ML042740132
| ML042740132 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/02/2004 |
| From: | Tam P NRC/NRR/DLPM/LPD1 |
| To: | Crane C AmerGen Energy Co |
| References | |
| TAC MC1653 | |
| Download: ML042740132 (7) | |
Text
November 2, 2004 Mr. Christopher M. Crane President and Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - EXEMPTION FROM THE REQUIREMENTS OF APPENDIX J OF 10 CFR PART 50, REGARDING MAIN STEAM ISOLATION VALVE LEAKAGE TESTING (TAC NO. MC1653)
Dear Mr. Crane:
The Commission has approved the enclosed exemption from specific requirements of Title 10 of the Code of Federal Regulations, Part 50, Appendix J, for Oyster Creek Nuclear Generating Station. This action is in response to an application from Mr. M. P. Gallagher, Director, Licensing and Regulatory Affairs, AmerGen Energy Company, LLC, dated December 23, 2003.
The Nuclear Regulatory Commission staff reviewed the application and has granted the exemption. Specifically, this permanent exemption permits AmerGen to perform leak testing of the main steam isolation valves at reduced pressure, but not lower than 20 psig.
A copy of the exemption is enclosed and is being forwarded to the Office of the Federal Register for publication.
Sincerely,
\\RA\\
Peter S. Tam, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Exemption cc w/encl: See next page
November 2, 2004 Mr. Christopher M. Crane President and Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - EXEMPTION FROM THE REQUIREMENTS OF APPENDIX J OF 10 CFR PART 50, REGARDING MAIN STEAM ISOLATION VALVE LEAKAGE TESTING (TAC NO. MC1653)
Dear Mr. Crane:
The Commission has approved the enclosed exemption from specific requirements of Title 10 of the Code of Federal Regulations, Part 50, Appendix J, for Oyster Creek Nuclear Generating Station. This action is in response to an application from Mr. M. P. Gallagher, Director, Licensing and Regulatory Affairs, AmerGen Energy Company, LLC, dated December 23, 2003.
The Nuclear Regulatory Commission staff reviewed the application and has granted the exemption. Specifically, this permanent exemption permits AmerGen to perform leak testing of the main steam isolation valves at reduced pressure, but not lower than 20 psig.
A copy of the exemption is enclosed and is being forwarded to the Office of the Federal Register for publication.
Sincerely,
\\RA\\
Peter S. Tam, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Exemption cc w/encl: See next page DISTRIBUTION PUBLIC PD1-1 R/F CHolden RLaufer PTam JJolicoeur SLittle OGC ACRS GHill (2)
DLPM DPR GMatakas, RI Adams Accession No. ML042740132 OFFICE PDI-1/PM PDI-1/LA OGC SPSB/SC PDI-1/SC PDI/D DLPM/D NAME PTam SLittle HMcurren RDennig*
RLaufer CHolden LMarsh DATE 10/5/04 10/4 /04 10/21/04 9/16/04 10/21/04 10/21/04 10/25/04
- SE transmitted by memo of 9/16/04.
OFFICIAL RECORD COPY
7590-01-P UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION AMERGEN ENERGY COMPANY, LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 EXEMPTION
1.0 BACKGROUND
AmerGen Energy Company, LLC (the licensee), is the holder of Facility Operating License No. DPR-16, which authorizes operation of the Oyster Creek Nuclear Generating Station (OCNGS).
The facility consists of a boiling-water reactor (BWR), located in Ocean County, New Jersey. The license provides, among other things, that the facility is subject to all rules, regulations, and orders of the Nuclear Regulatory Commission (NRC, the Commission) now or hereafter in effect.
2.0 REQUEST/ACTION Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix J, Option B,Section III.B., Type B and C Tests, states, in part, that containment leakage tests must demonstrate that the sum of the leakage rates at accident pressure of Type B tests, and pathway leakage rates from Type C tests, is less than the performance criterion (La) with margin as specified in the Technical Specifications (TSs). In this context, accident pressure, Pa, was previously analyzed to be 35 psig at OCNGS. Accordingly, for main steam isolation valves (MSIVs), leakage rate testing is to be done at this peak containment calculated pressure, i.e., 35 psig.
By letter dated December 23, 2003, the licensee requested a permanent exemption from the requirements of the subject provision of Appendix J, such that the MSIVs may be tested at lower pressures but not lower than 20 psig. By separate application also dated December 23, 2003, the licensee proposed to revise the OCNGS TSs, Section 4.5.D, to specify the lower test pressure and leakage rate; the NRC staff will communicate the results of its review of this proposed license amendment by separate correspondence.
