, TAC ME7994, TAC ME7995
Download: ML12257A163 (24)

Text

1 4300 Winfield Road Warrenville, IL 60555 Exelon Generation 630 657 2000 Office RS-12-149 10 CFR 5O.55a September 13, 2012 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Response to Request for Additional Information Regarding Relief Requests Associated with the Fifth Inservice Testing Interval

References:

1) Letter from D. Gullott (Exelon Generation Company, LLC) to NRC, "Submittal of Relief Requests Associated with the Fifth Inservice Testing Interval," dated February 15, 2012

2) Letter from B. Mozafari (NRC) to M. J. Pacilio, (Exelon Generation Company, LLC), DQuad Cities Nuclear Power Station, Units 1 and 2-Request for Additional Information Related to Relief Request RV-01, RV-03, RV-05, AND RV-06 (TAC NOS. ME7983, ME7984, ME7987, ME7988, ME7992, ME7993, ME7994, AND ME7995),* dated September 12, 2012 In Reference 1 Exelon Generation Company, LLC (EGC), requested NRC approval of relief requests associated with the fifth 10-year inservice testing (1ST) program interval for Quad Cities Nuclear Power Station (QCNPS). During review of the subject relief requests, the NRC concluded that additional information would be needed to complete their review as documented in Reference 2. The response to this request for additional information is provided in Attachment 1. Attachment 2 includes an updated relief request RV-01, which was revised to address concerns raised in Reference 2.

Attachment 3 includes an updated relief request RV-06, which removes the dual function Target Rock component since relief for this component is not required given it is a population of one. The revised RV-06 also corrects an incorrect code reference and clarifies the basis for the relief request. As noted in Reference 2, it was agreed that EGC would provide a response to this request for additional information by September 17, 2012.

U. S. Nuclear Regulatory Commission September 13, 2012 Page 2 of 2 There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact Mr. Joseph A.

Bauer at (630) 657-2804.

Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC - Response to Request for Additional Information - Revised Relief Request RV-01 - Revised Relief Request RV-06

ATTACHMENT 1 Response to Request for Additional Information

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval RAI RV-01-1:

The alternative identified in Section 5 for relief request (RR) RV-01 is based on, but reads differently than, the code case for inservice test (1ST) frequency approved by the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code Standards Committee. (This code case was approved for use by the ASME OM Standards Committee and the ASME Board of Nuclear Codes and Standards and is currently identified by ASME according to its Record Number 10-1992. This code case will carry a conventional number (OMN-xx) when it is published with the next OM Code edition.)

Describe whether it is Exelon's intent to adopt all of the language of the approved Code Case 10-1992, for the fifth inservice testing interval at QCNPS, as an alternative to the current 1ST frequency requirements listed in the QCNPS, technical specifications and the guidance provided in NRC NUREG-1482, Revision 1.

Response

Since this question was issue, the ASME OM Code Committee has assigned OMN-19 to this Code Case. The draft of Code Case OMN-19 was used in the development of this relief request. EGC will adopt the language of approved ASME Code Case OMN-19 for the fifth inservice testing interval. A revised RV-01 relief request is provided in Attachment 2, which reflects the approved ASME Code Case OMN-19 and replaces the original RV-01 in its entirety.

RAI RV-03-1:

In the noted reference for RR RV-03, Section 4, "Reason for Request," the second paragraph, third sentence, states that 'While the motor-operated Pressure Indicating Valves (PIVs) affected by this relief request are also containment isolation valves (CIVs) and tested in accordance with the Appendix J program, the check valve PIVs are not CIVs and not within the Appendix J scope." The RR does not provide any details (i.e., CIVs, PIVs, or check valve etc.) for the components listed in Section 1 of the RR.

(a) Please specify whether the listed valves are CIVs, PIVs, or check valves.

(b) Please provide the current frequency used at QCNPS for (1) functional testing and/or pOSition indicator testing of the PIVs, and (2) leak rate testing of the PIVs.

