ML17158B295

Relief Request RR-001 for Extension of the 4th 10-Year Lnservice Testing Interval

ML17158B295
Person / Time
Site:	FitzPatrick
Issue date:	06/07/2017
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML17158B295 (5)

Text

Exelon Generation 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a June 7, 2017 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Relief Request RR-001 for Extension of the 4th 10-Year lnservice Testing Interval Attached for your review is a relief request associated with the fourth ten-year lnservice Testing (IST) interval for the James A. FitzPatrick Nuclear Power Plant. The James A.

FitzPatrick Nuclear Power Plant (JAFNPP) currently complies with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants, 2001 Edition through the OMb Code-2003 Addenda. The fourth interval began on October 1, 2007, and will currently conclude on September 30, 2017.

We request your approval by August 31, 2017.

There are no regulatory commitments contained within this letter.

If you have any questions concerning this letter, please contact Mr. Tom Loomis at (610) 765-5510.

Sincerely, David T. Gudger Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Extension of the Fourth 10-Year IST Interval cc: Regional Administrator, Region I, USNRC USNRC Senior Resident Inspector, JAFNPP Project Manager USNRC, JAFNPP A. L Peterson, NYSERDA

James A. FitzPatrick Nuclear Power Plant Relief Request No. RR-001 Extension of the Fourth 10-Year IST Interval Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

-Code Requirements Present an Undue Hardship Without a Compensating Increase in the Level of Quality or Safety-(Page 1 of 4) 1.0 ASME CODE COMPONENTS AFFECTED:

Description:

Extension of Fourth 10-Year lnservice Test (IST) Interval Component Number: All IST Components 2.0 APPLICABLE CODE EDITION AND ADDENDA:

James A. FitzPatrick Nuclear Power Plant (JAFNPP) currently complies with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance (OM) of Nuclear Power Plants, 2001 Edition through the OMb Code-2003 Addenda.

3.0 APPLICABLE CODE REQUIREMENT:

ISTA-3120, lnservice Test Interval, (c) states, in part, that "The inservice test intervals shall comply with the following, except as modified by ISTA-3120(d) and ISTA-3120(e): ...

(2) Successive Test Intervals: 1O years following the previous test interval."

4.0 REASON FOR REQUEST:

Pursuant to 10CFR50.55a(z)(2), an alternative is proposed to the 10-year interval requirements contained within ISTA-3120(c)(2) for the fourth 10-year JAFNPP IST interval on the basis that the Code requirements present an undue hardship without a compensating increase in the level of quality or safety.

Specifically, relief is being sought to extend the current fourth IST interval an additional eight months from September 30, 2017, to May 31, 2018. Relief is required to extend the present interval since JAFNPP previously extended the IST interval for a total of 12 months, in two transmittals to the NRC: JPN-96-019, dated April 26, 1996, describing a nine-month extension, and JPN-97-015, dated April 16, 1997, describing an additional three-month extension. These letters document the twelve-month extension of the IST interval allowed by ISTA-3120(d).

Exelon Generation Company, LLC (Exelon) recently purchased the JAFNPP in early April 2017. Prior to that time, it was expected that the JAFNPP, which was operated by Entergy Operations, Inc., would be shut down prior to the start of the 5th IST interval. Therefore, no need existed to apply for relief from OM Code requirements associated with a new interval since the current interval was scheduled to end on September 30, 2017. However, since JAFNPP is to remain operating under new ownership, there is only a shortened time frame (April to September) to prepare for a new OM Code interval, develop a new IST program, and subsequently submit any necessary relief requests for timely NRC review and approval.

There is not the typical one-year review time afforded the NRC for review of relief requests.

James A. FitzPatrick Nuclear Power Plant Relief Request No. RR-001 Extension of the Fourth 10-Year IST Interval Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

-Code Requirements Present an Undue Hardship Without a Compensating Increase in the Level of Quality or Safety-(Page 2 of 4) 5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE:

Exelon is requesting an eight-month extension to prepare for the new interval, develop a new IST program applicable to the latest updated edition of the OM Code and subsequent submittal of applicable relief requests for NRG approval.