In summary, in order for the NRC staff to approve the lower leakage rate test pressure for the TSs, the licensee first needs an exemption from the subject regulation.
3.0 DISCUSSION Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 50 when (1) the exemptions are authorized by law, will not present an undue risk to public health or safety, and are consistent with the common defense and security; and (2) when special circumstances are present. These circumstances include situations where the regulation would not serve the underlying purpose of the rule.
OCNGS has two main steam lines, each having two MSIVs. The MSIVs are 24-inch angled globe valves of Y configuration. The cup-shaped poppet moves on a centerline that is 45 degrees upward from the horizontal centerline of the piping run. Each MSIV is oriented to provide effective sealing in the direction of post-accident containment atmosphere leakage, i.e.,
the forward direction, as compared to the between-the-valve Type C test which tends to unseat the inboard valve. The design of the steam lines is such that the preferred method of Type C testing is through the use of a between-the-valves test tap. Periodic Type C testing verifies that the leakage assumed in the radiological analysis is not exceeded. The licensee is requesting this exemption and associated amendment to the TSs in order to reduce the probability of lifting the inboard MSIVs during testing. Testing of the two MSIVs simultaneously at Pa, by pressurizing between the valves tends to lift the disc of the inboard valve. This results in test results which may not accurately reflect the isolation capabilities of the MSIVs. Therefore, testing the two MSIVs simultaneously at Pa does not serve the underlying purpose of the rule.
In conjunction with the proposed exemption, the licensee proposed an amendment to the TSs, specifying testing at a minimum of 20 psig between the 2 MSIVs, and an acceptance pathway leakage rate of 11.9 standard cubic feet per hour. The proposed 20 psig pressure is greater than one-half of Pa, and the licensee stated that it would avoid lifting the disc of the inboard valve. As shown in the OCNGS Updated Final Safety Analysis Report, Figure 6.2-3, the primary containment pressure following a design-basis loss-of-coolant accident reaches its peak within 2 to 3 seconds, and rapidly drops below 20 psig. The NRC staff has previously approved testing of MSIVs at reduced pressure at many other BWR plants. Industry experience in testing these valves at a pressure in the range of 20 psig and with an acceptance criterion of approximately 11.9 standard cubic feet per hour has been shown to be effective in determining the condition of these valves.
The underlying purpose of the requirements of 10 CFR Part 50, Appendix J, Option B,Section III.B is to demonstrate by periodic testing that the primary reactor containment will be able to perform its function of providing a leak-tight barrier against uncontrolled release of radioactivity to the environment. As stated above, the NRC staff examined the licensees rationale to support the exemption and concluded that MSIV leakage testing at accident pressure does not serve the underlying purpose of the rule, and fulfillment of the proposed alternative testing criteria would demonstrate leak-tightness of the MSIVs. Thus, the underlying purpose of the subject regulation is achieved and served by the licensees proposed criteria.
Based upon a consideration of the information submitted by the licensee, the NRC staff concludes that the licensees proposed reduced test pressure for Type C testing of MSIVs is justified.
Therefore, the NRC staff concludes that pursuant to 10 CFR 50.12(a)(2), special circumstances are present in that application of the Appendix J requirements does not serve the underlying purpose of the rule.
4.0 CONCLUSION
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12(a), the exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. Also, special circumstances are present. Therefore, the Commission hereby grants the licensee an exemption from the requirements of 10 CFR Part 50, Appendix J, Option B,Section III.B for OCNGS. Specifically, this permanent exemption permits the licensee to perform leakage testing of the MSIVs at reduced pressure, but not lower than 20 psig.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (69 FR 63562).
This exemption is effective upon issuance.
Dated at Rockville, Maryland, this 2nd day of November 2004.
FOR THE NUCLEAR REGULATORY COMMISSION
\\RA\\
Ledyard B. Marsh, Director Division of Licensing Project Management Office of Nuclear Reactor Regulation
Oyster Creek Nuclear Generating Station cc:
Chief Operating Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Nuclear Services AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Oyster Creek Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Vice President - Mid-Atlantic Operations AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 John E. Matthews, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations Support AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Director Licensing AmerGen Energy Company, LLC Nuclear Group Headquarters P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Oyster Creek and Three Mile Island AmerGen Energy Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Oyster Creek Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Regulatory Assurance Manager Oyster Creek AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 Pete Eselgroth, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348