Page 1

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval

Response

The following table provides the information requested in items (a) and (b) above:

Current Testing for Proposed Testing for CIV, Interval Interval Valve Component PIV, Type Test Frequency Test Frequency Both Exercise Cold Shutdown Stroke Time Closed Cold Shutdown Closed Cold Shutdown App J Option B - App J Option B -

24 months up to 24 months up to AppendixJ 60 months with 15 AppendixJ 60 months with 15 LLRT month grace LLRT month grace based on based on ance Similar to App J 1(2)-1 001- Option B-Gate Both 047-MO 24 months up to PIV Seat PIV Seat 2 Yrs 60 months with 15 Leakage Leakage month grace based on GL 96-05 OMN-1 lAW lAW Diagnostic Diagnostic GL 96-05 OMN-1 Test Test Position Indication Test (PIT) will 2Yrs be performed as part of 1

Exercise Cold Shutdown Stroke Time Closed Cold Shutdown Closed Cold Shutdown App J Option B - App J Option B -

24 months up to 24 months up to 1(2)-1001- AppendixJ 60 months with 15 AppendixJ 60 months with 15 Gate Both 050-MO LLRT month grace LLRT month grace based on based on Similar to App J Option B-24 months up to PIV Seat PIV Seat 2 Yrs 60 months with 15 Leakage Leakage month grace based on ance Page 2

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval CIV, Valve Component PIV, Type Test Frequency Test Frequency Both GL 96-05 OMN-1 lAW lAW Diagnostic Diagnostic GL 96-05 OMN-1 Test Test Position will Position be performed as part of Indication 2 Yrs Diagnostic Test per OMN-1 Test Quarterly App J Option B - App J Option B -

24 months up to 24 months up to AppendixJ 60 months with 15 Appendix J 60 months with 15 LLRT month grace LLRT month grace based on based on ance 1(2)-1 001- Similar to App J Gate Both Option B-029A1B-MO 24 months up to PIV Seat PIV Seat 2Yrs 60 months with 15 Leakage Leakage month grace based on ance 96-05 OMN-1 IAWGL Diagnostic Diagnostic 96-05 Test 2Yrs Exercise Exercise Cold Shutdown Refuel Closed Closed Position Position Indication 2Yrs Indication 2Yrs 1(2)-1001-Check PIV Similar to App 068A1B Option B-24 months up to PIV Seat PIV Seat 60 months with 15 2 Yrs Leakage Leakage month grace based on performance Page 3

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval Current Testing for Proposed Testing for CIV, Interval Interval Valve Component PIV, Type Test Frequency Test Frequency Both Quarterly Stroke Time < 24 months Quarterly Closed (PerOMN-1)

AppJ B-App J Option B - 24 months up to AppendixJ Currently at 60 AppendixJ 60 months with 15 LLRT months with 15 LLRT month grace month grace based on 1(2)-1402-Gate Both Similar to App J 025A/B-MO Option B-24 months up to PIV Seat PIV Seat 2Yrs 60 months with 15 Leakage Leakage month grace based on lAW lAW OMN-1 est GL 96-05 2 Yrs Exercise Exercise 2 Yrs Closed Closed 1(2)-1402- Similar to Check PIV 009A/B Option B-24 months up to PIV Seat PIV Seat 2 Yrs 60 months with 15 Leakage Leakage month grace based on RAI RV-03-2:

In the "Reason for Request," section of the noted reference, the third paragraph, fifth and sixth sentences state that "The functional testing of the PIV check valves will be monitored through a Condition Monitoring Plan in accordance with ISTC-5222, "Condition-Monitoring Program,"

and Mandatory Appendix II, "Check Valve Condition Monitoring Program." Performance of the separate 2-year PIV leak rate testing does not contribute any additional assurance of functional capability; it only determines the seat tightness of the closed valves.

Page 4

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval The use of a "Check Valve Conditioning Program," allows for testing of a check valve (group of one valve) extension of up to once in a 10-year interval. Please describe if allowing check valve testing once evelY 10 years, along with the proposed extension of leak rate testing (based on the Nuclear Energy Institute 94-01 "lndustlY Guideline for Implementing Performance Based Option of 10 CPR Part 50, Appendix J", to once evelY 54 months in lieu of 18 months) assures functional capability and operational readiness of these valves.