In order to recover this requested eight-month extension, the 5th ten-year IST interval that is proposed to begin on June 1, 2018, will end on September 30, 2027. Succeeding intervals will be scheduled in ten-year increments.

All previously NRG-approved JAFNPP relief requests (alternatives) for the 4th IST interval will also be extended until May 31, 2018, as a result of this proposed alternative. The JAFNPP will continue to comply with all requirements as specified in the current edition and addenda of the ASME OM Code and the approved NRG relief requests during this eight-month extended 4th IST interval time period. See Table 1, "Relief Requests Approved for JAFNPP 4th IST Interval", for the listing of Relief Requests approved for the 4th IST Interval at JAFNPP.

JAFNPP requests this additional time to allow for submittal of the necessary relief requests, NRG review and approval of the relief requests, and submittal of the IST Program for the 5th IST interval. This has the potential to result in emergent plant modifications and additional testing requirements. Based on the hardship resulting from implementing the OM Code requirements without a compensating increase in the level of quality and safety and that the relief will provide for a more manageable transition between a change in Code requirements, Exelon is requesting this proposed alternative pursuant to 10 CFR 50.55a(z)(2).

6.0 DURATION OF PROPOSED ALTERNATIVE:

Relief is requested to modify the end date of the JAFNPP fourth 10-year IST interval and start date of the 5th IST interval. The current 4th IST interval is scheduled to end September 30, 2017, and is proposed to end May 31, 2018. As a result, the 5th IST interval would commence on June 1, 2018, and end on September 30, 2027.

7.0 PRECEDENCE

1. Letter from NRG (W. D. Beckner) to Entergy Operations, Inc. (M. J. Meisner), "Update of lnservice Testing Programs for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3, (TAC Nos.

M94471, M94472, M94452, M94473, M94488)," dated August 27, 1996 (Accession Number 9608300001)

2. NRG SER, "Interim Extension of 120-Month Interval for lnservice Inspection and lnservice Testing (ISl/IST) Programs for Waterford Steam Electric Station, Unit 3, (TAC No. M89544),"

dated August 2, 1994 (Accession Nos. 9408080070 and 9408080075)

James A. FitzPatrick Nuclear Power Plant Relief Request No. RR-001 Extension of the Fourth 10-Vear IST Interval Proposed Alternative in Accordance with 10CFR 50.55a(z)(2)

-Code Requirements Present an Undue Hardship Without a Compensating Increase in the Level of Quality or Safety-(Page 3 of 4)

8.0 REFERENCES

1. JPN-96-019, dated April 26, 1996 (Accession Number 9605020205)

2. JPN-97-015, dated April 16, 1997 (Accession Number 9704240132)

James A. FitzPatrick Nuclear Power Plant Relief Request No. RR-001 Extension of the Fourth 10-Vear IST Interval Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

-Code Requirements Present an Undue Hardship Without a Compensating Increase in the Level of Quality or Safety-(Page 4 of 4)

Table 1 Relief Requests Approved for JAFNPP 4th IST Interval Relief Request Number Description VRR-01 Withdrawn VRR-02 Traversing In-Core Probe Containment Isolation Valve Stroke Time VRR-03 Excess Flow Check Valve Exercise Testina Durina Refuelina Outaaes VRR-04 Hiqh Pressure Coolant Injection Check Valve Online Testinq VRR-05 Power-Operated System Control Valves with Safety Function VRR-06 Safety Relief Valve Testing Interval VRR-07 Pressure Isolation Valve Testinq at Aooendix J Frequency VRR-08 Solenoid Operated Valve Position Indication Testing at Appendix J Frequency PRR-01 Withdrawn PRR-02 Core Spray Pump Suction Pressure Gauge Ranae PRR-03 Emergency Service Water Pumps Use of a Pump Curve PRR-04 Residual Heat Removal Service Water and Emergency Service Water Smooth Running Pumps PRR-05 Residual Heat Removal Pump Vibration Alert Ranqe