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| | number = ML17065A162 | | | number = ML17065A162 |
| | issue date = 03/14/2017 | | | issue date = 03/14/2017 |
| | title = Nine Mile Point Nuclear Station, Units 1 and 2 - Request for Additional Information Regarding Proposed Alternative to Perform Pressure Isolation Valve Leakage Testing at Frequencies Consistent with 10 CFR Part 50, Appendix J (CAC Nos. MF907 | | | title = Request for Additional Information Regarding Proposed Alternative to Perform Pressure Isolation Valve Leakage Testing at Frequencies Consistent with 10 CFR Part 50, Appendix J |
| | author name = Marshall M L | | | author name = Marshall M |
| | author affiliation = NRC/NRR/DORL/LPLI | | | author affiliation = NRC/NRR/DORL/LPLI |
| | addressee name = Hanson B C | | | addressee name = Hanson B |
| | addressee affiliation = Exelon Nuclear | | | addressee affiliation = Exelon Nuclear |
| | docket = 05000220, 05000410 | | | docket = 05000220, 05000410 |
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| | page count = 4 | | | page count = 4 |
| | project = CAC:MF9073, CAC:MF9074 | | | project = CAC:MF9073, CAC:MF9074 |
| | | stage = RAI |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 March 14, 2017 SUBJECT: NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 -REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ALTERNATIVE REQUEST NUMBER GVRR-3 TO PERFORM PRESSURE ISOLATION VALVE LEAKAGE TESTING AT FREQUENCIES CONSISTENT WITH TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50, APPENDIX J (CAC NOS. MF9073 AND MF9074) Dear Mr. Hanson: By letter dated December 27, 2017 (Agencywide Documents Access and Management System Accession No. ML 17003A096), Exelon Generation Company, LLC (the licensee) submitted a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) for a proposed alternative to the requirements of 10 CFR 50.55a and the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for Nine Mile Point Nuclear Station, Units 1 and 2. The proposed alternative would allow the licensee to perform pressure isolation valve leakage testing at frequencies consistent with 10 CFR Part 50, Appendix J, primary reactor containment leakage testing performance-based requirements. The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in your application and determined that additional information is needed to complete its review. Enclosed is our Request for Additional Information (RAI). The RAI was discussed with your staff on March 13, 2017, and it was agreed that your response would be provided within 30 days from the date of this letter. Docket Nos. 50-220 and 50-410 Enclosure: Request for Additional Information cc: Distribution via Listserv Sincerely, Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION PROPOSED ALTERNATIVE REQUEST NUMBER GVRR-3 FOR THE INSERVICE TESTING PROGRAM FOURTH AND THIRD 10-YEAR INTERVALS NINE MILE POINT NUCLEAR STATION, LLC EXELON GENERATION COMPANY, LLC NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-220 AND 50-410 By letter dated December 27, 2017 (Agencywide Documents Access and Management System Accession No. ML 17003A096), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) for a proposed alternative to the requirements of 10 CFR 50.55a and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code for Nine Mile Point Nuclear Station, Units 1 and 2 (NMP1 and NMP2). The Proposed Alternative Request Number GVRR-3 would allow the licensee to perform pressure isolation valve (PIV) leakage testing at frequencies consistent with the 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors,'' reactor containment leakage testing performance-based requirements. The licensee has proposed an alternative test in lieu of the requirements found in the 2004 Edition of the ASME Operation and Maintenance (OM) Code Section ISTC-3630(a) for 35 PIVs. The licensee proposes to functionally test and verify the leakage rate of these PIVs using 10 CFR Part 50, Appendix J, Option B, performance-based schedule. Valves would initially be tested at the required interval schedule, which is currently every refueling outage (RFO), or 2 years, as specified by ASME OM Code, Section ISTC-3630(a). Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended. Any PIV leakage test failure would require the component to return to the initial interval of every RFO, or 2 years, until good performance can again be established. In its proposed alternative, Exelon states that the extension of test frequencies will be consistent with the guidance provided for Appendix J, Type C, leak rate tests as detailed in NEI 94-01, Revision 2-A, "Industry Guidelines for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,'' paragraph 10.2.3.2, "Extended Test Interval" (ADAMS Accession No. ML 100620847), which states that, "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" (see page 10 of proposed alternative). Also, the licensee states that it proposes to perform PIV testing at intervals ranging from every refueling outage to every third refueling outage (see page 3 of proposed alternative). The U.S. Nuclear Regulatory Commission (NRC) staff understands that NMP1 and NMP2 have a refueling cycle of 24 months. The proposed testing interval from every refueling outage to every Enclosure third refueling outage would exceed the maximum 60-month test interval described in NEI 94-01, Revision 2-A. NEI 94-01 has been updated and is currently on its third version that has been accepted by the NRC staff. For NMP1, the Type C test interval is in accordance with NEI 94-01, Revision 0 (ADAMS Accession No. ML 11327 A025), which is endorsed by Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program" (ADAMS Accession No. ML003740058). Type C tests intervals are set to 60 months. For NMP2, the Type C test interval is in accordance with NEI 94-01, Revision 2-A which has been accepted with limitations by letter dated June 25, 2008 (ADAMS Accession No. ML081140105). Type C test intervals are set to 60 months with a 9-month grace period. The third version of NEI 94-01, Revision 3-A (ADAMS Accession No. ML 12221A202), has been approved with conditions by NRC staff. Type C test intervals can be extended to 75 months with a 9-month grace period with conditions. The NRC staff has determined that the following additional information is required to complete its review: (1) Explain which version of NEI 94-01 NMP1 and NMP2 wants to apply to the extension of PIV test frequencies. (2) Clarify whether the extension of the PIV test frequencies will be consistent with NEI 94-01, paragraph 10.2.3.2, or up to every third refueling outage. | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 14, 2017 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 -REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ALTERNATIVE TO PERFORM PRESSURE ISOLATION VALVE LEAKAGE TESTING AT FREQUENCIES CONSISTENT WITH TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50, APPENDIX J (CAC NOS. MF9073 AND MF9074) DATED MARCH 14, 2017 DISTRIBUTION: Public LPL 1 R/F RidsNrrDorlLpl1 RidsACRS _MailCTR RidsRgn1 MailCente RidsNrrPMNineMilePoint RidsNrrLALRonewicz RidsNrrDeEpnb MFarnan, NRR ADAMS Accession Number: ML 17065A162 OFFICE DORL/LPL 1 /PM DORL/LPL 1 /LA DORL/LPL 1/BC NAME MMarshall LRonewicz JDanna DATE 03/14/2017 03/13/2017 03/14/2017 OFFICIAL RECORD COPY DORL/LPL 1 /PM MMarshall 03/14/2017 | | NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ALTERNATIVE REQUEST NUMBER GVRR-3 TO PERFORM PRESSURE ISOLATION VALVE LEAKAGE TESTING AT FREQUENCIES CONSISTENT WITH TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50, APPENDIX J (CAC NOS. |
| }} | | MF9073 AND MF9074) |
| | |
| | ==Dear Mr. Hanson:== |
| | |
| | By letter dated December 27, 2017 (Agencywide Documents Access and Management System Accession No. ML17003A096), Exelon Generation Company, LLC (the licensee) submitted a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) for a proposed alternative to the requirements of 10 CFR 50.55a and the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for Nine Mile Point Nuclear Station, Units 1 and 2. The proposed alternative would allow the licensee to perform pressure isolation valve leakage testing at frequencies consistent with 10 CFR Part 50, Appendix J, primary reactor containment leakage testing performance-based requirements. |
| | The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in your application and determined that additional information is needed to complete its review. |
| | Enclosed is our Request for Additional Information (RAI). The RAI was discussed with your staff on March 13, 2017, and it was agreed that your response would be provided within 30 days from the date of this letter. |
