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| | number = ML16029A343 | | | number = ML16029A343 |
| | issue date = 02/03/2016 | | | issue date = 02/03/2016 |
| | title = Dresden Nuclear Power Station, Units 2 & 3; LaSalle County Station, Units 1 & 2; & Quad Cities Nuclear Power Station, Units 1 & 2 - Recent Amendments Adding Technical Specification 3.10.8, Inservice Leak and Hydrostatic Testing Operations. | | | title = Recent Amendments Adding Technical Specification 3.10.8, Inservice Leak and Hydrostatic Testing Operations. |
| | author name = Purnell B A | | | author name = Purnell B |
| | author affiliation = NRC/NRR/DORL/LPLIII-2 | | | author affiliation = NRC/NRR/DORL/LPLIII-2 |
| | addressee name = Hanson B C | | | addressee name = Hanson B |
| | addressee affiliation = Exelon Generation Co, LLC | | | addressee affiliation = Exelon Generation Co, LLC |
| | docket = 05000237, 05000249, 05000254, 05000265, 05000373, 05000374 | | | docket = 05000237, 05000249, 05000254, 05000265, 05000373, 05000374 |
| | license number = DPR-019, DPR-025, DPR-029, DPR-030, NPF-011, NPF-018 | | | license number = DPR-019, DPR-025, DPR-029, DPR-030, NPF-011, NPF-018 |
| | contact person = Purnell B A | | | contact person = Purnell B |
| | case reference number = CAC MF5471, CAC MF5472, CAC MF5473, CAC MF5474, CAC MF5475, CAC MF5476 | | | case reference number = CAC MF5471, CAC MF5472, CAC MF5473, CAC MF5474, CAC MF5475, CAC MF5476 |
| | document type = Letter | | | document type = Letter |
| | page count = 3 | | | page count = 3 |
| | project = CAC:MF5471, CAC:MF5472, CAC:MF5473, CAC:MF5474, CAC:MF5475, CAC:MF5476 | | | project = CAC:MF5471, CAC:MF5472, CAC:MF5473, CAC:MF5474, CAC:MF5475, CAC:MF5476 |
| | stage = | | | stage = Other |
| }} | | }} |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:Mr. Bryan C. Hanson Senior Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 3, 2016 Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO) Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 -RECENT AMENDMENTS ADDING TECHNICAL SPECIFICATION 3.10.8, "INSERVICE LEAK AND HYDROSTATIC TESTING OPERATIONS" Dear Mr. Hanson: On December 17, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15324A439), the U.S. Nuclear Regulatory Commission (NRC) issued the following amendments: 1. Amendment No. 248 to Renewed Facility Operating License No. DPR-19 and Amendment No. 241 to Renewed Facility Operating License No. DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively, 2. Amendment No. 219 to Facility Operating License No. NPF-11 and Amendment No. 205 to Facility Operating License No. NPF-18 for the LaSalle County Station (LSCS), Units 1 and 2, respectively, and 3. Amendment No. 261 to Renewed Facility Operating License No. DPR-29 and Amendment No. 256 to Renewed Facility Operating License No. DPR-30 for the Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively. The amendments added a new technical specification, Section 3.10.8, "lnservice Leak and Hydrostatic Testing Operation," including a new limiting condition for operation (LCO). After issuance of the amendments, Exelon Generation Company, LLC (Exelon, the licensee) informed the NRC staff of an issue with the underlined portion of the following paragraph from page 8 of the associated safety evaluation (SE): Prior to use of the special operation LCO 3.10.8 for the inservice leakage and hydrostatic testing of the RCS [reactor coolant system]. all main steam isolation valves and the primary containment isolation valves connected to RCS should be in their fully closed position, even though the primary containment is inoperable. Therefore, if there is a main steam line break in the secondary containment during use of the LCO, the resulting conditions inside and outside the secondary containment are bounded by the conditions resulting from a large main steam line break inside the secondary containment in Mode 1 described in UFSAR [updated final safety analysis report] Section 15.6.4 (for all six plants) because the SGTS [standby gas treatment system] and secondary containment are B. Hanson -2 -operable for all six plants. Based on this, the NRC staff finds the proposed LCO 3.10.8 acceptable to the extent that GDC [general design criterion]-16 for LSCS and draft GDC-10 for DNPS and QCNPS would