ML18086B221

Exelon - Withdrawal of Submittal of Relief Request for an Alternative to the ASME Code - Revise Main Steam Isolation Valve Partial Stroke Testing Frequency

ML18086B221
Person / Time
Site:	Dresden, Nine Mile Point, Oyster Creek, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	03/27/2018
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLR-0134
Download: ML18086B221 (3)

Text

Exelon 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com March 27, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 10 CFR 50.55a(z)

Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 USNRC Docket No. 50-219 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR 29 and DPR 30 NRC Docket Nos. 50-254 and 50-265

Subject:

Withdrawal of Submittal of Relief Request for an Alternative to the ASME Code -Revise Main Steam Isolation Valve Partial Stroke Testing Frequency

References:

1. Letter from D. P. Helker (Exelon Generation

Company, LLC), to U.S. Nuclear Regulatory Commission, "Submittal of Relief Request for an Alternative to the ASME Code -Revise Main Steam Isolation Valve Partial Stroke Testing Frequency,"

dated November 1, 2017 (ADAMS Accession No. ML 17306A014)

U.S. Nuclear Regulatory Commission Withdrawal of Proposed Relief Request for MSIV Partial Stroke Testing Frequency March 27, 2018 Page 2 2. Letter from B. Purnell (U.S. Nuclear Regulatory Commission),

"Summary of February 26, 2018, Meeting With Exelon Generation

Company, LLC, Regarding Proposed Alternative to the Main Steam Isolation Valve Testing Requirements (EPID L-2017-LLR-0134),"

dated March 1, 2018 (ADAMS Accession No. ML 18058A523)

In Reference 1, Exelon Generation

Company, LLC (Exelon) submitted a relief request associated with the lnservice Testing (IST) programs for Clinton Power Station, Unit 1; Dresden Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; and Quad Cities Nuclear Power Station, Units 1 and 2. The Reference 1 submittal proposed an authorization to continue to partial stroke exercise Main Steam Isolation Valves (MSIVs) on a limited basis with an ASME OM Code Cold Shutdown Justification (CSJ) currently in place for MSIVs at each of the cited Exelon stations.

Exelon proposed that the partial stroke exercise of MSIVs would be performed in accordance with the Surveillance Frequency Control Program (SFCP) and would partially stroke exercise MS I Vs at various test intervals until the final refueling outage testing interval was achieved.

Exelon's relief request was submitted due to the belief that ISTC-3521 (b) and ISTC-3521 (c) prohibited any type of exercising of MSIVs with a CSJ in place. On February 26, 2018, the NRG held a public meeting (Reference

2) to discuss the Reference 1 relief request.

The NRG staff stated that the alternative is not needed, since the ASME OM Code does not prevent the continued exercising of MSIVs at power if a CSJ documented in the IST Program Plan document for each site demonstrates that exercising at power is not practicable.

In particular, the NRG staff noted that paragraph ISTC-3521 (c) of the ASME OM Code states that exercising "may"-not "shall" -be limited to full-stroke exercising during cold shutdown.

Thus, paragraph ISTC-3521 (c) does not prevent the partial-stroke testing of the MSIVs at power. Exelon will utilize paragraph ISTC-3521 (c) for full stroke exercising of the MSIVs during cold shutdown under the IST program while continuing to partially stroke exercise the MSIVs during power operation under the SFCP at various intervals commensurate with the SFCP frequencies.

Based on this information, Exelon agrees with the conclusion that the relief request submitted in Reference 1 is not needed and should be withdrawn.

Therefore, Exelon hereby withdraws the Reference 1 relief request.

There are no regulatory commitments contained in this letter. If you have any questions regarding this letter, please contact David Neff at (267) 533-1132.

Respectfully, 9,g.

David P. Helker Manager -Licensing

& Regulatory Affairs Exelon Generation

Company, LLC U.S. Nuclear Regulatory Commission Withdrawal of Proposed Relief Request for MSIV Partial Stroke Testing Frequency March 27, 2018 Page 3 cc: USNRC Regional Administrator

-NRC Region I USNRC Regional Administrator-NRC Region Ill USNRC Project Manager, NRR -Clinton Power Station USNRC Project Manager, NRR -Dresden Power Station USNRC Project Manager, NRR -James A. FitzPatrick Nuclear Power Plant USNRC Project Manager, NRR -LaSalle County Station USNRC Project Manager, NRR -Nine Mile Point Nuclear Station USNRC Project Manager, NRR -Oyster Creek Nuclear Generating Station USNRC Project Manager, NRR -Quad Cities Nuclear Power Station USNRC Senior Resident Inspector

-Clinton Power Station USNRC Senior Resident Inspector

-Dresden Power Station USNRC Senior Resident Inspector

-James A. FitzPatrick Nuclear Power Plant USNRC Senior Resident Inspector

-LaSalle County Station USNRC Senior Resident Inspector

-Nine Mile Point Nuclear Station USN RC Senior Resident Inspector

-Oyster Creek Nuclear Generating Station USNRC Senior Resident Inspector

-Quad Cities Nuclear Power Station A. L. Peterson, NYSERDA Illinois Emergency Management Agency -Division of Nuclear Safety R. R. Janati -Bureau of Radiation Protection, Commonwealth of Pennsylvania

Director, Bureau of Nuclear Engineering, New Jersey, Dept. of Environmental Protection