RS-13-040, Supplement to the Dresden Nuclear Power Station Fifth Inservice Inspection Interval Relief Request I5R-04

Supplement to the Dresden Nuclear Power Station Fifth Inservice Inspection Interval Relief Request I5R-04

ML13025A161
Person / Time
Site:	Dresden
Issue date:	01/24/2013
From:	Simpson P Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
15R-04, RS-13-040
Download: ML13025A161 (6)

Text

1 RS-13-040 RS-13-040 10 10 CFR CFR SO.SSa 50.55a January 24, 2013 U. S. Nuclear U. Nuclear Regulatory Regulatory Commission Commission ATTN: Document Control Control Desk Washington, D.C.

Washington, D.C. 20555-0001 20SSS-0001 Dresden Nuclear Power Station, Dresden Station, Units 22 and 3 Renewed Facility Renewed Facility Operating Operating License License Nos.

Nos. DPR-19 and DPR-25 DPR-2S NRC Docket Nos. 50-237 SO-237 and 50-249 SO-249

Subject:

Supplement to the Dresden Nuclear Power Station Fifth Inservice Inspection Inspection Interval Interval Relief Request Request 15R-04 ISR-04

Reference:

Letter from from D.D. M.

M. Gullott Gullott(Exelon (Exelon Generation Generation Company, Company, LLC LLC (EGC))

(EGC>> to to U.

U. S.

S. NRC, NRC, "Dresden Nuclear Power Power Station, Station, Units Units 22 and and3, 3,Fifth Fifth Interval Inservice Inspection Intervallnservice Inspection Program Plan Program Plan and Relief Requests," dated September Relief Requests," September 28, 28, 2012 2012 In the In the referenced letter, EGC submitted relief requests associated relief requests associatedwith withthe thefifth fifth inservice inservice inspection inspection (ISI) intervalfor (lSI) interval forDresden Dresden Nuclear Nuclear Power Station (DNPS), Units 2 and 3. 3. Following Following discussions discussionswithwith the NRC, it became apparent that additional clarification is required for the NRC, it became apparent that additional clarification is required for the NRC to complete its NRC to complete its review of of Relief Relief Request Request ISR-04.

15R-04. Therefore, EGC requests requests to to supersede supersedethe theversion versionofof15R-04 ISR-04inin the referenced referenced letterletter with with the version version in in the attachment attachmentto to this this letter letter in in its its entirety.

entirety.

EGC continues to request approval approval ofof this relief request by September relief request September 28, 28, 2013, 2013, to to support support examination of components componentsduring during the theDNPS, DNPS,Unit Unit 22Fall Fall 2013 2013refueling refueling outage outagewhichwhichfalls falls within the fifth fifth 10-year 10-year ISIlSI interval.

interval.

There There areareno noregulatory regulatorycommitments commitmentscontained containedwithin withinthis thisletter.

letter.

Should you have have anyany questions questionsconcerning concerningthis thisletter, letter,please pleasecontact contactMr. Mr.Mitchel MitchelA. A. Mathews Mathews at at (630) 657-2819.

6S7-2819.

Sin Patrick R. Simpson Manager - Licensing Exelon Generation Generation Company, LLC LLC

Attachment:

10 CFR CFR 50.55a SO.SSa Request Request Number Number 15R-04, ISR-04, Revision Revision 11

ATTACHMENT 10 CFR SO.SSa 50 .55a Request Number Number 15R-04,ISR-04, Revision 11 Proposed Alternative In Accordance with 10 Proposed 10 CFR SO.SSa(a)(3)(ii) 50.55a(a)(3)(ii)

--Hardship or Unusual Difficulty without Compensating Increase in Level Level of Quality and Safety--

1. ASME Code Component(s)

Component(s) Affected:

Affected:

Code Class: 3

Reference:

IWD-2500, Table IWD-2500-1 IWD-2500-1 Examination Category: D-B Item Number: B2.10

Description:

Testing Frequency for Isolation Condenser Condenser Shell Shell Side Side and Associated Piping Component Number:

Unit No. Drawing Test Block No.

