RA-17-059, Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues

Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues

ML17242A209
Person / Time
Site:	Oyster Creek, Quad Cities
Issue date:	08/29/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-17-059, RS-17-122
Download: ML17242A209 (6)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com RS-17-122 RA-17-059 August 29, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRG Docket No. 50-219 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRG Docket Nos. 50-254 and 50-265

Subject:

Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues

References:

1) Letter from Greg Krueger (NEI) to Mr. John Lubinski (U.S. Nuclear Regulatory Commission), Anchor Darling Double Disc Gate Valve Industry Resolution Plan Update (Project 689), dated August 4, 2017

2) Letter from W. J. Trafton (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Amendment to Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues,"

dated June 20, 2017 (RA-17-059)

3) BWROG Topical Report TP-16-1-112, "Recommendations to Resolve Flowserve 10 CFR Part 21 Notification Affecting Anchor Darling Double Disc Gate Valve Wedge Pin Failures (Revision 4)," dated August 2017 In Reference 1, the Nuclear Energy Institute (NEI) provided the NRG a near-term plan for the U.S. Nuclear Industry to address the known Anchor Darling Double Disk Gate Valve (ADDDGV) issues leading up to the February 2017 LaSalle County Station, Unit 2 valve stem-disc separation on a High Pressure Core Spray Motor Operated Valve (MOV). The NEI letter states that each affected utility will communicate to the NRG by August 31, 2017, a list of "High Significance" valves and an associated repair schedule. "High Significance" as defined by the NEI are safety related MOVs having an active safety function to either Open or Open/Close with an "UNSAT" wedge pin analysis. Excluding LaSalle County Station, Units 1 and 2, this scope of valves within Exelon Generation Company, LLC (EGG) is limited

U.S. Nuclear Regulatory Commission Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues August 29, 2017 Page2 to only the Oyster Creek Generating Station. Further, this letter provides additional information for all susceptible High Risk valves at Quad Cities Nuclear Power Station, Units 1 and 2, in addition to the Oyster Creek Nuclear Generating Station and LaSalle County Station, Units 1 and 2.

In Reference 2, EGC provided commitments associated with the resolution of ADDDGV Part 21 issues for the LaSalle County Station, Units 1 and 2. This LaSalle letter committed the station to repair all susceptible safety related MOVs by the next available refueling outage.

For the remaining EGG plants, Attachment 1 contains commitments regarding the repair and resolution of the susceptible High Risk MOVs at the Oyster Creek Generating Station and Quad Cities Nuclear Power Station, Units 1 and 2. Excluding LaSalle County Station, Units 1 and 2, as discussed in the preceding paragraph, Oyster Creek Nuclear Generating Station and Quad Cities Nuclear Power Station, Units 1 and 2, are the only EGC plants with susceptible High Risk MOVs. High Risk MOVs are determined using the procedurally established NRC approved Joint Owner's Group Generic Letter (GL) 96-05 Risk Ranking Methodology and includes both High and Medium Risk GL 96-05 MOVs. Additionally, there are no susceptible Low Risk MOVs that meet the NEI definition of "High Significance" within the EGG fleet.

EGC is an active participant in the Boiling Water Reactors Owners Group (BWROG) committee that is developing corrective actions and maintenance activities to ensure proper functioning of the Anchor Darling valves. All affected EGC plants will comply with the Reference 3 recommended actions to address applicable GL 96-05 MOVs affected by the ADDDGV Part 21. The requirements for each category of valves is in accordance with the BWROG simplified recommendations and schedule for Part 21 applicable MOVs. These include the following aspects:

• Screening evaluation method for susceptible MOVs

• Wedge Pin Analysis

• Stem Rotation Check Methods

• Diagnostic Test I Evaluation Methods

• Valve Repair Methods

• Repair Schedule A brief explanation of the specific valve repair and test/inspection commitment scope as contained in Attachment 1 are as follows:

Category A - The Category A group includes Susceptible High and Medium Risk GL 96-05 MOVs with multiple Open/Close active safety function strokes. This group of valves will be repaired by the next refueling outage. For EGC, the MOVs that meet this criteria include:

Plant Valve ID Oyster Creek Nuclear Generating Station V-14-0034 Oyster Creek Nuclear Generating Station V-14-0035

U.S. Nuclear Regulatory Commission Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues August 29, 2017 Page 3 These Oyster Creek Nuclear Generating Station MOVs function as Isolation Condenser Condensate Return valves with active safety functions in both Open and Close directions.