continue to be satisfied. The NRC staff discussed this issue with Exelon personnel during a call on January 28, 2016. Exelon explained that some of the isolation valves are open or bypassed during testing to maintain shutdown cooling capability or to facilitate the 10-year extended boundary test of the reactor coolant system. As discussed in the license amendment request and reinforced by Exelon during the call, the plant conditions and conservatisms in the main steam line break analysis (UFSAR Section 15.6.4) envelope the expected conditions during testing. Exelon stated that its UFSAR Section 15.6.4 analysis assumed full power operations and did not take credit for secondary containment and the SGTS. Under the test conditions, the reactor is not operating and the RCS has a lower temperature thus any break would result in a smaller source term. Furthermore, LCO 3.10.8 requires that secondary containment and the SGTS are operable such that any radioactive release would be reduced due to holdup within secondary containment and filtration through the SGTS. The NRC staff considered the potential for some of the isolation valves to be open or bypassed during testing and determined that this does not alter the staff's finding in the SE that the UFSAR Section 15.6.4 analysis bounds the consequences of a pipe break in the primary system under the test conditions. Therefore, the staff's conclusions in the SE are not affected. The staff does not expect the licensee to change how it performs its testing to conform to the above statement. If you have any questions, please contact me at 301-415-1380. Docket Nos. 50-237, 50-249, 50-373, 50-374, 50-254, and 50-265 cc: Distribution via Listserv Sincerely, Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation B. Hanson -2 -operable for all six plants. Based on this, the NRC staff finds the proposed LCO 3.10.8 acceptable to the extent that GDC [general design criterion]-16 for LSCS and draft GDC-10 for DNPS and QCNPS would continue to be satisfied. The NRC staff discussed this issue with Exelon personnel during a call on January 28, 2016. Exelon explained that some of the isolation valves are open or bypassed during testing to maintain shutdown cooling capability or to facilitate the 10-year extended boundary test of the reactor coolant system. As discussed in the license amendment request and reinforced by Exelon during the call, the plant conditions and conservatisms in the main steam line break analysis (UFSAR Section 15.6.4) envelope the expected conditions during testing. Exelon stated that its UFSAR Section 15.6.4 analysis assumed full power operations and did not take credit for secondary containment and the SGTS. Under the test conditions, the reactor is not operating and the RCS has a lower temperature thus any break would result in a smaller source term. Furthermore, LCO 3.10.8 requires that secondary containment and the SGTS are operable such that any radioactive release would be reduced due to holdup within secondary containment and filtration through the SGTS. The NRC staff considered the potential for some of the isolation valves to be open or bypassed during testing and determined that this does not alter the staff's finding in the SE that the UFSAR Section 15.6.4 analysis bounds the consequences of a pipe break in the primary system under the test conditions. Therefore, the staff's conclusions in the SE are not affected. The staff does not expect the licensee to change how it performs its testing to conform to the above statement. If you have any questions, please contact me at 301-415-1380. Sincerely, /RAJ Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-373, 50-374, 50-254, and 50-265 cc: Distribution via Listserv DISTRIBUTION: PUBLIC LPL 3-2 R/F RidsNrrDssSrxb Resource RidsNrrDssStsb Resource RidsNrrDorlLpl3-2 Resource RidsRgn3MailCenter Resource RidsAcrs_MailCTR Resource RidsNrrPmExelon Resource RidsNrrDssScvb Resource RidsNrrDraArcb Recource RidsNrrPMDresden Resource RidsNrrPMLaSalle Resource ADAMS Accession N o: ML 16029A343 OFFICE LPL3-2/PM LPL3-2/LA SCVB/BC NAME BPurnell SRohrer RDennig* DATE 2/03/2016 2/01/2016 2/03/2016 RidsNrrPMQuadCities Resource RidsNrrMailCenter Resource RidsNrrLASRohrer Resource JBorromeo, NRR ASallman, NRR NKaripineni, NRR *b *1 1y e-ma1 LPL3-2/BC(A) LPL3-2/PM JPoole BPurnell 2/03/2016 2/03/2016 OFFICIAL RECORD COPY | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 3, 2016 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO) |
