RA-11-076, Submittal of Relief Request to Extend the Fourth Inservice Inspection (ISI) Interval
| ML112730210 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/30/2011 |
| From: | Jesse M Exelon Corp, Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-11-076 | |
| Download: ML112730210 (5) | |
Text
10 CFR 50.55a RA-11-076 September 30,2011 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 NRC Docket No. 50-219
Subject:
Submittal of Relief Request to Extend the Fourth Inservice Inspection (lSI)
Interval In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), Exelon Generation Company, LLC (Exelon), is requesting relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components."
Relief Request R-41 proposes to extend the Inservice Inspection (lSI) interval by three months. The fourth lSI interval is currently scheduled to end on October 14, 2012. We request your approval by September 30, 2012.
There are no regulatory commitments in this letter.
If you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.
Respectfully,
Attachment:
Relief Request R-41 cc:
Regional Administrator, Region I, USNRC USNRC Senior Resident Inspector, OCNGS Project Manager [OCNGS] USNRC
Attachment Relief Request R-41
Relief Request R-41 Concerning Extension of the Fourth Inspection Interval in Accordance with 10 CFR 50.55a(a)(3)(i) lof 1.0 ASME CODE COJ\\tIPONENTS AFFECTED:
Code Class:
Reference:
Examination Category:
Item Number:
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Description:==
Component Numbers:
1,2, and 3 IWA-2430, IWA-2432 All Applicable All Applicable Extension of the fourth Inservice Inspection (lSI) interval Class I, 2, and 3 Components and Component Supports 2.0 APPLICABLE CODE EDITION AND ADDENDA:
The fourth interval Inservice Inspection (lSI) program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 1995 Edition. 1996 Addenda.
3.0 APPLICABLE CODE REQUIREMENTS:
Paragraph IWA-2430, "Inspection Intervals", requires the inspection interval to be determined by calendar years following placement of the plant into commercial service.
Paragraph IWA-2432, "Inspection Program B", requires that each inspection interval consist of a ten-year duration, except as modified by IWA-2430(d) which permits the inspection interval to be reduced or extended by as much as one year, provided that successive intervals are not altered by more than one year from the original pattern of intervals.
4.0 REASON FOR REQUEST:
Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.
Currently, the Oyster Creek Nuclear Generating Station (OCNGS) fourth lSI interval is scheduled to end on October 14,2012, with the successive fifth lSI interval scheduled to commence on October 15,2012. The fourth interval began on October 15,2002, and as currently scheduled, is a normal ten-year interval. IWA-2430(d)(I) allows for an interval to be reduced or extended by as much as one year provided successive intervals are not altered by more than one year from the original pattern. The requirement also clarifies that when taking the +/- one year in a given interval, the start and end dates for successive intervals need not be revised. This last portion of the paragraph allows plants to take the extension in a given interval, and either leave the successive interval dates as-is or revise the successive interval dates at the same time, essentially carrying the one year adjustment through the following intervals.
Relief Request R-41 Concerning Extension of the Fourth Inspection Interval in Accordance with 10 CFR 50.55a(a)(3)(i) 2 of In the OCNGS second lSI interval, a five month extension was taken from October 15, 1991 to March 14,1992. In OCNGS's third lSI interval, a seven month extension was taken from March 1 2002 to October 14,2002. Each of these extensions, one in the second interval and one in the third interval, were implemented in a manner that adjusted the successive interval dates by the same extended period of time. These actions combined adjusted the original pattern of intervals by the code allowed one year (i.e., 12 months). It is noted that the U.S. Nuclear Regulatory Commission approved a similar three month extension to the third lSI interval to account for the actual outage dates at that time (see Section 7.0, Relief Request No. 27 for OCNGS). For this third interval extension, the start of the successive fourth interval was not shifted, but rather remained as scheduled and overlapped with the end of the third interval. Since that time, OCNGS outage schedules have not changed significantly and there now is a need for a similar three month extension to the fourth interval.
OCNGS is currently in the fourth lSI interval, which as stated above, is scheduled as a normal ten year interval. The third inspection period of this fourth interval runs from October 15,2009 through October 14,2012. The last refueling outage for the plant was OCIR23, which was completed in early December 2010. With the current interval and outage schedule, this would be the only outage in the third period and the last outage in the fourth interval. The next outage, OCIR24, is scheduled to begin in late October 2012 and will fall just outside of the current interval.
As such, OCNGS requests a three month extension to the fourth interval in order to include OCIR24 in the fourth interval for the completion of exams and to permit time to generate the subsequent Owner's inservice inspection summary report and close out the interval. The code-required sequencing and distribution of examinations will be maintained and are not impacted by this relief.
5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE:
OCNGS will modify the current fourth interval end date from October 14,2012 to January 14,2013. This three month extension will be implemented such that the fifth interval start will also be adjusted three month to commence on January 15,2013, and the interval will be scheduled as a ten year inspection interval. The scheduling of examinations within this fifth interval will be performed in accordance with the new interval code of record requirements for sequencing and distribution of examinations.
Since no alternatives to examination methods or distribution/sequencing of examinations is proposed in this relief request, and this extension is of a relatively short duration in order to encompass a refueling outage, OCNGS considers that this alternative provides an acceptable level of quality and safety, and is consistent with provisions of 10 CFR 50.55a(a)(3)(i).
Relief Request R-41 Concerning Extension of the Fourth Inspection Interval in Accordance with 10 CFR 50.55a(a)(3)(i) 3 of 6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested to modify the end date of the OCNGS fourth lSI interval.
With implementation of this relief, the current fourth lSI interval will end on January 14, 2013, and the next (fifth) lSI interval will begin on January 15,2013.
7.0 PRECEDENTS
The following similar relief requests have been approved:
- 1) Relief Request I3R-Ol was approved by the u.S. Nuclear Regulatory Commission for Limerick Station, Units 1 and 2 in a Safety Evaluation Report dated January 24,2007 (ML063390103).
- 2) Relief Request I3R-Ol was approved by the U.S. Nuclear Regulatory Commission for Byron Station, Units 1 and 2 in a Safety Evaluation Report dated September 7,2006 (ML062280606).
- 3) Relief Request No. 27 was approved for the third lSI interval by the U.S. Nuclear Regulatory Commission for the Oyster Creek Nuclear Generating Station in a Safety Evaluation Report dated May 23, 2002 (TAC NO. MB2942).