2 M-28, M-39 21CO1, 21C02 21C01, 3 M-359, M-369 31CO1, 31C02 31C01,

2. Code Applicable Edition Applicable Code and EditionAddenda:

and Addenda:

The Inservice Inspection (ISI) (lSI) Program is based based on on the theAmerican American Society Societyof of Mechanical Mechanical Engineers (ASME) Boiler and (ASME) Boiler and Pressure Vessel(B&PV)

Pressure Vessel (B&PV) Code, Code, Section SectionXI, XI, 2007 2007 Edition Edition through the 2008 Addenda.

Addenda.

3. Applicable Applicable Code Requirements:

Table IWD-2500-Table IWD-2500-1, 1, "Examination "Examination Categories," Examination Examination Category Category D- D-B, B, Item Item Number D2.10, requires 02.10, requires all allClass Class 33 pressure retaining retaining components components be subject to to a system leakage leakage test with test with aa VT-2 examination in VT-2 visual examination in accordance accordance with with IWD-5220, IWD-5220, "System "System Leakage Test."

Leakage Test."

This system leakage test is is to be be conducted conducted once each inspection period. period.

IWD-5221, IWD-5221,"Pressure,"

"Pressure,"states states that that system system leakage test shall shall be conducted conducted at at the the system system pressureobtained pressure obtainedwhile while the thesystem, system,ororportion portionof ofthe thesystem, system,isisininservice serviceperforming performingits its normal operating function function or oratat the the system system pressure developedduring pressure developed during aatest testconducted conductedto to verify system verify operability (e.g.,

system operability (e.g., to demonstrate demonstrate systemsystemsafety safetyfunction functionororsatisfy satisfytechnical technical specification surveillance requirements).

requirements).

Reason 4. for Request:

Reason for Request:

Pursuant to Pursuant to 10 10 CFR CFR 50.55a(a)(3)(ii),

50.55a(a)(3)(ii), relief relief is is requested requested on on the the basis basisthat thatconformance conformancewith with Code requirements the Code requirements impose imposehardship hardshipwithout without aacompensating compensatingincrease increaseininthe thelevel levelofof quality and safety.

Isolation Condenser The Isolation Condenserisisnot notnormally normallyin in service; service; itit is is normally normally in a standby standby alignment alignment with its with its shell shell side side vented vented toto the the atmosphere through aa non-isolable atmosphere through non-isolable vent vent line.

line. ForFor inservice inservice purposes, each inspection purposes, eachunit's unit'sIsolation IsolationCondenser Condenserisisdivideddividedinto intotwo twotest testblocks blocks Page 11 of of 5S

ATTACHMENT 50.55a Request 10 CFR SO.SSa Request NumberNumber15R-04, ISR-04, Revision Revision 11 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(ii)

Proposed SO.SSa(a){3)(ii)

--Hardship or Unusual Difficulty without Compensating Increase in Increase in Level Level of of Quality Quality and and Safety-Safety-(e.g., 21C01 21C01 and and 21C02 21C02for forthe the Unit Unit22Isolation IsolationCondenser Condenser upper upper and and lower lower portions, portions, respectively). For example, the respectively). For the DNPS, DNPS, Unit Unit 2 upper and and lowerlower system leakage leakagetest testblocks blocks are represented representedininFigures Figures15R-04.01 ISR-04.01 and and15R-04.02 ISR-04.02 below, below, respectively.

respectively.

,/

./

./".

,:~:t ISOLA7iCN CO WE SE' 2--133 2 Figure Figure15R-04.1:

ISR-04.1: Unit Unit 22 Isolation IsolationCondenser CondenserTest TestBlock BlockNo. No.21C01 21C01 Page 2 of 5 ofS

ATTACHMENT ATTACHMENT 10 CFR 10 CFR 50.55a RequestRequest NumberNumber15R -04, Revision 11 15R-04, Proposed Alternative Proposed Alternative In In Accordance with 10 CFR 50.55a(a)(3)(ii) 50.55a{a){3){ii)

--Hardship or Unusual Difficulty without Compensating

--Hardship Increase in Increase in Level Level of Quality and Safety--

4SOLA I: N CUND SER 2-?382 Figure Figure15R-04.2:

15R-04.2: Unit Unit 22 Isolation IsolationCondenser CondenserTest TestBlock BlockNo.

