RS-14-292, Proposed Alternative Testing Requirements for ASME Class 1, 2, and 3 Motor Operated Valves (MOV) in CPS MOV Testing Program
| ML14335A540 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/01/2014 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-14-292 | |
| Download: ML14335A540 (4) | |
Text
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10 CFR 50.55a December 1,2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461
Subject:
Proposed Alternative Testing Requirements for ASME Class 1, 2, and 3 Motor Operated Valves (MOV) in CPS MOV Testing Program Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (a)(3)(i), Exelon Generation Company, LLC (EGC), hereby requests NRC approval of a request for a proposed alternative to the requirements of the American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," (ASME OM Code), with the 2006 addenda version of OMN-01 for Clinton Power Station (CPS).
The applicable section of the OM Code requires that all motor operated valves (MOVs), within the scope of the Code Case, shall be full-cycle exercised at least once per refueling cycle. CPS will be transitioning to a 12 month fuel cycle beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). This request proposes to allow testing of these valves on the current 24 month testing frequency. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the two year frequency that these valves have historically been tested at during the "refueling/maintenance outage." The details of this request are provided in the attachment to this letter.
EGC requests approval of this relief request by December 31, 2015 to support scheduling for future refueling outages following the CPS transition to a 12 month fuel cycle.
There are no regulatory commitments contained in this letter.
r R.
Patrick R. Simpson Manager Licensing Exelon Generation Company, LLC December 1,2014 U. S. Nuclear Regulatory Commission Page 2 Should you have any questions concerning this letter, please contact Mr. Timothy Byam at (630) 657-2818.
Attachment:
10 CFR 50.55a Request Number 2204 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i) cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector Clinton Power Station Illinois Emergency Management Agency Division of Nuclear Safety
ATTACHMENT Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
Page 1 of 2 10 CFR 50.55a Request Number 2204 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
Alternative Provides Acceptable Level of Quality and Safety
- 1. ASME Code Component(s) Affected All ASME Class 1, 2, and 3 motor-operated valves (MOVs) currently included in the Clinton Power Station (CPS) MOV Testing Program.
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," 2004 Edition (ASME OM Code-2004) with the 2006 addenda version of OMN-01.
3. Applicable Code Requirement
CODE CASE OMN-1 (2006 addenda)
Subsection 3.6.1 Normal Exercising Requirements:
All MOVs, within the scope of this Code Case, shall be full-cycle exercised at least once per refueling cycle with the maximum time between exercises to be not greater than 24 months.
Full-cycle operation of an MOV, as a result of normal plant operations or Code requirements, may be considered an exercise of the MOV, if documented. If full-stroke exercising of an MOV is not practical during plant operation or cold shutdown, full-stroke exercising shall be performed during the plant's refueling outage.
4. Reason for Request
In accordance with 10 CFR 50.55a(a)(3)(i), relief is requested from the requirements of OM Code Case OMN-01, Subsection 3.6.1. The proposed alternative would provide an acceptable level of quality and safety.
Subsection 3.6.1 requires the applicable valves to be tested each refueling outage not to exceed 24 months. CPS is currently on a 24 month fuel cycle, thus, the applicable valves are currently being tested every 24 months. For financial reasons, CPS will be transitioning to a 12 month fuel cycle beginning in the Spring of 2015; performing a refueling outage every 12 months. CPS intends to alternately schedule one short outage that will focus primarily on refueling activities with minimal maintenance activities (i.e., "refueling only outages") and one more traditional refueling outage consisting of both refueling activities and maintenance activities (i.e., "refueling/maintenance outages"). Based on the above referenced code case requirements, CPS will be required to test all valves every 12 months. This in effect cuts the
ATTACHMENT Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(1)
Page 2 of 2 allowable testing frequency of these valves in half (i.e., 12 months vs 24 months). This change in outage scheduling and its OM Code implications do not provide a compensating increase in level of quality or safety.
This relief request is being pursued to maintain the current (i.e., 24 month) exercise frequency for the CPS valves covered by OMN-01. This will allow CPS to maintain a minimal amount of testing during the "refueling only outage" and still maintain the same level of quality and safety by continuing the 24 month frequency that these valves have historically been tested at during the "refueling/maintenance outage."
5. Proposed Alternative and Basis for Use
CPS proposes to continue performing the exercise tests required by Subsection 3.6.1 of OMN-01 for the applicable valves every 24 months, as opposed to the required once per refueling cycle not to exceed 24 months.
By maintaining the current testing frequency at once every 24 months, CPS maintains the current acceptable level of quality and safety with regards to valves covered by OMN-01. This statement is supported by the years of testing these valves at a 24 month interval.
In summary, CPS is proposing to perform the exercise test for all of the valves covered by OMN-01 every 24 months. This will maintain the current time between tests at two years.
6. Duration of Proposed Alternative
The proposed alternative identified in this relief request shall be utilized during the Third 10-Year 1ST Interval.