Response

The functional capability of check valves 1(2)-1 001-068A1B is demonstrated by the opening and closing of the valves using a valve actuator each refuel outage. This test is separate and distinct from the PIV testing; therefore, there is no need for a Condition Monitoring Plan for these valves.

The functional capability of check valves 1(2)-1402-009A1B is demonstrated by:

1. The injection of Core Spray Flow into the Reactor Vessel on a Cold Shutdown frequency verifies the valves capability of opening.

2. The capability of building pressure against the valve during Pressure Isolation Valve Seat Leakage Testing verifies the valves are closed.

These tests provide reasonable assurance of operational readiness.

Note that NEI 94-01 is not the sole basis for this relief request given NEI 94-01 does not address seat leakage testing with water. This document was cited as an approach similar to the requested alternative method.

If the proposed alternative is approved and the valves exhibit good performance, there is the possibility that the PIV test frequency could be extended so that the test would not be required each refuel outage. However, since these valves can only be verified for closure by establishing pressure against the valve disc; current code requirements in ISTC-3522 would require a closure test every refuel negating the intended dose and resource savings.

It is not intended to extend check valve testing to once every 10 years by means of a Condition Monitoring Plan. The use of a Condition Monitoring Plan is intended to align the frequency for the closure exercise testing with the pressure isolation valve test. By use of a Condition Monitoring Plan, the check valve closure test, based on performance, would be verified concurrently with the PIV seat leakage test. The frequency of the check valve closure test would then be the same as the PIV seat leakage test since closure performance and seat leakage performance are linked. The PIV seat leakage test would not pass if the valve failed to close.

RAJ RV-03-3:

In the noted reference, Section 5, "Proposed Alternative and Basis for Use," the second paragraph, states that "the primalY basis for this relief request is historically good performance PageS

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval of the PIVs."

(a) Please provide the historical data of good performance that supports this statement.

(b) Please provide an explanation for how many successful PIV leakage tests will be required before the test frequency can be extended?

Response to Item (a):

The following tables present test data that demonstrate acceptable historical PIV performance for the Residual Heat Removal (RHR) and Core Spray (CS) systems.

Note that for the following PIVs: RHR Shutdown Cooling Suction (MO 1(2)-1001-47, MO 1(2)-

1001-50), Core Spray Injection (MO 1(2)-1402-25A1B), and RHR Injection (MO 1(2)-1001-29A1B), PIV data is not available prior to 2006. A 2005 self assessment performed on the 1ST program identified deficiencies in how the station conducted PIV tests on certain Motor Operated PIVs. The assessment concluded that the station inappropriately credited Appendix J Type C tests to verify the seat tightness of these valves. These deficiencies were entered into the Corrective Action Program and measures were taken to align the PIV testing with the OM Code requirements. The following table denotes three test failure; these failures occurred at low test pressure (approximately 100 Ibs).

RHR Shutdown Cooling Suction PIVs Valve Comments 3/23/2012 0.282 5

_1--------------------------------------------------------------

2-1001-050-MO 4/1/2006 No Measurable Leakage 5 2-1001-050-MO 31712008 No Measurable Leakage 5 2-1oo1-050-MO 3/23/2010 No Measurable Leakage 5 2-1001-050-MO 3/23/2012 0.744 5 Page 6

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval Core Spray Injection PIVs Valve Comments RHR LPCI Injection PIVs Valve Comments 2-1001-0298-MO 4/4/2006 No Measurable Leakage 5 2-1001-0298-MO 3/13/2008 No Measurable Leakage 5 2-1001-0298-MO 3/18/2010 No Measurable Leakage 5 2-1001-0298-MO 3/30/2012 0.0081 5 Page 7

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval Core Spray PIVs Valve EPN Comments Retest following seating of valve.