No.21C02 21C02 The system The system isisnormally normally aligned aligned with with the Isolation Condenser shell side Condenser shell side water waterlevel level greater greater than or equal to six (6) than or equal to six (6) feet in accordance with Dresden Nuclear Power Station (DNPS),

in accordance with Dresden Nuclear Power Station (DNPS),

and 33 Technical Units 2 and Technical Specifications Specifications (TS); (TS); however, however, the theshell shellside sidewater waterlevel levelofofthe the Isolation Condenser Condenser isis administratively administratively maintained between between 77 feet feet and and7.4 7.4feet feetinin accordance accordancewithwith plant plant procedures.

procedures.

Page Page 33 of 5 of5

ATTACHMENT ATTACHMENT 10 CFR 10 CFR SO.SSa 50.55a Request Request NumberNumber15R-04, ISR-04, Revision Revision 11 Proposed Alternative Proposed Alternative In In Accordance with 10 CFR SO.SSa{a){3){ii) 50.55a(a)(3)(ii)

--Hardship or Unusual Difficulty without Compensating

--Hardship Increase in Increase in Level Level of Quality and and Safety--

Isolation IsolationCondenser Condenser system system operability operability is is verified verified through performance performance of of TS TS Surveillance Surveillance Requirement (SR) 3.5.3.4, "Isolation Requirement "Isolation Condenser Condenser System System Heat HeatRemoval RemovalCapability Capability Verification VerificationTest," every60 Test,"every 60 months months (Le.,

(i.e., during during two twoof ofthe thethree three inspection inspection periods for DNPSs DNPSs fifthfifthlSIISIinterval).

interval).The Thesystem system pressures pressures developeddevelopedduring duringthe theperformance performanceofofthis this TS surveillance meet the Code Code requirements requirementsof ofIWD-5221; IWD-5221; however, the the 60-month 60-month frequency does does not not meet meetthe theTable TableIWD-2500-1 IWD-2500-1 examinationexamination frequency frequency requirement requirement of of once perper inspection period. period.

Performance of an additional Isolation Isolation Condenser Condenser heat heatremoval removal capability capability testtest solely solely forfor the purposes of performing performing aa system leakage leakage testtest requires requires aaminimum minimum of of aa 25%

25% reduction reduction in in reactor power power to to perform performthe theexamination.

examination. This This presents presents an unnecessary unnecessarytransient transient on on the the affected DNPS reactor and aa challenge challenge to to station station operators.

operators. Additionally, Additionally, as as previously previously stated, the isolation isolation condenser condenser shell shell cannot cannotbe beisolated isolatedand andpressurized pressurizedtotomeet meetIWD-5221 IWD-5221 examination examination pressure pressure requirements when in a standby alignment. ItIt would be an abnormal activityto activity tofill fillthetheIsolation IsolationCondenser Condenserto tothe thetop top simply simplytotoachieve achieve aa slight slight increase increase in static head for the additional additional system leakage test.

system leakage test. As Asan anadditional additionalcomplication, complication, any any water water added added to to the the isolation isolation condenser condensershell shelltotoraise raiselevel levelabove abovethe thenormal normaloperating operatinglevel levelwould would subsequently have to be drained and processed processed by by radwaste.

radwaste.

In In summary, summary, imposing imposing aa largelarge transient transient on on the reactor plant to to accommodate the performance of the Isolation Condenser Condenser heat heatremoval removal capability capability verification verification at at a greater frequency than required required by by DNPS DNPS TS TS and andfilling filling thethe Isolation Isolation Condenser Condenser to the top to perform perform aa third third system system leakage test, present presenthardshiphardshipwithout without aa compensating compensating increase increaseinin and safety.

quality and 5.

