View source for RS-13-098, Response to Request for Additional Information Related to Request for NRC Approval of Relief Requests for Fifth Inservice Testing Interval

{{Adams
| number = ML13093A177
| issue date = 04/01/2013
| title = Response to Request for Additional Information Related to Request for NRC Approval of Relief Requests for Fifth Inservice Testing Interval
| author name = Simpson P
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000237, 05000249
| license number = DPR-019, DPR-025
| contact person = 
| case reference number = RS-13-098, TAC ME9871, TAC ME9872
| document type = Letter type:RS
| page count = 6
| project = TAC:ME9871, TAC:ME9872
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:,.
RS-1 3-098 RS-13-098 10 CFR 10  CFR 50.55a 50.55a April 1, April   1, 2013 2013 ATTN:
A         Document Control TIN: Document        Control Desk Desk U. S. Nuclear   Regulatory    Commission U. S. Nuclear Regulatory Commission Washington,DC Washington,       DC 20555-0001 20555-0001 Dresden Nuclear Dresden    Nuclear Power Power Station, Station, Units Units 22 and and 3 3 Renewed     Facility  Operating      License    Nos.
Renewed Facility Operating License Nos. DPR-19 and     DPR-19     and DPR-25 DPR-25 NRC   Docket    Nos. 50 -237  and NRC Docket Nos. 50-237 and 50-249      50-249

==Subject:==

==Subject:==
Response to Response     to Request Request forfor Additional Additional Information InformationRelated Related toto Request Request for for NRC NRC Approval   of  Relief  Requests Approval of Relief Requests         for Fifth Fifth  Inservice     Testing  Interval Testing Interval (TAC Nos.
(TAC          ME9871 and Nos. ME9871       and ME9872)
ME9872)

==Reference:==

==Reference:==
Letter  fromP.
Letter from    P. R.
R. Simpson Simpson (Exelon Generation Generation Company, Company, LLC) to U. u. S. NRC, NRC, "Submittal "Submittal ofofRelief ReliefRequests Requests Associated Associatedwith with the the Fifth Fifth Inservice Inservice Testing Testing Interval,"dated Interval,"   datedOctober October 30,2012 30, 2012 In  the referenced In the   referenced letter, letter, Exelon Exelon Generation Generation Company, Company, LLC   LLC (EGC)
(EGC) requested requested approval approval of of relief relief requests    associated  with   the  upcoming requests associated with the upcoming Fifth              IST Interval at Dresden Fifth 1ST                 Dresden Nuclear Nuclear Power Power Station, Station, Units Units 2 2 and and 3.
3.
During During the NRC's review of the     the referenced referenceddocument, document,the   theNRC NRCfoundfoundthat thatadditional additionalinformation information was   required   to was required supportsupport   its review. The The requested information is provided in the requested     information      is provided    in the attachment attachmentto   to this this letter.
letter.
There There areare no no regulatory regulatory commitments commitments contained contained within       this letter.
within this    letter. Should Should you you have haveanyany questions questionsconcerning concerningthis thisletter, letter,or orrequire require additional additional information,        please contact information, please       contact Mitchel     Mathews at Mitchel Mathews       at (630)
(630) 657-2819.
657-2819.
Patrick Patrick R.R. Simpson Simpson Manager Manager --  - Licensing Licensing Exelon    Generation Exelon Generation Company, Company, LLC  LLC

==Attachment:==

==Attachment:==

===Response===
Response  totoNRC NRC Request Request forfor Additional AdditionalInformation Information

Attachment Response to NRC Request   Request forfor Additional Additional Information Information Page 11 of Page      of 5 RAI-RV-23H-1:
RAI-RV-23H-1 :
In Relief Relief Request Request RV-23H, RV-23H, Section Section3,3, "Applicable "ApplicableCode CodeRequirements, Requirements," notes  U notesthat thatrelief reliefisis requested from the requirements of        of the the American American Society Societyof  ofMechanical MechanicalEngineers Engineers (ASME),
(ASME),
Code of Operation and and Maintenance Maintenance of     of Nuclear Nuclear Power PowerPlants Plants (OM(OM Code),
Code), Paragraphs Paragraphs ISTC-3300, ISTC-3310, ISTC-3310, ISTC-5151 (a),       (a), (b),
(b), and (c),
(c), and ISTC*5152.
ISTC-5152. The    The ASME ASME OM   OM Code also provides provides inservice inservice testing testing requirements requirements for   for solenoid-operated solenoid-operatedvalves  valves inin ISTC ISTC5151(d) 5151(d) andand ISTC-5153. Confirm    that  no  relief is  needed     from   ISTC-5151(d)
ISTC-5153. Confirm that no relief is needed from ISTC-5151(d) and ISTC-5153.        and   ISTC-5153.
Company. LLC (EGC)
Exelon Generation Company,                     IEGC) Response:
As stated in in proposed proposed Relief Relief Request RequestRV-23H, RV-23H, the the affected affected high high pressure pressurecoolant coolant injection (HPCI) injection (HPCI)system system solenoid solenoid operated valves  valves 2(3)-2301-32 2(3)-2301-32 are    are not notequipped equippedwith with position position indicators and the   valves    are completely      enclosed;     therefore,   valve    position the valves are completely enclosed; therefore, valve position cannot be verified    cannot   be verified by direct observation.
While valve While   valve operation operation cannot be   be assessed assessedduring duringthethequarterly quarterlyexercise, exercise,EGC  EGCwillwillcomply complywith with the requirements requirementsof  ofISTC-5151(d)
ISTC-5151 (d) during during thethefunctional functional testing testingduring duringrefueling.
refueling.
ISTC-5153, EGC With regards to ISTC-5153,         EGCisisonlyonlyrequesting requestingrelief relieffrom fromthethestroke stroketiming timingrequirements requirementsinin ISTC-5153(b).
ISTC-5153(b). AllAll other   ISTC-5153       requirements ISTC-5153 requirements            will be  met    for  the  fifth IST   interval 1ST interval atat DNPS.

