RS-13-219, Clarification Regarding the Inservice Testing of Dresden Nuclear Power Station High Pressure Coolant Injection (HPCI) Valves 2(3)-2301-32-SO

Clarification Regarding the Inservice Testing of Dresden Nuclear Power Station High Pressure Coolant Injection (HPCI) Valves 2(3)-2301-32-SO

ML13241A419
Person / Time
Site:	Dresden
Issue date:	08/29/2013
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-13-219, TAC ME9872
Download: ML13241A419 (2)

Text

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) 630 RS-13-219 RS-13-219 10 10 CFR CFR 50.55a 50.55a August 29, August 29, 2013 2013 ATTN:

A Document Control TIN: Document Control Desk Desk U. S. Nuclear U. Nuclear Regulatory Regulatory Commission Commission Washington,DC Washington, DC 20555-0001 Dresden Nuclear Power Station, Dresden Station, Units 2 and 3 Renewed Facility Renewed Facility Operating Operating License Nos. DPR-19 and DPR-25 DPR-25 NRC Docket Nos.

NRC Nos. 50-237 and 50-249

Subject:

ClarificationRegarding Clarification Regardingthe the Inservice Inservice Testing Testing of Dresden NuclearNuclear Power PowerStation Station High Pressure High Pressure Coolant Injection (HPCI)Valves Injection (HPCI) Valves 2(3)-2301-32-S0 2(3)-2301-32-SO (TAC No. ME9872)

References:

1. Letter fromfrom P. R. Simpson (Exelon Generation Company, LLC LLC (EGC))

(EGC>> to to U.

U. S. NRC, "Submittal "Submittal of of Relief Relief Requests Associatedwith Requests Associated with the theFifth Fifth Inservice Inservice Testing Interval," dated October 30, Interval," dated 2012 30,2012

2. Letter Letter from from P. P. R.

R. Simpson Simpson (EGG)(EGC) to to U.U. S.

S. NRC, NRC, "Response "Response to Request Request for for Additional Information Related Additional Information Related to Request Requestfor for NRC NRC Approval Approval of of Relief Relief Requests Requestsfor for Fifth Fifth Inservice Testing Testing Interval Interval (TAC (TAC Nos. ME9871 ME9871 and and ME9872)," dated dated April April 1, 2013 2013 In In Reference 1, EGC EGC requested requested approval approval of of relief relief requests requests associated associatedwith withthe theupcoming upcomingfifth fifth inservice testing (IST) interval at (1ST) interval at Dresden Dresden Nuclear Power Station Station (DNPS),

(DNPS), Units Units 2 andand 3.

3. InIn Reference Reference 2, 2, EGC EGC provide provide additional information related additional information related toto these these relief requests in relief requests in response responseto to an NRC NRC request.

request.

During During aa telephone conversation between between NRC NRC and and EGC EGC personnel personnelon onJuly July31, 31,2013, 2013,NRC NRC personnel personnel requested requestedthat thatEGC EGCprovide provideadditional additionalclarification clarificationininsupport supportofofthe theinformation information provided in References References 11and and22for forthe thetesting testingof ofDNPS, DNPS, Units Units22and and33HPCI HPCIvalves valves 2(3)-2301-32-SO.

2(3)-2301-32-S0.

Specifically, Specifically, in in Reference Reference 1, Attachment 4, Section 4, EGC EGC stated statedthat, that,"Valve "Valve actuation actuation maymaybe be indirectly verified indirectly verified by removing the HPCI system from service, filling the drain pot with HPCI system from service, filling the drain pot with water until water until the the high high level level alarm received, and observing that the high level alarm is received, level alarm alarm clears."

clears." In In this case, case, thethe test testisis normally normally performed performed by by DNPS DNPS Operations Operations Department Departmentpersonnel personnelperforming performingaavalve valveline-line-up up to to isolate isolate 2(3)-2301-32 2(3)-2301-32 from from thethe HPCI HPCI system.

system. The Theentire entire HPCI HPCI system systemisisnotnotremoved removedfrom from service service for for this this test.

test.

August 29, 2013 U. S. Nuclear Regulatory Regulatory Commission Commission Page 2 Additionally, in EGC's Additionally, in EGC's response response to to NRC NRC Request RequestRAI-RV-23H-3 RAI-RV-23H-3 provided provided in in Reference Reference2,2,EGC EGC stated that stated that 2(3)-2301-32-SO 2(3)-2301-32-S0 valve valve internals internals were were not not repaired repaired or or replaced replaced during during the thefourth fourth ten-ten-year inservice in service testing interval.

interval. The The intent intent of this response response was was toto convey convey the the fact fact that that the entire entire valve (Le.,

valve (i.e., actuator, valve body, valve bonnet, and internals),

internals), is is replaced replaced at at aasix-year six-year frequency. This Thisreplacement replacementactivity activity is is performed performed in in lieu lieu of valve valve disassembly and and inspection inspection and or repair of valve valve internals.

internals. The The valves valves were were last last replaced replaced onon March March 11, 11, 2013, 2013, and and onon December 8, 2007, for 8,2007, for DNPS DNPS Units 2 and 3, respectively.

respectively. No Noinspection inspectionofof the the valve valve internals internals took place during during the valve valve replacement replacementactivities.

activities.

Respectfully, R. Simpson Patrick R.

Manager -- Licensing Manager Exelon Generation Company, LLC