| }} | | Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 |
| | |
| | ==SUBJECT:== |
| | DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - RECENT AMENDMENTS ADDING TECHNICAL SPECIFICATION 3.10.8, "INSERVICE LEAK AND HYDROSTATIC TESTING OPERATIONS" |
| | |
| | ==Dear Mr. Hanson:== |
| | |
| | On December 17, 2015 (Agencywide Documents Access and Management System (ADAMS) |
| | Accession No. ML15324A439), the U.S. Nuclear Regulatory Commission (NRC) issued the following amendments: |
| | : 1. Amendment No. 248 to Renewed Facility Operating License No. DPR-19 and Amendment No. 241 to Renewed Facility Operating License No. DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively, |
| | : 2. Amendment No. 219 to Facility Operating License No. NPF-11 and Amendment No. 205 to Facility Operating License No. NPF-18 for the LaSalle County Station (LSCS), Units 1 and 2, respectively, and |
| | : 3. Amendment No. 261 to Renewed Facility Operating License No. DPR-29 and Amendment No. 256 to Renewed Facility Operating License No. DPR-30 for the Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively. |
| | The amendments added a new technical specification, Section 3.10.8, "lnservice Leak and Hydrostatic Testing Operation," including a new limiting condition for operation (LCO). After issuance of the amendments, Exelon Generation Company, LLC (Exelon, the licensee) informed the NRC staff of an issue with the underlined portion of the following paragraph from page 8 of the associated safety evaluation (SE): |
| | Prior to use of the special operation LCO 3.10.8 for the inservice leakage and hydrostatic testing of the RCS [reactor coolant system]. all main steam isolation valves and the primary containment isolation valves connected to RCS should be in their fully closed position, even though the primary containment is inoperable. |
| | Therefore, if there is a main steam line break in the secondary containment during use of the LCO, the resulting conditions inside and outside the secondary containment are bounded by the conditions resulting from a large main steam line break inside the secondary containment in Mode 1 described in UFSAR |
| | [updated final safety analysis report] Section 15.6.4 (for all six plants) because the SGTS [standby gas treatment system] and secondary containment are |
| | |
| | B. Hanson operable for all six plants. Based on this, the NRC staff finds the proposed LCO 3.10.8 acceptable to the extent that GDC [general design criterion]-16 for LSCS and draft GDC-10 for DNPS and QCNPS would continue to be satisfied. |
| | The NRC staff discussed this issue with Exelon personnel during a call on January 28, 2016. |
| | Exelon explained that some of the isolation valves are open or bypassed during testing to maintain shutdown cooling capability or to facilitate the 10-year extended boundary test of the reactor coolant system. |
| | As discussed in the license amendment request and reinforced by Exelon during the call, the plant conditions and conservatisms in the main steam line break analysis (UFSAR Section 15.6.4) envelope the expected conditions during testing. Exelon stated that its UFSAR Section 15.6.4 analysis assumed full power operations and did not take credit for secondary containment and the SGTS. Under the test conditions, the reactor is not operating and the RCS has a lower temperature thus any break would result in a smaller source term. Furthermore, LCO 3.10.8 requires that secondary containment and the SGTS are operable such that any radioactive release would be reduced due to holdup within secondary containment and filtration through the SGTS. |
| | The NRC staff considered the potential for some of the isolation valves to be open or bypassed during testing and determined that this does not alter the staff's finding in the SE that the UFSAR Section 15.6.4 analysis bounds the consequences of a pipe break in the primary system under the test conditions. Therefore, the staff's conclusions in the SE are not affected. |