2-1402-009A 3/21/2012 0.000461 5

?i' 2-1402-0098 7/2/1995 No Measurable Leakage 5 2-1402-0098 4/10/1997 0.125 5 2-1402-0098 2/25/1999 0.68 5 2-1402-0098 1/31/2000 No Measurable Leakage 5 2-1402-0098 2/15/2002 No Measurable Leakage 5 Page 8

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval Required Measured Value Valve EPN Date of Test Action Limit Comments (gpm)

(gpm) 2-1402-0098 2/17/2002 No Measurable Leakage 5 2-1402-0098 2/25/2004 No Measurable Leakage 5 2-1402-0098 3/9/2004 No Measurable Leakage 5 2-1402-0098 4/5/2006 0.19 5 2-1402-0098 3/11/2008 0.35 5 2-1402-0098 3/21/2010 0.7 5 2-1402-0098 3/31/2012 No Measurable Leakage 5 RHR PIVs Required Valve Date of Test Action Limit Comments Page 9

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval Required Measured Value Valve Date of Test Action Limit Comments (gpm)

(gpm) 2-1001-0686 2/1/2000 No Measurable Leakage 5 2-1001-0686 2115/2002 No Measurable Leakage 5 2-1001-0686 4/4/2006 No Measurable Leakage 5 2-1001-0686 3/13/2008 0.33 5 2-1001-0686 3/18/2010 No Measurable Leakage 5 2-1001-0686 3/30/2012 0.29 5 Response to Item (b):

The extension of test frequencies will be consistent with the guidance provided for Appendix J, Type C leak rate tests as detailed in paragraph 10.2.3.2, "Extended Test Interval," of NE194-01 "Nuclear Energy Institute - Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J," which states:

Test intervals for Type C valves may be increased based upon completion of two consecutive periodic as-found Type C tests where the result of each test is within a licensee's allowable administrative limits. Elapsed time between the first and last tests in a series of consecutive passing tests used to determine performance shall be 24 months or the nominal test interval (e.g., refueling cycle) for the valve prior to implementing Option B to Appendix J. Intervals for Type C testing may be increased to a specific value in a range of frequencies from 30 months up to a maximum of 60 months (as limited by Regulatory Guide 1.163, "Performance Based Containment Leak-Test Program"). Test intervals for Type C valves are determined in accordance with Section 11.0 of NEI 94-01.

RAI RV-05-1:

Please define the length of time QCNPS has between refueling outages (e.g., 18 months or 24 months).

Response

The length of time between refueling outages at QCNPS is 24 months.

RAI RV-05-2:

Please describe the historical cumulative radiation exposure for removal and replacement of the main steam safety valves (MSSVs), and the expected radiation exposure using the proposed alternative method.

Response

The proposed relief has no impact on cumulative radiation exposure (Le., the number of MSSVs removed and replaced each refueling is unaffected). However, as noted in the relief Page 10

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval request, to support replacement activities four spare MSSVs are required to be certified prior to the refuel outage during which they will be installed. These spare MSSVs are initially certified tested immediately after refurbishment and placed into storage. In order to meet the five year test-to-test interval requirement, each spare MSSV requires a second certification test immediately prior to a refuel outage to mitigate the time the valve spent in storage. The proposed relief extends the testing interval from five to six years (with a grace period of six months) allowing additional time for the spare MSSVs to reside in storage after the initial certification test, negating the need for recertification immediately prior to installation. Quad Cities does not have the facilities to perform MSSV certification testing. The proposed relief request reduces the number of recertification tests and reduces the potential for disc/seat damage due to these additional tests.

RAI RV-05-3:

The request describes 1ST results for the MSSVs from 1997 to the present. Please provide the 1ST results for the MSSVs, prior to 1997, if available.

Response

While MSSV test data is available prior to 1997, performance in this timeframe is not indicative of the current MSSV performance. Since that time, changes in refurbishment methods, testing methods, and improvements in reducing main steam system vibration (through the Acoustic Side Branch modification) have had a positive impact on MSSV performance. Therefore the MSSV performance prior to 1997 is not relevant to this relief request.

RAI RV-05-4:

The request states that, "This alternative is consistent with the alternative provided in ASME Code Case OMN-17, 'Alternative Rules for Testing ASME Class 1 Pressure Relief/Safety Valves,' Section 1, 7est Frequencies, Class 1 Pressure Relief Valves,' Paragraph (a) 72-month Interval." Please confirm that the alternative complies with paragraph (b) of Code Case OMN-17.