| | Sincerely, Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410 |
| | |
| | ==Enclosure:== |
| | |
| | Request for Additional Information cc: Distribution via Listserv |
| | |
| | REQUEST FOR ADDITIONAL INFORMATION PROPOSED ALTERNATIVE REQUEST NUMBER GVRR-3 FOR THE INSERVICE TESTING PROGRAM FOURTH AND THIRD 10-YEAR INTERVALS NINE MILE POINT NUCLEAR STATION, LLC EXELON GENERATION COMPANY, LLC NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-220 AND 50-410 By letter dated December 27, 2017 (Agencywide Documents Access and Management System Accession No. ML17003A096), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) for a proposed alternative to the requirements of 10 CFR 50.55a and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code for Nine Mile Point Nuclear Station, Units 1 and 2 (NMP1 and NMP2). The Proposed Alternative Request Number GVRR-3 would allow the licensee to perform pressure isolation valve (PIV) leakage testing at frequencies consistent with the 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors,'' reactor containment leakage testing performance-based requirements. The licensee has proposed an alternative test in lieu of the requirements found in the 2004 Edition of the ASME Operation and Maintenance (OM) Code Section ISTC-3630(a) for 35 PIVs. |
| | The licensee proposes to functionally test and verify the leakage rate of these PIVs using 10 CFR Part 50, Appendix J, Option B, performance-based schedule. Valves would initially be tested at the required interval schedule, which is currently every refueling outage (RFO), or 2 years, as specified by ASME OM Code, Section ISTC-3630(a). Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended. Any PIV leakage test failure would require the component to return to the initial interval of every RFO, or 2 years, until good performance can again be established. |
| | In its proposed alternative, Exelon states that the extension of test frequencies will be consistent with the guidance provided for Appendix J, Type C, leak rate tests as detailed in NEI 94-01, Revision 2-A, "Industry Guidelines for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,'' paragraph 10.2.3.2, "Extended Test Interval" (ADAMS Accession No. ML100620847), which states that, "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" (see page 10 of proposed alternative). |
| | Also, the licensee states that it proposes to perform PIV testing at intervals ranging from every refueling outage to every third refueling outage (see page 3 of proposed alternative). The U.S. Nuclear Regulatory Commission (NRC) staff understands that NMP1 and NMP2 have a refueling cycle of 24 months. The proposed testing interval from every refueling outage to every Enclosure |
| | |
| | third refueling outage would exceed the maximum 60-month test interval described in NEI 94-01, Revision 2-A. |
| | NEI 94-01 has been updated and is currently on its third version that has been accepted by the NRC staff. For NMP1, the Type C test interval is in accordance with NEI 94-01, Revision 0 (ADAMS Accession No. ML11327A025), which is endorsed by Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program" (ADAMS Accession No. ML003740058). |
| | Type C tests intervals are set to 60 months. For NMP2, the Type C test interval is in accordance with NEI 94-01, Revision 2-A which has been accepted with limitations by letter dated June 25, 2008 (ADAMS Accession No. ML081140105). Type C test intervals are set to 60 months with a 9-month grace period. The third version of NEI 94-01, Revision 3-A (ADAMS Accession No. ML12221A202), has been approved with conditions by NRC staff. Type C test intervals can be extended to 75 months with a 9-month grace period with conditions. |
| | The NRC staff has determined that the following additional information is required to complete its review: |
| | (1) Explain which version of NEI 94-01 NMP1 and NMP2 wants to apply to the extension of PIV test frequencies. |
| | (2) Clarify whether the extension of the PIV test frequencies will be consistent with NEI 94-01, paragraph 10.2.3.2, or up to every third refueling outage. |
| | |
| | ==SUBJECT:== |
| | NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ALTERNATIVE TO PERFORM PRESSURE ISOLATION VALVE LEAKAGE TESTING AT FREQUENCIES CONSISTENT WITH TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50, APPENDIX J (CAC NOS. MF9073 AND MF9074) |