| | The staff does not expect the licensee to change how it performs its testing to conform to the above statement. If you have any questions, please contact me at 301-415-1380. |
| | Sincerely, Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-373, 50-374, 50-254, and 50-265 cc: Distribution via Listserv |
| | |
| | ML16029A343 *b1y e-ma1*1 OFFICE LPL3-2/PM LPL3-2/LA SCVB/BC LPL3-2/BC(A) LPL3-2/PM NAME BPurnell SRohrer RDennig* JPoole BPurnell DATE 2/03/2016 2/01/2016 2/03/2016 2/03/2016 2/03/2016}} |
Letter Sequence Other |
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CAC:MF5471, Use of TS 3.10.1 for SCRAM Time Testing Activities (Approved, Closed) CAC:MF5472, Use of TS 3.10.1 for SCRAM Time Testing Activities (Approved, Closed) CAC:MF5473, Use of TS 3.10.1 for SCRAM Time Testing Activities (Approved, Closed) CAC:MF5474, Use of TS 3.10.1 for SCRAM Time Testing Activities (Approved, Closed) CAC:MF5475, Use of TS 3.10.1 for SCRAM Time Testing Activities (Approved, Closed) CAC:MF5476, Use of TS 3.10.1 for SCRAM Time Testing Activities (Approved, Closed) |
|
MONTHYEARML15324A4392015-12-17017 December 2015 Issuance of Amendments (CAC Nos. MF5471-MF5476) Project stage: Approval ML16029A3432016-02-0303 February 2016 Recent Amendments Adding Technical Specification 3.10.8, Inservice Leak and Hydrostatic Testing Operations. Project stage: Other 2015-12-17
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Category:Letter
MONTHYEARIR 05000237/20240022024-08-14014 August 2024 Integrated Inspection Report 05000237/2024002 and 05000249/2024002 IR 05000373/20240022024-08-13013 August 2024 County Station - Integrated Inspection Report 05000373/2024002 and 05000374/2024002 ML24222A6772024-08-0909 August 2024 Response to Request for Additional Information for Application to Revise Technical Specifications to Adopt TSTF-591-A, “Revise Risk Informed Completion Time (RICT) Program” Revision 0 and Revise 10 CFR 50.69 License Condition IR 05000237/20240102024-08-0909 August 2024 NRC Age-Related Degradation Inspection Report 05000237/2024010 and 05000249/2024010 ML24183A1082024-08-0808 August 2024 – Issuance of Amendment Nos. 302 and 298 Adoption of Tstf-505, Provide Risk Informed Extended Completion Times – RITSTF Initiative 4b SVP-24-049, Owners Activity Report Submittal Sixth 10-Year Interval 2024 Refueling Outage Activities2024-08-0707 August 2024 Owners Activity Report Submittal Sixth 10-Year Interval 2024 Refueling Outage Activities IR 05000237/20230112024-08-0707 August 2024 Reissue - Dresden Nuclear Power Station, Units 2 and 3 Comprehensive Engineering Team Inspection Report 05000237/2023011 and 05000249/2023011 IR 05000237/20200012024-08-0606 August 2024 Reissue - Dresden Nuclear Power Station, Units 2 and 3 - Integrated Inspection Report 05000237/2020001 and 05000249/2020001 IR 05000373/20244202024-08-0505 August 2024 County Station - Security Baseline Inspection Report 05000373 2024420 and 05000374 2024420 ML24184A1712024-08-0202 August 2024 SLRA Schedule Letter IR 05000254/20243012024-08-0101 August 2024 NRC Initial License Examination Report 05000254/2024301; 05000265/2024301 SVP-24-048, Registration of Use of Casks to Store Spent Fuel2024-07-31031 July 2024 Registration of Use of Casks to Store Spent Fuel RS-24-073, Alternative Schedule to Complete Decommissioning Beyond 60 Years of Permanent Cessation of Operations – Additional Information Supporting Request to Withhold Security-Related Information2024-07-31031 July 2024 Alternative Schedule to Complete Decommissioning Beyond 60 Years of Permanent Cessation of Operations – Additional Information Supporting Request to Withhold Security-Related Information ML24136A1322024-07-30030 July 2024 Transmittal Letter for Renewed License ML24208A0962024-07-25025 July 2024 57243-EN 57243 - Rssc Wire & Cable LLC, Dba Marmon - Part 21 Notification ML24193A0882024-07-24024 July 2024 Request for Withholding Information from Public Disclosure for Dresden Nuclear Power Station, Unit 1 Alternative Schedule to Complete Decommissioning Beyond 60-Years of Permanent Cessation of Operations (Docket 50-10) ML24204A1862024-07-24024 July 2024 – Regulatory Audit in Support of License Amendment Requests to Adopt TSTF 505, Revision 2; TSTF-591, Revision 0; and 10 CFR 50.69 RS-24-070, Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, Quad Cities, Units 1 and 2, R. E. Ginna - Nuclear