Response

Paragraph (b) of Code Case OMN-17 states:

(b) Replacement With Pretested Valves. The Owner may satisfy testing requirements by installing pretested valves to replace valves that have been in service, provided that (1) for replacement of a partial complement of valves, the valves removed from service shall be tested prior to resumption of electric power generation and shall be subjected to the maintenance specified in subpara. (d); or (2) for replacement of a full complement of valves, the valves removed from service shall be tested within 24 mo of removal from the system.

Page 11

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval Quad Cities removes a partial complement of MSSVs each refueling outage and ships them to an ASME OM Code-certified vendor to perform as-found testing prior to resumption of electric power generation. The vendor also performs the inspection, refurbishment, and as-left testing that meet the maintenance requirements specified in subparagraph (d) of OMN-17. For these reasons, the proposed alternative complies with paragraph (b) of Code Case OMN-17.

RAI RV-06-1:

It is stated in the alternative request that the removal and testing of additional valves due to sample expansion would delay unit startup from refueling outages by at least several days, and that this represents a significant hardship. Please describe why this would represent a significant hardship.

Response

The information provided below provides additional detail regarding ttle impact of a typical refuel outage schedule in the event that expanded testing is required. The MSSV work starts approximately on the second day of a refueling outage. It takes three to four days to remove the valves from the Drywell and prepare them for shipment. The valves are shipped to an off-site vendor facility for as-found testing. Shipping and testing of the valves typically takes two to three days. The as-found results are then reported and scope expansion is determined. If scope expansion requires the remaining four MSSVs to be replaced, this will take approximately six to eight days (including removal and installation activities) provided sufficient resources and valve access are readily available. During a typical outage, this additional work scope would be at or near 'critical path' and result in a corresponding push to unit restart. In the event the remaining four MSSVs would be required to be replaced, then an approximate 6.4 REM and 876 resource-hours would be required to complete the evolution. This estimate was calculated using the dose and resource-hour data from the previous six refueling outages.

The relief request is intended to decrease the likelihood of an unplanned scope expansion and corresponding restart delays by preemptively removing and testing 50% of the MSSVs during each refuel outage.

RAI RV-06-2:

The proposed alternative states that the dual function safety/relief valve, and at least half of the eight MSSVs, would be removed and tested during each reactor refueling outage.

Proposed alternative RV-05 is requesting to only remove and test a minimum of 20 percent of the MSSVs during each reactor refueling outage. Please describe why the number of MSSVs to be removed and tested differs in the two alternative requests.

Response

RV-06 presents the actual station practice for MSSV testing, which includes the removal of at least half of the eight MSSVs each refueling outage (for a total of four valves). The proposed alternative for RV-05 (Le., test frequency extension from five year to six year 'test-to-test') is quoting OMN-17, noting a minimum of 20% of the pressure relief valves will be tested within Page 12

ATTACHMENT 1 Response to Request for Additional Information 10-Year Inservice Testing Program Interval any 24-month interval. Testing at least half of the eight MSSVs each refueling outage continues to meet the "minimum of 20 percent of the MSSVs" requirement of OMN-17 as stated in RV-05.

Page 13

ATIACHMENT2 Revised Relief Request RV-01

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

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety Page 1 of 4

1. ASME Code Components Affected All Pumps and Valves contained within the Inservice Testing Program scope.

2. Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3. Applicable Code Requirement

This request applies to the frequency specifications of the ASME OM Code. The frequencies for tests given in the ASME OM Code do not include a tolerance band.

ISTA-3120(a) - "The frequency for the inservice testing shall be in accordance with the requirements of Section 1ST."