| | DATED MARCH 14, 2017 DISTRIBUTION: |
| | Public LPL 1 R/F RidsNrrDorlLpl1 RidsACRS _MailCTR RidsRgn1 MailCente RidsNrrPMNineMilePoint RidsNrrLALRonewicz RidsNrrDeEpnb MFarnan, NRR ADAMS Accession Number: ML17065A162 OFFICE DORL/LPL 1/PM DORL/LPL 1/LA DORL/LPL 1/BC DORL/LPL 1/PM NAME MMarshall LRonewicz JDanna MMarshall DATE 03/14/2017 03/13/2017 03/14/2017 03/14/2017 OFFICIAL RECORD COPY}} |
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Category:Letter
MONTHYEARML24268A3382024-10-16016 October 2024
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Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests
NMP2L2890, Submittal of Revision 26 to the USAR and Reference Figures, 10 CFR 50.59 Evaluation Summary Report, TS Bases, TRM Requirements Manual Changes, and 10 CFR 54.37(b) Aging Management Review (Excludes Attachment 6)2024-10-0404 October 2024
Submittal of Revision 26 to the USAR and Reference Figures, 10 CFR 50.59 Evaluation Summary Report, TS Bases, TRM Requirements Manual Changes, and 10 CFR 54.37(b) Aging Management Review (Excludes Attachment 6)
ML24275A2442024-10-0303 October 2024
Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief, Division of Operating Reactor Licensing
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Initial Operator Licensing Examination Report 05000220/2024302
NMP1L3608, Supplemental Information Letter No. 3 - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2024-09-20020 September 2024
Supplemental Information Letter No. 3 - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation
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EN 57304 - Westinghouse Electric Company, LLC, Final Report - No Embedded Files. Notification of the Potential Existence of Defects Pursuant to 10 CFR Part 21
IR 05000220/20240052024-08-29029 August 2024
Updated Inspection Plan for Nine Mile Point Nuclear Station, Units 1 and 2 (Report 05000220/2024005 and 05000410/2024005)
IR 05000220/20240102024-08-22022 August 2024
Age-Related Degradation Inspection Report 05000220/2024010 and 05000410/2024010
NMP1L3603, Submittal of Preliminary Decommissioning Cost Estimate and Irradiated Fuel Management Plan2024-08-20020 August 2024
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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 05000220/20240022024-08-0505 August 2024
Integrated Inspection Report 05000220/2024002 and 05000410/2024002
ML24215A3002024-08-0202 August 2024
Operator Licensing Examination Approval
ML24213A1412024-07-31031 July 2024
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NMP1L3601, Supplemental Information Letter No. 2 - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2024-07-31031 July 2024
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Senior Reactor and Reactor Operator Initial License Examinations
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Issuance of Amendments to Adopt TSTF 264
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NMP1L3589, Special Report: Containment High Range Radiation Monitor Instrumentation Channel 12 Inoperable2024-05-16016 May 2024
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NMP1L3582, 2023 Annual Radioactive Environmental Operating Report for Nine Mile Point Units 1 and 22024-05-15015 May 2024
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IR 05000220/20240012024-05-10010 May 2024
Integrated Inspection Report 05000220/2024001 and 05000410/2024001
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NMP1L3581, Independent Spent Fuel Storage Installation (ISFSI) - 2023 Radioactive Effluent Release Report2024-04-30030 April 2024
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NMP2L2877, 2023 Annual Environmental Operating Report2024-04-19019 April 2024
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IR 05000220/20230042024-02-0101 February 2024
Integrated Inspection Report 05000220/2023004 and 05000410/2023004
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Supplement to LER 2023-001-00, Automatic Reactor Scram on Low Level Due to Partial Loss of Feedwater
NMP1L3569, CFR 50.46 Annual Report2024-01-26026 January 2024
CFR 50.46 Annual Report
ML24004A2122024-01-0808 January 2024
Senior Reactor and Reactor Operator Initial License Examinations
