ML17200A088

Draft RAI for QC LAR Re Permanent Extension of Type a and Type C Leak Rate Testing Frequencies

ML17200A088
Person / Time
Site:	Quad Cities
Issue date:	07/07/2017
From:	Kimberly Green Plant Licensing Branch III
To:	Mathews M Exelon Generation Co
References
DPR-29, DPR-30
Download: ML17200A088 (4)

Text

NRR-PMDAPEm Resource From: Green, Kimberly Sent: Friday, July 07, 2017 12:01 PM To: Mathews, Mitchel A:(GenCo-Nuc)

Subject:

Draft RAI for QC LAR re Permanent Extension of Type A and Type C Leak Rate Testing Frequencies Attachments: Quad Cities Draft RAI Set 2.docx

Dear Mr. Mathews:

By letter dated April 27, 2017, Exelon Generation Company, LLC (EGC), submitted an amendment request for Quad Cities Nuclear Power Station, Units 1 and 2 (Agencywide Documents Access and Management System Accession No. ML17121A449). The proposed amendment would modify Technical Specification 5.5.12, Primary Containment Leakage Rate Testing Program, to allow for the permanent extension of the Type A Integrated Leak Rate Testing and Type C Leak Rate Testing frequencies.

The U.S Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified areas where additional information is needed to complete its review. Attached, please find a draft request for additional information (RAI).

The draft RAI is being sent to ensure that the questions are understandable and the regulatory basis for the questions is clear. This email and the attachment do not convey or represent an NRC staff position regarding EGC's request.

Please note that the draft requests are numbered 7 and 8. An RAI with requests 1 through 6 were previously transmitted to you by letter dated June 29, 2017.

Please let me know if you need a call to clarify the NRC staffs requests.

Sincerely, Kimberly Green, Sr. Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation (301) 415-1627 kimberly.green@nrc.gov 1

Hearing Identifier: NRR_PMDA Email Number: 3612 Mail Envelope Properties (Kimberly.Green@nrc.gov20170707120000)

Subject:

Draft RAI for QC LAR re Permanent Extension of Type A and Type C Leak Rate Testing Frequencies Sent Date: 7/7/2017 12:00:49 PM Received Date: 7/7/2017 12:00:00 PM From: Green, Kimberly Created By: Kimberly.Green@nrc.gov Recipients:

"Mathews, Mitchel A:(GenCo-Nuc)" <Mitchel.Mathews@exeloncorp.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1425 7/7/2017 12:00:00 PM Quad Cities Draft RAI Set 2.docx 34996 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION EXELON GENERATION COMPANY, LLC QUAD CITIES NUCLEAR POWER STATION (QCNPS), UNITS 1 AND 2 DOCKET NOS. 50-254 and 50-265 By letter dated April 27, 2017, Exelon Generation Company, LLC (EGC), submitted a license amendment request (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17121A449). The proposed amendment would modify Technical Specification 5.5.12, Primary Containment Leakage Rate Testing Program, to allow for the permanent extension of the Type A Integrated Leak Rate Testing and Type C Leak Rate Testing frequencies. The additional information below is needed to support the Nuclear Regulatory (NRC) staffs continued technical review of the license amendment request (LAR).

RAI 7

Background Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix J, Option B, requires a general visual inspection of the containment prior to each Type A test and at a periodic interval between tests. Nuclear Energy Institute 94-01, Revision 3-A, recommends these inspections be performed in conjunction with the American Society of Mechanical Engineers (ASME) Code,Section XI, Subsection IWE required examinations. Section 3.5.2 of the LAR indicates that QCNPS will use the required ASME Code examinations to meet the Appendix J requirement regarding visual inspections.

The regulation at 10 CFR 50.55a(b)(2)(ix)(A) imposes a condition on the use of ASME Code,Section XI, Subsection IWE, which requires licensees to evaluate the acceptability of inaccessible metal containment areas when conditions exist in accessible areas that could indicate the presence of, or result in degradation to, such inaccessible areas.

Issue Table 3.5-3 of the LAR summarizes the results of the ASME Section XI, Subsection IWE metal containment inspections performed over the last three outages. The table notes that both units have identified recordable indications on the moisture barrier; however, no discussion is provided regarding the containment behind the moisture barrier. A degraded moisture barrier could indicate the presence of degradation in the inaccessible areas behind the moisture barrier.

It is not clear to the staff how EGC determined that the degraded moisture barrier did not allow moisture to contact the containment and cause degradation in an inaccessible area.

Request Summarize the results of any 10 CFR 50.55a(b)(2)(ix)(A) evaluations associated with noted moisture barrier indications, or explain how EGC determined that the inaccessible portions of the containment were not impacted and that an evaluation was not necessary.

RAI 8

Background Appendix J to 10 CFR 50, Option B, requires a general visual inspection of the containment prior to each Type A test and at a periodic interval between tests for indications of structural deterioration that may impact leak-tightness. Section 3.6.5 of the LAR notes that inspections of the sand pocket region and drywell liner area are conducted at QCNPS during each refueling outage. Table 3.6.5-1 of the LAR summarizes the results of the last two inspections.

Issue Table 3.6.5-1 Note (2) of the LAR, related to Unit 1, states that there is leakage but that the leakage is not from the drains and appears to be groundwater leakage with no structural impact.

Note (4), related to Unit 2, also indicates issues with groundwater leakage. From the notes, it appears the leakage is an ongoing issue.

It is not clear to the staff how EGC determined that the leakage is groundwater and that the leakage is not impacting the structural integrity or leak-tightness of the containment.

Request For both units, explain how EGC determined that the identified leakage is groundwater and that the leakage is not impacting the structural integrity or leak-tightness of the containment.