ISTB-3400 - Frequency of Inservice Tests ISTC-3510 - Exercising Test Frequency ISTC-3540 - Manual Valves ISTC-3630(a) - Frequency ISTC-3700 - Position Verification Testing ISTC-5221 (c)(3) - "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

Appendix 1,1-1320 - Test Frequencies, Class 1 Pressure Relief Valves Appendix 1,1-1330 - Test Frequencies, Class 1 Nonreclosing Pressure Relief Devices Appendix 1,1-1340 - Test Frequencies - Class 1 Pressure Relief Valves that are used for Thermal Relief Application Appendix I, 1-1350 - Test Frequencies - Class 2 and 3 Pressure Relief Valves

10 CFR SO.SSa Request Number RV-01 Page 2 of 4 Appendix I, 1-1360 - Test Frequencies - Class 2 and 3 Nonreclosing Pressure Relief Devices Appendix 1,1-1370 - Test Frequencies - Class 2 and 3 Primary Containment Vacuum Relief Valves Appendix 1,1-1380 - Test Frequencies - Class 2 and 3 Vacuum Relief Valves Except for Primary Containment Vacuum Relief Valves Appendix 1,1-1390 - Test Frequencies - Class 1 Pressure Relief Valves that are used for Thermal Relief Application Appendix II, 11-4000(a)(1) - Performance Improvement Activities Interval Appendix II, 11-4000(b)(1)(e) - Optimization of Condition Monitoring Activities Interval

4. Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in the Table 3.2 of NUREG 1482, Revision 1) and Owners routinely applied the surveillance extension time period (Le., grace period) contained in the plant Technical Specifications (TS)

Surveillance Requirements (SRs). The TS typically allow for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (SR 3.0.2). However, regulatory issues have been raised concerning the applicability of the TS "Grace Period" to ASME OM Code required inservice test frequencies irrespective of allowances provided under TS Administrative Controls (Le., TS 5.5.6, "Inservice Testing Program," invokes SR 3.0.2 for various OM Code frequencies).

The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. There may be a conflict where a surveillance test could be required (Le., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after a plant condition or associated Limiting Condition for Operation (LCO) is within its applicability. Therefore, to avoid this conflict, the surveillance test should be performed when it can be and should be performed.

10 CFR 50.55a Request Number RV-01 Page 3 of4 The NRC recognized this potential issue in the TS by allowing a frequency tolerance as described in TS SR 3.0.2. The lack of a similar tolerance applied to OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility.

Thus, just as with TS required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. This assures operational flexibility when scheduling surveillance tests that minimize the conflicts between the need to complete the surveillance and plant conditions.

5. Proposed Alternative and Basis for Use 1ST and earlier editions and addenda of ASME OM Code specify component test frequencies based either on elapsed time periods (e.g., quarterly, 2 years, etc.) or based on the occurrence of plant conditions or events (e.g., cold shutdown, refueling outage, upon detection of a sample failure, following maintenance, etc.).

a} Components whose test frequencies are based on elapsed time periods shall be tested at the frequencies specified in Section 1ST with a specified time period between tests as shown in the table below. The specified time period between tests may be reduced or extended as follows:

1) For periods specified as less than 2 years, the period may be extended by up to 25% for any given test.

2) For periods specified as greater than or equal to 2 years, the period may be extended by up to 6 months for any given test.

3) All periods specified may be reduced at the discretion of the owner (Le., there is no minimum period requirement).

Period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g.,

performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified.

Period extensions may also be applied to accelerated test frequencies (e.g., pumps in Alert Range) and other less than two year test frequencies not specified in the table below.

10 CFR 50.55a Request Number RV-01 Page 4 of4 Peried extensiens may net be applied to. the test frequency requirements specified in Subsectien ISTD, Preservice and Inservice Examinatien and Testing ef Dynamic Restraints (Snubbers) in Light-water Reacter Nuclear Pewer Plants, as Subsectien ISTD centains its ewn rules fer peried extensiens.

Frequency Specified Time Period Between Tests Quarterly 92 days (er every 3 menths)

Semiannually 184 days (er every 6 menths)

Annually 366 days (er every year) x calendar years x Years where 'x' is a whele number ef years ~ 2 b) Cempenents whese test frequencies are based en the eccurrence ef plant cenditiens er events may net have their peried between tests extended except as allewed by ASME OM Cede 2004 Editien through OMb-2006 Addenda and earlier editiens and addenda ef ASME OM Cede.

6. Duration of Proposed Alternative The prepesed alternative will be utilized fer the entire Fifth 120 menth Interval beginning February 18, 2013.