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Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0059 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting))
NMP1L3566, Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station2023-12-14014 December 2023
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ML23278A1292023-12-14014 December 2023
Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines
IR 05000410/20243012023-12-14014 December 2023
Initial Operator Licensing Examination Report 05000410/2024301
2024-09-04
[Table view]
Category:Request for Additional Information (RAI)
MONTHYEARML24197A0162024-07-12012 July 2024
NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591
ML24074A2812024-03-14014 March 2024
Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000220/2024010 and 05000410/2024010
ML23264A7992023-09-21021 September 2023
NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1
ML23205A2432023-07-19019 July 2023
NRC Staff Follow-up Question on Audit Question 18 TSTF-505 and 50.69 Regulatory Audit (E-mail Dated 7/19/2023) (EPIDs L-2022-LLA-0185 and L-2022-LLA-0186)
ML23087A2912023-03-28028 March 2023
Request for Additional Information (3/28/2023 E-mail) - Proposed Emergent I5R-11 Alternative Associated with a Weld Overlay on RPV Recirculation Nozzle N2E DM Weld
ML23061A0522023-03-0202 March 2023
Request for Additional Information (3/2/2023 E-mail) - Proposed Alternative Associated with a Weld Overlay Repair to the Torus
ML23012A2002023-01-13013 January 2023
Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000220/2023401 and 05000410/2023401
ML22207A2162022-07-26026 July 2022
Information Request to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000220/2022010 and 05000410/2022010
ML22194A9412022-07-13013 July 2022
Request for Additional Information Relief Request CS-PR-02 (7/13/2022 e-mail)
ML22041B5362022-02-10010 February 2022
NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541
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NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles
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Request for Additional Information LAR to Revise TSs to Adopt TSTF-582, Revision 0
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Request for Additional Information Alternative Request GV-RR-10 (11/2/2021 e-mail)
ML21256A1902021-09-10010 September 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application
ML21144A2132021-05-24024 May 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application
ML21117A0342021-05-0505 May 2021
Request for Additional Information Regarding Proposed Alternative to Use ASME Code Case N-893
ML21125A1282021-05-0404 May 2021
OPC Document Request - Feb 2021
ML21110A5112021-04-20020 April 2021
Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt TSTF-582
ML21088A2682021-03-30030 March 2021
Notification of Conduct of a Fire Protection Team Inspection
ML21062A0652021-03-0101 March 2021
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2024-07-12
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 14, 2017 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ALTERNATIVE REQUEST NUMBER GVRR-3 TO PERFORM PRESSURE ISOLATION VALVE LEAKAGE TESTING AT FREQUENCIES CONSISTENT WITH TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50, APPENDIX J (CAC NOS.
MF9073 AND MF9074)
Dear Mr. Hanson:
By letter dated December 27, 2017 (Agencywide Documents Access and Management System Accession No. ML17003A096), Exelon Generation Company, LLC (the licensee) submitted a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) for a proposed alternative to the requirements of 10 CFR 50.55a and the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for Nine Mile Point Nuclear Station, Units 1 and 2. The proposed alternative would allow the licensee to perform pressure isolation valve leakage testing at frequencies consistent with 10 CFR Part 50, Appendix J, primary reactor containment leakage testing performance-based requirements.
The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in your application and determined that additional information is needed to complete its review.
Enclosed is our Request for Additional Information (RAI). The RAI was discussed with your staff on March 13, 2017, and it was agreed that your response would be provided within 30 days from the date of this letter.
