ML13010A456

Units 1 & 2 - Supplemental to Dresden and Quad Cities Fifth Inservice Inspection Interval Relief Request I5R-03

ML13010A456
Person / Time
Site:	Dresden, Quad Cities
Issue date:	01/10/2013
From:	Simpson P R Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-13-005
Download: ML13010A456 (3)

Text

RS-13-005 January 10, 2013 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 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:

Supplement to Dresden Nuclear Power Station and Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request 15R-03

References:

1.Letter from D. M. Gullott (Exelon Generation Company, LLC (EGC)) toU.S. NRC, "Dresden Nuclear Power Station, Units 2 and 3, Fifth Interval Inservice Inspection Program Plan and Relief Requests," dated September 28, 2012 2.Letter from D. M. Gullott (EGC) to U.S. NRC, "Quad Cities Nuclear Power Station, Units 1 and 2, Fifth Interval Inservice Inspection Program Plan and Relief Requests," dated September 28, 20123.Letter from B. Mozafari, (U.S. NRC) to M. J. Pacilio (EGC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 - Request for Additional Information Related to the Request for Alternative, 15R-03, from American Society of Mechanical Engineers Boiler

and Pressure Vessel Code,Section XI, Associated with the Fifth Inservice Inspection (TAC Nos.ME9686-87 and ME9672

-73)," dated December 21, 2012 In References 1 and 2, Exelon Generation Company, LLC (EGC) submitted relief requests associated with the fifth inservice inspection (ISI) interval for Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2, respectively. In

Reference 3, the NRC discussed information that is needed to complete the review of Relief Request 15R-03. The attachment provides the requested information.

1 RS-13-005 10 CFR 50.55a January 10, 2013 u.s. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 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:

Supplement to Dresden Nuclear Power Station and Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request 15R-03

References:

1. Letter from D. M. Gullott (Exelon Generation Company, LLC (EGC>> to U.S. NRC, "Dresden Nuclear Power Station, Units 2 and 3, Fifth Interval Inservice Inspection Program Plan and Relief Requests," dated September 28, 2012 2. Letter from D. M. Gullott (EGC) to U.S. NRC, "Quad Cities Nuclear Power Station, Units 1 and 2, Fifth Interval Inservice Inspection Program Plan and Relief Requests," dated September 28,2012 3. Letter from B. Mozafari, (U.S. NRC) to M. J. Pacilio (EGC), "Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 -Request for Additional Information Related to the Request for Alternative, 15R-03, from American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Associated with the Fifth Inservice Inspection (TAC Nos. ME9686-87 and ME9672-73)," dated December 21, 2012 In References 1 and 2, Exelon Generation Company, LLC (EGC) submitted relief requests associated with the fifth inservice inspection (lSI) interval for Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2, respectively.

In Reference 3, the NRC discussed information that is needed to complete the review of Relief Request 15R-03. The attachment provides the requested information.

January 10, 2013 U.S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.

Attachment:

Supplemental Information Regarding Relief Request 15R-03 January 10, 2013 U.S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819. Patrick R. Simpson Manager -licensing

Attachment:

Supplemental Information Regarding Relief Request 15R-03 ATTACHMENT Supplemental Information Regarding Relief Request 15R-03 NRC Request Under 10 CFR 50.55a(a)(3)(ii), the licensee shall provide a basis to demonstrate that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of basis for hardship or unusual difficulty include, but are not limited to: having to enter multiple technical specification limiting conditions for operations or as low as reasonably achievable (ALARA)radiological concerns. Statements made in Section 4 of the submittal such as: "Failure of the inner 0-ring is the only condition under which this line is pressurized" and "Failure of this seal could possibly cause ejection of the device used for plugging into the vessel" does not provide the necessary information to support a determination that the requirement creates hardship or unusual difficulty. Please provide supplemental bases for hardship or unusual difficulty.

Exelon Generation Company, LLC Response Due to the design of the Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, reactor pressure vessels (RPVs), pressurization of the RPV Head Flange Leak Detection Line will likely damage the inner RPV Head Flange o-ring without successful completion of the examination as described in Section 4 of the DNPS, Units 2 and 3, and QCNPS, Units 1 and 2, Relief Request 15R-03 submittals.

During the performance of the examination and resulting corrective maintenance, station personnel would be exposed to radiation fields of up to 75 mR per hour with total station exposure estimated to be up to 7.3 rem based on single RPV head disassembly and reassembly evolutions in previous outages. Exposure to these levels of radiation without the compensating increase in quality and safety that would be afforded by a successful completion of the examination is not in accordance with NRC regulations or industry principles of maintaining personnel radiation exposure ALARA. Therefore, attempting to perform a VT-2 examination on the DNPS, Units 2 and 3, and QCNPS, Units 1 and 2, RPV Head Flange Leak Detection Lines in accordance with Code requirements constitutes hardship without a compensating increase in quality or safety.

Page 1 ATTACHMENT Supplemental Information Regarding Relief Request 15R-03 NRC Request Under 10 CFR SO.SSa(a)(3)(ii), the licensee shall provide a basis to demonstrate that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Examples of basis fOl hardship or unusual difficulty include, but are not limited to: having to enter multiple technical specification limiting conditions for operations or as low as reasonably achievable (ALARA) radiological concerns.

Statements made in Section 4 of the submittal such as: "Failure of the inner O-ring is the only condition under which this line is pressurized" and "Failure of this seal could possibly cause ejection of the device used for plugging into the vessel" does not provide the necessary information to support a determination that the requirement creates hardship or unusual difficulty.

Please provide supplemental bases for hardship or unusual difficulty.

Exelon Generation Company, LLC Response Due to the design of the Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, reactor pressure vessels (RPVs), pressurization of the RPV Head Flange Leak Detection Line will likely damage the inner RPV Head Flange o-ring without successful completion of the examination as described in Section 4 of the DNPS, Units 2 and 3, and QCNPS, Units 1 and 2, Relief Request 15R-03 submittals.

During the performance of the examination and resulting corrective maintenance, station personnel would be exposed to radiation fields of up to 75 m R per hour with total station exposure estimated to be up to 7.3 rem based on single RPV head disassembly and reassembly evolutions in previous outages. Exposure to these levels of radiation without the compensating increase in quality and safety that would be afforded by a successful completion of the examination is not in accordance with NRC regulations or industry principles of maintaining personnel radiation exposure ALARA. Therefore, attempting to perform a VT-2 examination on the DNPS, Units 2 and 3, and QCNPS, Units 1 and 2, RPV Head Flange Leak Detection Lines in accordance with Code requirements constitutes hardship without a compensating increase in quality or safety. Page 1