7. Precedent Generic relief has net been specifically granted to. apply a telerance band to. the ASME OM cede required test frequencies. The NRC has previeusly accepted the applicatien ef TS SR 3.0.2 telerances to selected OM Cede frequencies as deneted in TS 5.5.6.

The prier NRC acceptance ef the practice ef applying TS telerances to. ASME OM cede required test frequencies provides equivalent precedence fer accepting and appreving this relief request.

8. References

a. Quad Cities TS Sectien 1.4 - Frequency

b. Quad Cities TS Sectien 5.5.6 - Inservice Testing Pregram

c. Quad Cities TS SR 3.0.2 - Specified Frequency (25% Grace Peried)

d. Quad Cities TS SR 3.0.4 - Mode Entry Requirements

ATTACHMENT 3 Revised Relief Request RV-06

10 CFR 50.55a Request Number RV-06 Relief Requested In Accordance with 10 CFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality or Safety Page 1 of2

1. ASME Code Components Affected Component Number System Code Class Cateqory 1-0203-004A Main Steam 1 C 1-0203-0048 Main Steam 1 C 1-0203-004C Main Steam 1 C 1-0203-004D Main Steam 1 C 1-0203-004E Main Steam 1 C 1-0203-004F Main Steam 1 C 1-0203-004G Main Steam 1 C 1-0203-004H Main Steam 1 C 2-0203-004A Main Steam 1 C 2-0203-0048 Main Steam 1 C 2-0203-004C Main Steam 1 C 2-0203-004D Main Steam 1 C 2-0203-004E Main Steam 1 C 2-0203-004F Main Steam 1 C 2-0203-004G Main Steam 1 C 2-0203-004H Main Steam 1 C

2. Applicable Code Edition and Addenda

ASME OM Code 2004 Edition through 2006 Addenda

3. Applicable Code R!9uirement Appendix I, 1-1320(c) - Requirements for Testing Additional Valves

4. Reason for Request

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(ii), relief is requested from the requirement of ASME OM Code, Appendix I, 1-1320(c). The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

These main steam safety valves are used to terminate an abnormal pressure increase in the reactor vessel and the reactor coolant pressure boundary (i.e., they provide overpressure protection).

10 CFR 50.55a Request Number RV-06 Page 2 of 2 The physical locations of the safety valves cause them to interfere with one another during transport of the valves in and out of containment. In order to create a transport path, at least half of the subject valves are removed, tested and rebuilt during each refueling outage. This accelerated maintenance schedule provides a high level of assurance that these safety valves will perform their safety function.

Quad Cities Nuclear Power Station does not have the facilities required to perform set-point tests on large relief and safety valves. These valves are unbolted from their mounting flanges, decontaminated, and shipped to an off-site test facility. Because of the lengthy period required for removal, transportation, testing and re-installation, the removal and testing of additional valves due to sample expansion would delay unit start-up from refueling outages by at least several days. This represents a significant hardship.

The sample expansion requirements of Appendix I would require two additional valves be tested if one valve failed its set-point test. Since no less than four of the safety valves are tested during each outage, the valves already being tested represent an increased (>20% of group) sample population. Therefore, based on the larger initial sample size (4 vs. a minimum of 2 required), accelerated maintenance schedule, and the hardship associated with pulling additional valves, no additional valves will be tested if only one valve fails the set-point test. This methodology also ensures that 100% of the population is tested every five years.

5. Proposed Alternative and Basis for Use At least half of the eight safety valves will be removed and tested during each reactor refueling outage. If only one of the four safety valves removed for testing fails its set-point test, additional safety valves will not be tested. If more than one safety valve fails its as-found initial setpoint test, the sample expansion criteria of Appendix I, 1320(c)(2) will be implemented.

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

7. Precedents This relief request was previously approved for Quad Cities Nuclear Power Station Units 1 and 2 for the Fourth 120 month Interval (Relief Request RV-30B) in letter from A. Mendiola (U.S. NRC) to C. Crane (Exelon Generation), "Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth 10-Year Inservice Testing Program Relief Requests,U dated February 20, 2004.