S. Proposed Alternative and Basis for Use: Use:

As an alternative, Exelon Exelon Generation Generation Company, Company, LLC LLC (EGC) proposes proposes the the performance performanceof ofaa system leakage system leakagetest testusing usingaaVT-2 VT-2visual visualexamination examinationof of all all DNPS DNPS UnitsUnits 22 and and 33Isolation Isolation CondenserTest Condenser TestBlocks Blocks(i.e.,

(Le., Test TestBlocks Blocks 2(3)IC01 2(3)IC01 and and 2(3)IC02) 2(3)IC02) every 60 months months during during the performance of TS SR 3.5.3.4 versus once once per per inspection inspection periodperiod as as discussed discussedininTable Table IWD-2500-1.

IWD-2500-1.

discussedinin the As discussed theprevious previousparagraph, paragraph,during duringthe theDNPS DNPSfifth fifth ISI lSI interval interval EGC proposes proposes the leakage that the leakagetest testofofIsolation Isolation Condenser CondenserTest TestBlocks Blocks2(3)IC01 2(3)IC01 (i.e.,(Le., the theupper upperportion portionof of the Isolation the Isolation Condenser Condenserand andassociated associatedpiping)piping)will will only only be be performed performed once onceeveryevery60 60 months during months during the performance of TS SR 3.5.3.4 3.5.3.4 versusversus once onceper perinspection inspectionperiodperiodas as discussed discussedininTable TableIWD-2500-1.

IWD-2500-1.

During inspection periods where TS SR During SR 3.5.3.4 3.5.3.4 isis not not performed performed on on aaunit's unit'sIsolation Isolation Condenser,an Condenser, anadditional additionalVT-2 VT-2examination examinationwill will bebeperformed performedfor forTest TestBlocks Blocks2(3)IC02 2(3)IC02 (Le., the lower portion (i.e., portionof ofthetheIsolation IsolationCondensers Condensers and and associated piping). This associated piping). This leakage leakage will be performed with test will test with Isolation IsolationCondenser Condenser shell shell side water level at the normal standby standby level versus versus at at the the normal normal pressure pressurewhen whenthe thesystem systemisisininservice serviceperforming performingitsitsnormal normal operating function operating function or at the system pressure pressuredeveloped developedduring duringaatest testconducted conductedtotoverify verify system system operability operability as as discussed discussedininIWD-5221.

IWD-5221.

Page Page 44 of ofS 5

ATTACHMENT ATTACHMENT 10 CFR 50.55a 10 CFR SO.SSa Request Number Number 15R-04, ISR-04, Revision 11 Proposed Alternative Proposed Alternative In In Accordance with with 10 CFR SO.SSa{a){3){ii) 50.55a(a)(3)(ii)

--Hardship or Unusual Difficulty

--Hardship Difficulty without without Compensating Compensating Increase in Level Increase Level ofof Quality Quality and Safety--

Safety--

The proposed alternative The alternative isis based based on the hardship hardship imposed imposed by by the the performance performance of of the heat heat removal capability verification test at a greater frequency than required removal capability verification test at a greater frequency than required by DNPS TS by DNPS TS and fillingthe filling theIsolation IsolationCondenser Condenserto tothe thetop toptotoperform performaathirdthirdsystem system leakage leakage test without a compensating increase compensating increase in in quality quality and safety.

6.

Duration 6.

of Proposed Duration of Proposed Alternative:

Alternative:

Relief isis requested Relief requested for the Fifth Ten-Year Inspection Interval Fifth Ten-Year for DNPS, Interval for DNPS, Units Units 22 and and 3.

Precedents:

7. Precedents:

DNPS, Units DNPS, Units 2 and 3 fourth inspection intervalinterval Relief Request Request 14R-06 14R-06 was authorized authorized in in an NRC safety evaluation evaluation (SE) dated September 4, 2003. The fifth inspection September 4, 2003. The fifth inspection interval interval relief request relief request (i.e.,

(Le., 15R-04, Revision 1)

ISR-04, Revision 1) utilizes utilizes aa similar similar approach approach that was previously previously approved.

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