Attachment Response to NRC Request for Additional Information      Information Page Page 22 ofof 5 RAI-RV-23H-2:
The Section 4.0, "Reason for       for Request,       second paragraph states that, Request, " second                               that, "Compliance "Compliance with  withthe the quarterly exercising and stroke timing requirements of              of the Code Code would would require require either eithersystem system modifications to replace these valves with ones of             of testable testable design, design, or ortoto purchase purchase non-intrusive non-intrusive test equipment and  and develop develop newnew test methods methods andand procedures."
procedures." Please Please explain explain why why modifying modifying the system by replacing these valves with a testable design or                   or purchasing purchasing non-intrusive non-intrusive testtest equipment is not feasible (i.e., cost, planning or new                method new method and     and   procedure).
EGC Response:
The Dresden Nuclear Nuclear Power Station8tation (DNPS),
(DNP8), Units 2 and 3 design  design does doesnot  notinclude includeremote remotelight light indicationfor indication    forthe the2(3)-2301-32-80 2(3)-2301-32-SOvalves. valves.These These valves valves areare completely completely enclosed enclosed such that the valve position valve   position cannot cannot be verified verified by bydirect directobservation.
observation. Due to the absence  absenceof   ofaavisible visible valve valve stem and    light and light  indication,     "switch    to light"  stroke  timing    cannot "switch to light" stroke timing cannot be         be  performed.      In In addition, there addition,     there are no known reliable non-intrusive test        test methods methods forfor measuring measuring strokestroketimes timesfor forthis this valve valve configuration.
In order In  order to to perform performstroke stroketiming timingofofthese thesevalves, valves,aadesign design change change would would have to be implemented. The   Themodification modification would include:
include: (1)
(1) changing changing the valve design   design toto include include position position limit  switches,   (2)  routing   light  indication    cabling  from    the limit switches, (2) routing light indication cabling from the plant to the    plant  to the  control   room,    and   (3) and (3) installing position installing   position indication indicationlights lightsininthe themain maincontrol controlroomroompanels.
panels. ItIt is is estimated estimated that this modificationwould modification     wouldcost costininexcess excess ofof $300,000
                                                  $300,000 per unit.
unit. This This remote remotevalvevalve indication indication would would bebe installed solely for installed           for meeting meeting the American Society 80ciety of Mechanical EngineersEngineers(ASME)(A8ME) Operation Operation and Maintenance (OM)            Code requirements and would serve no (OM) Code                                                 no other other operational operational purpose.
purpose.
A semi-annual A  semi-annual exercise of the      the 2(3)-2301-32-80 2(3)-2301-32-SO valvesvalves is  is currently currently performed performed and   and its its associated associated level switches operate operate as proven by the receipt of the IIHPCI TURBINE EXH DRAIN POTHIGH as proven    by  the  receipt of  the  "HPCI      TURBINE         EXH   DRAIN       POT     HIGH LEVEL"alarm LEVEL"       alarm(Le.,
(i.e.,water waterlevel levelincrease) increase)and andreset reset(Le.,
(i.e.,water waterlevel leveldecrease decrease due due to the open exercise of valves 2(3)-2301-32-80).
2(3)-2301-32-SO). During           this same During this   same evolution, evolution, the valve solenoid is also verifiedactuated verified  actuated (Le.,
(i.e., valve valve solenoid solenoid isis magnetized) magnetized) by  by use use of aa small metal object.
object. This This testing testing approach provides reasonable reasonable assurance assurancethat thatthe thevalves valvesfunction function as asrequired.
required.