Radiological Emergency Plan Document Revisions2024-07-12012 July 2024 Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, Quad Cities, Units 1 and 2, R. E. Ginna - Nuclear Radiological Emergency Plan Document Revisions SVP-24-041, Regulatory Commitment Change Summary Report2024-07-0505 July 2024 Regulatory Commitment Change Summary Report SVP-24-043, Registration of Use of Casks to Store Spent Fuel2024-07-0505 July 2024 Registration of Use of Casks to Store Spent Fuel ML24162A0982024-07-0303 July 2024 – Issuance of Amendment Nos. 301 and 297 Adoption of 10 CFR 50.69 “Risk Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors” RS-24-064, Nuclear Radiological Emergency Plan Document Revisions2024-06-28028 June 2024 Nuclear Radiological Emergency Plan Document Revisions ML24178A2522024-06-27027 June 2024 County Station – Acknowledgement of Response to NRC Inspection Report 05000373/2024001 and 05000374/2024001 and Disputed Non-Cited Violation IR 05000237/20243012024-06-27027 June 2024 NRC Initial License Examination Report 05000237/2024301; 05000249/2024301 ML24138A0572024-06-26026 June 2024 – Issuance of Amendment Nos. 285 and 278 Application to Adopt TSTF-564, “Safety Limit Mcpr” SVP-24-040, Registration of Use of Casks to Store Spent Fuel2024-06-25025 June 2024 Registration of Use of Casks to Store Spent Fuel ML24138A1812024-06-18018 June 2024 Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review ML24128A2742024-06-14014 June 2024 Notice of Acceptance and Opportunity for Hearing - Letter RS-24-063, Response to Request for Additional Information for 10 CFR 50.55a Request No. I5R-222024-06-14014 June 2024 Response to Request for Additional Information for 10 CFR 50.55a Request No. I5R-22 RS-24-061, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations2024-06-14014 June 2024 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations SVP-24-039, Ile Post Exam Package Letter2024-06-12012 June 2024 Ile Post Exam Package Letter ML24156A2332024-06-11011 June 2024 Letter Supplemental Information for Alternative Schedule to Complete Decommissioning Beyond 60-Years of Permanent Cessation of Operations RS-24-053, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed2024-06-0606 June 2024 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities SVPLTR 24-0020, Registration of Use of Casks to Store Spent Fuel2024-05-30030 May 2024 Registration of Use of Casks to Store Spent Fuel ML24183A2752024-05-30030 May 2024 Registration of Use of Casks to Store Spent Fuel IR 05000373/20240102024-05-29029 May 2024 County Station - Commercial Grade Dedication Inspection Report 05000373/2024010 and 05000374/2024010 ML24110A0492024-05-28028 May 2024 Audit Report Related to the TSTF-505 and 10 CFR 50.59 Amendments RS-24-056, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors2024-05-28028 May 2024 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML24079A0762024-05-23023 May 2024 Issuance of Amendments to Adopt TSTF 264 ML24145A0432024-05-23023 May 2024 Registration of Use of Casks to Store Spent Fuel 10 CFR 72.212 SVPLTR 24-0019, Registration of Use of Casks to Store Spent Fuel2024-05-23023 May 2024 Registration of Use of Casks to Store Spent Fuel ML24158A0012024-05-22022 May 2024 License Amendment Request to Adopt TSTF-564 (EPID L-2023-LLA-0120) Illinois State Concurrence ML24142A3352024-05-21021 May 2024 Quad Cities—Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes ML24141A2102024-05-20020 May 2024 Operator Licensing Examination Approval - Quad Cities Nuclear Power Station, May 2024 RS-24-055, 2023 Corporate Regulatory Commitment Change Summary Report2024-05-17017 May 2024 2023 Corporate Regulatory Commitment Change Summary Report IR 05000254/20240012024-05-14014 May 2024 Integrated Inspection Report Nos. 05000254/2024001 and 05000265/2024001 IR 05000373/20240012024-05-13013 May 2024 County Station - Integrated Report 05000373/2024001 and 05000374/2024001 RS-24-042, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion2024-05-10010 May 2024 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion SVP-24-034, Annual Radiological Environmental Operating Report2024-05-10010 May 2024 Annual Radiological Environmental Operating Report 2024-08-09