These valves are classified as susceptible MOVs of High Significance and High Risk.

Category B - The Category B group includes Susceptible High or Medium Risk GL 96-05 MOVs and only stroke once, open or closed, to perform their safety function. This group of valves will either be repaired at the next refueling outage OR pass diagnostic tests and stem rotation checks during the next refueling outage with final repair within two refueling outages (as applicable). For EGG, the MOVs that meet this criteria include:

Plant Valve ID Quad Cities Nuclear Power Station, Unit 1 1-1201-2 Quad Cities Nuclear Power Station, Unit 1 1-1201-5 Quad Cities Nuclear Power Station, Unit 2 2-1201-2 Quad Cities Nuclear Power Station, Unit 2 2-1201-5 These Quad Cities Nuclear Power Station, Units 1 and 2, MOVs function as Reactor Water Cleanup Containment Isolation Inboard and Outboard Valves and have an active safety function to Close Only. Repairs are scheduled for next refueling outage for each unit.

Plant Valve ID Oyster Creek Nuclear Generating Station V-14-0030 Oyster Creek Nuclear Generating Station V-14-0031 Oyster Creek Nuclear Generating Station V-14-0032 Oyster Creek Nuclear Generating Station V-14-0033 These Oyster Creek Nuclear Generating Station MOVs function as Isolation Condenser Steam Supply Isolation Valves and have an active safety function to Close Only. Diagnostic testing and stem rotation checks are planned for the next refueling outage (2018). Planned repairs are contingency only given that the Oyster Creek Nuclear Generating Station is scheduled to permanently shut down in 2019. This plan is in full compliance with BWROG recommended actions.

Note that the Category B Valves listed above have a Close Only safety function such that they are not considered to be susceptible MOVs of "High Significance."

Also in Reference 1, NEI states that susceptibility reviews and repair plans for all safety related valves against the revised BWROG Guidance (Reference 3) be communicated to the NRG by December 31, 2017. EGG will communicate this information including repair schedule commitments in a separate letter in accordance with the NEI Plan.

U.S. Nuclear Regulatory Commission Commitments for Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues August29,2017 Page4 Should you have any questions or require additional information, please contact Tom Loomis at 610-765-5510.

Respectfully, ~

Jam rt::

Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Summary of Commitments cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station S. T. Gray, State of Maryland Illinois Emergency Management Agency - Division of Nuclear Safety -

(w/o attachments)

R. R. Janati - Bureau of Radiation Protection, Commonwealth of Pennsylvania -

(w/o attachments Manager, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

ATTACHMENT Summary of Commitments

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITMENT TYPE COMMITTED COMMITMENT DATE OR ONE-TIME Programmatic "OUTAGE" ACTION (Yes/No)

(YES/NO)

Category A MOVs to be repaired at the Oyster Creek Nuclear Generating Station:

MOV Number Outage(Year) Yes V-14-0034 OC1 R27(2018)

V-14-0035 OC1 R27(2018)

Category B MOVs to be repaired at the Quad Cities Nuclear Power Station, Units 1 and 2:

MOV Number Outage(Year) Yes Unit 1 1-1201-2 01 R25(2019)

Unit 1 1-1201-5 01 R25(2019)

Unit 2 2-1201-2 02R24(2018)

Unit 2 2-1201-5 02R24(2018)

Perform diagnostic testing and stem rotation checks with contingent repairs on the following Oyster Creek Nuclear Generating Station MOVs:

MOV Number Outage(Year) Yes V-14-0030 OC1 R27(2018)

V-14-0031 OC1 R27(2018)

V-14-0032 OC1 R27(2018)

V-14-0033 OC1 R27(2018)