Sincerely, Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-220 and 50-410
Enclosure:
Request for Additional Information cc: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION PROPOSED ALTERNATIVE REQUEST NUMBER GVRR-3 FOR THE INSERVICE TESTING PROGRAM FOURTH AND THIRD 10-YEAR INTERVALS NINE MILE POINT NUCLEAR STATION, LLC EXELON GENERATION COMPANY, LLC NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-220 AND 50-410 By letter dated December 27, 2017 (Agencywide Documents Access and Management System Accession No. ML17003A096), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) for a proposed alternative to the requirements of 10 CFR 50.55a and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code for Nine Mile Point Nuclear Station, Units 1 and 2 (NMP1 and NMP2). The Proposed Alternative Request Number GVRR-3 would allow the licensee to perform pressure isolation valve (PIV) leakage testing at frequencies consistent with the 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, reactor containment leakage testing performance-based requirements. The licensee has proposed an alternative test in lieu of the requirements found in the 2004 Edition of the ASME Operation and Maintenance (OM) Code Section ISTC-3630(a) for 35 PIVs.
The licensee proposes to functionally test and verify the leakage rate of these PIVs using 10 CFR Part 50, Appendix J, Option B, performance-based schedule. Valves would initially be tested at the required interval schedule, which is currently every refueling outage (RFO), or 2 years, as specified by ASME OM Code, Section ISTC-3630(a). Valves that have demonstrated good performance for two consecutive cycles may have their test interval extended. Any PIV leakage test failure would require the component to return to the initial interval of every RFO, or 2 years, until good performance can again be established.
In its proposed alternative, Exelon states that the extension of test frequencies will be consistent with the guidance provided for Appendix J, Type C, leak rate tests as detailed in NEI 94-01, Revision 2-A, "Industry Guidelines for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, paragraph 10.2.3.2, "Extended Test Interval" (ADAMS Accession No. ML100620847), which states that, "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" (see page 10 of proposed alternative).
Also, the licensee states that it proposes to perform PIV testing at intervals ranging from every refueling outage to every third refueling outage (see page 3 of proposed alternative). The U.S. Nuclear Regulatory Commission (NRC) staff understands that NMP1 and NMP2 have a refueling cycle of 24 months. The proposed testing interval from every refueling outage to every Enclosure
third refueling outage would exceed the maximum 60-month test interval described in NEI 94-01, Revision 2-A.
NEI 94-01 has been updated and is currently on its third version that has been accepted by the NRC staff. For NMP1, the Type C test interval is in accordance with NEI 94-01, Revision 0 (ADAMS Accession No. ML11327A025), which is endorsed by Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program" (ADAMS Accession No. ML003740058).
Type C tests intervals are set to 60 months. For NMP2, the Type C test interval is in accordance with NEI 94-01, Revision 2-A which has been accepted with limitations by letter dated June 25, 2008 (ADAMS Accession No. ML081140105). Type C test intervals are set to 60 months with a 9-month grace period. The third version of NEI 94-01, Revision 3-A (ADAMS Accession No. ML12221A202), has been approved with conditions by NRC staff. Type C test intervals can be extended to 75 months with a 9-month grace period with conditions.
The NRC staff has determined that the following additional information is required to complete its review:
(1) Explain which version of NEI 94-01 NMP1 and NMP2 wants to apply to the extension of PIV test frequencies.
(2) Clarify whether the extension of the PIV test frequencies will be consistent with NEI 94-01, paragraph 10.2.3.2, or up to every third refueling outage.
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED ALTERNATIVE TO PERFORM PRESSURE ISOLATION VALVE LEAKAGE TESTING AT FREQUENCIES CONSISTENT WITH TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50, APPENDIX J (CAC NOS. MF9073 AND MF9074)
DATED MARCH 14, 2017 DISTRIBUTION:
Public LPL 1 R/F RidsNrrDorlLpl1 RidsACRS _MailCTR RidsRgn1 MailCente RidsNrrPMNineMilePoint RidsNrrLALRonewicz RidsNrrDeEpnb MFarnan, NRR ADAMS Accession Number: ML17065A162 OFFICE DORL/LPL 1/PM DORL/LPL 1/LA DORL/LPL 1/BC DORL/LPL 1/PM NAME MMarshall LRonewicz JDanna MMarshall DATE 03/14/2017 03/13/2017 03/14/2017 03/14/2017 OFFICIAL RECORD COPY