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Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 3, 2016 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - RECENT AMENDMENTS ADDING TECHNICAL SPECIFICATION 3.10.8, "INSERVICE LEAK AND HYDROSTATIC TESTING OPERATIONS"
Dear Mr. Hanson:
On December 17, 2015 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML15324A439), the U.S. Nuclear Regulatory Commission (NRC) issued the following amendments:
- 1. Amendment No. 248 to Renewed Facility Operating License No. DPR-19 and Amendment No. 241 to Renewed Facility Operating License No. DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively,
- 2. Amendment No. 219 to Facility Operating License No. NPF-11 and Amendment No. 205 to Facility Operating License No. NPF-18 for the LaSalle County Station (LSCS), Units 1 and 2, respectively, and
- 3. Amendment No. 261 to Renewed Facility Operating License No. DPR-29 and Amendment No. 256 to Renewed Facility Operating License No. DPR-30 for the Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, respectively.
The amendments added a new technical specification, Section 3.10.8, "lnservice Leak and Hydrostatic Testing Operation," including a new limiting condition for operation (LCO). After issuance of the amendments, Exelon Generation Company, LLC (Exelon, the licensee) informed the NRC staff of an issue with the underlined portion of the following paragraph from page 8 of the associated safety evaluation (SE):
Prior to use of the special operation LCO 3.10.8 for the inservice leakage and hydrostatic testing of the RCS [reactor coolant system]. all main steam isolation valves and the primary containment isolation valves connected to RCS should be in their fully closed position, even though the primary containment is inoperable.
Therefore, if there is a main steam line break in the secondary containment during use of the LCO, the resulting conditions inside and outside the secondary containment are bounded by the conditions resulting from a large main steam line break inside the secondary containment in Mode 1 described in UFSAR
[updated final safety analysis report] Section 15.6.4 (for all six plants) because the SGTS [standby gas treatment system] and secondary containment are
B. Hanson operable for all six plants. Based on this, the NRC staff finds the proposed LCO 3.10.8 acceptable to the extent that GDC [general design criterion]-16 for LSCS and draft GDC-10 for DNPS and QCNPS would continue to be satisfied.
The NRC staff discussed this issue with Exelon personnel during a call on January 28, 2016.
Exelon explained that some of the isolation valves are open or bypassed during testing to maintain shutdown cooling capability or to facilitate the 10-year extended boundary test of the reactor coolant system.
As discussed in the license amendment request and reinforced by Exelon during the call, the plant conditions and conservatisms in the main steam line break analysis (UFSAR Section 15.6.4) envelope the expected conditions during testing. Exelon stated that its UFSAR Section 15.6.4 analysis assumed full power operations and did not take credit for secondary containment and the SGTS. Under the test conditions, the reactor is not operating and the RCS has a lower temperature thus any break would result in a smaller source term. Furthermore, LCO 3.10.8 requires that secondary containment and the SGTS are operable such that any radioactive release would be reduced due to holdup within secondary containment and filtration through the SGTS.
The NRC staff considered the potential for some of the isolation valves to be open or bypassed during testing and determined that this does not alter the staff's finding in the SE that the UFSAR Section 15.6.4 analysis bounds the consequences of a pipe break in the primary system under the test conditions. Therefore, the staff's conclusions in the SE are not affected.
The staff does not expect the licensee to change how it performs its testing to conform to the above statement. If you have any questions, please contact me at 301-415-1380.
Sincerely, Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-373, 50-374, 50-254, and 50-265 cc: Distribution via Listserv
ML16029A343 *b1y e-ma1*1 OFFICE LPL3-2/PM LPL3-2/LA SCVB/BC LPL3-2/BC(A) LPL3-2/PM NAME BPurnell SRohrer RDennig* JPoole BPurnell DATE 2/03/2016 2/01/2016 2/03/2016 2/03/2016 2/03/2016