Attachment Response to NRC Request    Request for Additional Information Information Page 33 of Page      of 5 RAI-RV-23H-3:
Section 5.0, "Proposed "Proposed Alternative Alternativeand andBasisBasisforforUse, Use,"  " does does not not provide provide anyanyoperational operationalhistoryhistory (i.e., maintenance and      and reliability reliability data) data) or or note note any any failures failures of of solenoid-operated solenoid-operated valves   valves 2 2301-032 and   and 3-2301-032. Please   Pleaseprovide providedetails detailsof  ofthe the operational operational history historyandand information information regarding any failures of        of these valves for each unit. unit. Also, Also, describe describe how  how often often thethe internals internals forfor these valves have been replaced or             or repaired repaired and and note note anyany defects defects identified identified during during maintenance activities, maintenance          activities, during during the the fourth fourthten-year ten-yearinservice inservicetestingtesting(1ST)
(1ST) interval intervalat   at Dresden 2 and   and 3. 3.
EGC Response:
A   review of A review     ofthethe work workandand Inservice Inservice Testing Testing history history of ofthese these valves did  did not identify identify any any cases cases of of these valves these   valves failing failing to stroke open since since they they were were added addedto   tothe theIST 1STProgram Programscopescopeinin November 1994. EGC         EGC hashasaapreventive preventivemaintenance maintenanceactivity activity to replace these these DNPS DNPS valves valves once every every six years. The     Thevalve valveinternals internalswere werenot notrepaired repairedororreplaced replacedduring duringthe  thefourth fourthten-ten-year interval. This  This activity activity was last performed on March 11, 2013, on Unit 2,                     2, and on December 8, 2007, on Unit 3.
8,2007,                   3. No No defects defects were were noted.
noted.
RAI-RV-23H-4:
The Section 5.0, The               5.0, second paragraph, under     under "Basis "Basis for Use,"
Use, " states, in part, that, "failure"failure of of these these valves to perform their safety    safety function wouldwould be indicated indicated by    by the the drain drain pot pot high level level alarm alarm operation with low pressure steam." (1)             (1) Please Please provide provide details details of of any any consequences consequences of       of failures of the 2(3)-2301-032 valves during normal of                                                normal and and emergency emergency operations, operations, and  and (2)
(2) explain explain whatwhat actions and/or and/or procedures procedures are used   used ifif these these valves valves failfail to to perform perform their their safety safety function.
function.
EGC Response:
Ifthe If the HPCI HPCI DrainDrain Pot Pot Steam Steam Trap (i.e.,
(Le., 2(3) 2301-2) fails, then the        the HPCI HPCI drain pot   pot bypass bypassvalvevalve (i.e., 2(3)
(Le.,  2(3) 2301-32) would   would receive receive a signal to open  open to to drain drain condensation condensationto      tothe theunit's unit'sgland gland steam condenser.
condenser.IfIfboth   both2301-2 2301-2and and2301-32 2301-32fail fail to to open, open, thenthen the the exhaust exhaustdrain drain pot pot could could begin to fill,     resultingininan fill, resulting         anexhaust exhaust diaphragm rupture and turbine blade             blade and and exhaust exhaustline  linecheck check valve damage.
valve Operator actions Operator      actions are  arecurrently currentlyin in place placeininaccordance accordancewith    withDNPS DNPSProcedure ProcedureDAN    DAN902(3)-3 902(3)-3C-11C-11 trip the to trip  the HPCI        turbine ififthis HPCI turbine           thisoccurs occurs while whilethe the HPCI HPCIsystemsystem isis being being tested.
tested. IfIf an alarm alarm isis received during the     the emergency use   use ofof HPCI HPCI system, then   then manual manual traptrap bypass bypassvalvevalve 2(3) 2301-50 is opened to          to drain drain to the unit's unit's torus, andand prevent prevent HPCI HPCI system system damage.
damage.

Attachment Response to NRC Request for Additional Information         Information Page Page 44 of of 55 RAI-RV-23H-5:
RAI-RV-23H-S:
The Section 5.0, thirdthird paragraph, under    under "Basis for Use, If" states states that, that, "Following discussions discussions with with the manufacturer manufacturer regarding valve design and              and application, itit was  was decided decided to   to disassemble, disassemble, examine and repair or replace   replace these these valves valves every third third operating operating cycle.
cycle."/J Please Please provide provide (1)  (1) the the basis for this activity activity to  to be performed performed everyevery third third operating operating cycle,cycle, and and (2)
(2) the the criteria criteria for for selecting between repair repair and/or and/or replacement replacement of   of the the valve valve during during this this activity.
activity.
EGC Response:

===Response===
EGC has elected elected to to replace replace the theDNPS DNPSvalvevalve 2(3)-2301-32 2(3)~2301 ~32 on     on aasix six year yearinterval, interval, due dueto  to cost cost saving and dose concerns. The          Thesix-year six~year replacement replacement schedule schedule has   hasproven proven to to bebe adequate adequatefor   for this valve and its application application based on        on the the history history discussed discussedininthe   theresponse responsetotoRAI-RV-23H-3 RAI~RV-23H-3 above. The Thecriteria criteria for for selecting between repair    repair and/or replacement replacement of      of the valve are based basedon   on performance, cost of repair    repair versus versus replacement and dose        doseconcerns.
concerns.
RAI-RV-02C-1 RAI-RV-02C-1 Will the alternative to ASME  ASME OM   OM Code Code Mandatory MandatoryAppendix Appendix1,I, Section Section 1-1320,         proposed by 1-1320, proposed          by Relief Relief Request Request RV-02C for testing of           of the Dresden Dresden UnitsUnits 22 && 33 Main Main Steam Steam Safety Safety Valves (MSSVs) fully meet      meet all requirements of ASME OM Code Case OMN-17? For                              Forinstance, instance, the referenced letter mentions compliance with OMN-17                           paragraphs        (a),  (b),
OMN-17 paragraphs (a), (b), and (d) but     and   (d) but contains contains no no information information regarding regarding compliance compliancewith  withparagraphs paragraphs(c)     (c)and and(e).(e).
EGC Response:

===Response===
Paragraph (c) of    of Code Code Case  Case OMN-17 OMN-17 states:
states:
(c) Requirements Requirements for      for Testing Testing Additional AdditionalValves.
Valves. Additional valves   valves shall shall bebe tested tested in in accordance accordance with  with thethe following following requirements.
requirements.
(1) For each each valve valve tested tested for for which the as-found set-pressure set-pressure(first  (first test testactuation) actuation) exceeds exceedsthe     thegreater greaterofofeither eitherthetheplus/minus plus/minustolerance tolerancelimitlimitofofthe theOwner Owner--
established established set-pressure set-pressureacceptance acceptancecriteria criteriaoror+/-3%+/-SOloof of valve valve nameplate nameplateset-   set-pressure,       two   additional pressure, two additional            valves   shall    be tested     from    the  same be tested from the same valve group.valve    group.
(2) If    the as-found set-pressure If the                  set-pressure of  ofany anyof of the theadditional additional valves valves tested testedinin accordance accordancewith     with subpara.
subpara. (c)(1)
(c)(1) exceeds exceedsthe    thecriteria criterianoted notedtherein, therein,thenthenallall remaining valves of that       that same valve group shall be          be tested.
tested.
(3) The The OwnerOwner shall evaluate the cause     causeand  andeffect effectononsystem systemcapability capability of of valves valves that fail     to comply      with  the  set-pressure      acceptance       criteria fail to comply with the set-pressure acceptance criteria established in         established      in subpara. (c)(1),(c)(1), oror the acceptance acceptancecriteria criteria for for other required required teststests (e.g.,
(e.g.,
acceptance acceptanceofofauxiliaryauxiliary actuating devices, devices,compliance compliancewith   with Owner's Owner's seat seat tightness tightnesscriteria).
criteria). Based Based upon upon this this evaluation, to address any generic concerns,          concerns,

Attachment Response to NRC Request for Additional Information Information Page 55 of Page      of 5 the Owner shall determine determine the the need needforfortesting testingininaddition addition toto the theminimum minimum tests tests specified.
EGC will    comply with will comply    with paragraph paragraph (c)
(c) of of Code CodeCaseCaseOMN-17 OMN-17during duringthethefifth fifthIST 1STinterval.
interval.
Paragraph (e) of Code Case OMN-17 states:
(e) Disassembly and  and Inspection.
Inspection. Each valve valve shall shall have have been been disassembled and inspected in in accordance accordance with with subpara.
subpara. (d)(d) above aboveprior prior to to the the start start of of the the 72-mo 72-mo test test interval. Disassembly and  and inspection inspection performed performed prior prior to to the the implementation implementation of    of this Code Code Case may be used.
EGC removes a partial EGC                 partial complement of the DNPS MSSVs each refueling      refueling outage and ships  ships them them to an ASME ASME OM       Code-certified vendor to perform as-found testing prior OM Code-certified                                                  prior to resumption of    of electric electric power generation. The  Thevendor vendoralso alsoperforms performsthe theinspection, inspection,refurbishment, refurbishment,and     andas-left as-lefttesting testing that meet meet the the maintenance maintenancerequirements requirementsspecified specifiedininsubparagraph subparagraph(d)   (d)ofofOMN-17.
OMN-17. All  All MSSVs MSSVs for each for each unit   are refurbished unit are refurbished ininthis thismanner mannerevery every72  72months.
months. For For these these reasons, the proposed proposed alternative complies withwith paragraph paragraph (e)(e)of of Code CodeCase CaseOMN-1 OMN-17. 7.}}