SVP-12-094, License Renewal Commitment for Evaluation of Operating Experience at Extended Power Uprate Levels Prior to Period of Extended Operation: Difference between revisions

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{{#Wiki_filter:ExelknExelon Generation Company, LLC www.exeloncorp.com Quad Cities Nuclear Power Station Nuclear 22710 2o6th Avenue North Cordova, I L 61242-9740 SVP-12-094 October 18, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 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  
{{#Wiki_filter:Exelkn Exelon Generation Company, LLC www.exeloncorp.com Quad Cities Nuclear Power Station Nuclear 22710 2o6th Avenue North Cordova, I L 61242-9740 SVP-12-094 October 18, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 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:==
==Subject:==
License Renewal Commitment for Evaluation of Operating Experience at Extended Power Uprate Levels Prior to Period of Extended Operation  
License Renewal Commitment for Evaluation of Operating Experience at Extended Power Uprate Levels Prior to Period of Extended Operation


==Reference:==
==Reference:==
(1) Letter from Keith R Jury (Exelon Generation Company, LLC) to U.S.NRC, "Additional Commitments for License Renewal," dated October 8, 2004 (2) NUREG 1796, "Safety Evaluation Report Related to the License Renewal of the Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2" As a result of recommendations from the Advisory Committee on Reactor Safeguards (ACRS) review of the Quad Cities Nuclear Power Station (QCNPS) License Renewal Application, Exelon Generation Company, LLC (EGC), committed in Reference 1 to perform an evaluation of operating experience at extended power uprate (EPU) levels prior to the period of extended operation. The commitment is intended to ensure that operating experience at EPU levels is properly addressed by the aging management programs (AMPs). The results of the evaluation (including experience from Dresden, QCNPS and other plants operating at EPU) are to be submitted to the NRC for review prior to entering the period of extended operation (i.e., December 14, 2012). The commitment was also documented in the Reference 2 Safety Evaluation. The purpose of this letter is to document completion of the commitment for QCNPS Units 1 and 2. There are no new regulatory commitments contained in this letter.
EGC has performed an operating experience review and evaluation to ensure that operating experience at EPU levels is properly addressed by the QCNPS AMPs. The review included experience reported by both EGC and non-EGC plants. The method of review and a summary of the results are presented below.


(1) Letter from Keith R Jury (Exelon Generation Company, LLC) to U.S.NRC, "Additional Commitments for License Renewal," dated October 8, 2004 (2) NUREG 1796, "Safety Evaluation Report Related to the License Renewal of the Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2" As a result of recommendations from the Advisory Committee on Reactor Safeguards (ACRS) review of the Quad Cities Nuclear Power Station (QCNPS) License Renewal Application, Exelon Generation Company, LLC (EGC), committed in Reference 1 to perform an evaluation of operating experience at extended power uprate (EPU) levels prior to the period of extended operation.
October 18, 2012 U. S. Nuclear Regulatory Commission Page 2 Method of Review Institute of Nuclear Power Operations (INPO) Significant Event Report, SER 5-02, "Lessons Learned from Power Uprates," was reviewed to determine if the insights provided in this document are adequately addressed by the QCNPS AMPs. No issues were identified that require additional action under an AMP. Given that this document was published in 2002, a review of more recent operating experience was completed.
The commitment is intended to ensure that operating experience at EPU levels is properly addressed by the aging management programs (AMPs). The results of the evaluation (including experience from Dresden, QCNPS and other plants operating at EPU) are to be submitted to the NRC for review prior to entering the period of extended operation (i.e., December 14, 2012). The commitment was also documented in the Reference 2 Safety Evaluation.
The INPO website contains an updated listing of events associated with operation at power uprate conditions. As of August 17, 2012, the website contained 185 operating experience reports. Each of these reports was reviewed and evaluated to determine if the Operating Experience (OE) indicated a potential aging effect for evaluation against the QCNPS AMPs. This original review identified 49 events for further review. These 49 events are discussed in more detail below (Results of Review).
The purpose of this letter is to document completion of the commitment for QCNPS Units 1 and 2. There are no new regulatory commitments contained in this letter.EGC has performed an operating experience review and evaluation to ensure that operating experience at EPU levels is properly addressed by the QCNPS AMPs. The review included experience reported by both EGC and non-EGC plants. The method of review and a summary of the results are presented below.
Results of Review A. Thirty-five of the 49 events identified issues not requiring aging management associated with license renewal. This included:
October 18, 2012 U. S. Nuclear Regulatory Commission Page 2 Method of Review Institute of Nuclear Power Operations (INPO) Significant Event Report, SER 5-02,"Lessons Learned from Power Uprates," was reviewed to determine if the insights provided in this document are adequately addressed by the QCNPS AMPs. No issues were identified that require additional action under an AMP. Given that this document was published in 2002, a review of more recent operating experience was completed.
Components not included in the scope of license renewal at QCNPS.
The INPO website contains an updated listing of events associated with operation at power uprate conditions.
" Components that are included in the scope of license renewal, but are active components that do not require aging management under license renewal.
As of August 17, 2012, the website contained 185 operating experience reports. Each of these reports was reviewed and evaluated to determine if the Operating Experience (OE) indicated a potential aging effect for evaluation against the QCNPS AMPs. This original review identified 49 events for further review. These 49 events are discussed in more detail below (Results of Review).Results of Review A. Thirty-five of the 49 events identified issues not requiring aging management associated with license renewal. This included:* Components not included in the scope of license renewal at QCNPS." Components that are included in the scope of license renewal, but are active components that do not require aging management under license renewal." OE related to systems in license renewal scope, but the specific event does not impact a component that is in license renewal (e.g., Feedwater heater internals, where only the Feedwater heater shells are in scope).* Vibration issues related to EPU conditions which QCNPS addressed with plant modifications including the main steam Acoustic Side Branch modification.
OE related to systems in license renewal scope, but the specific event does not impact a component that is in license renewal (e.g., Feedwater heater internals, where only the Feedwater heater shells are in scope).
These actions have been confirmed as successful in resolving the vibration issues associated with EPU, therefore, addition to existing AMPs is not required.B. Thirteen of the 49 events were found to be bounded by existing QCNPS AMPs including:
Vibration issues related to EPU conditions which QCNPS addressed with plant modifications including the main steam Acoustic Side Branch modification. These actions have been confirmed as successful in resolving the vibration issues associated with EPU, therefore, addition to existing AMPs is not required.
* Seven events related to steam dryer performance.
B. Thirteen of the 49 events were found to be bounded by existing QCNPS AMPs including:
The steam dryers have been replaced on both units at QCNPS with a new robust design and are managed for aging under AMP B.2.10, "Periodic Inspection of Steam Dryers." Further, the Acoustic Side Branch modification was installed to reduce Steam Dryer acoustic loading.* Two events related to in vessel components other than the steam dryers, which are being adequately managed by existing QCNPS AMPs. This includes an event identified in the previous EPU OE review completed by Dresden related to degradation of feedwater sparger bracket keepers. This component is within the scope of license renewal and requires aging management.
Seven events related to steam dryer performance. The steam dryers have been replaced on both units at QCNPS with a new robust design and are managed for aging under AMP B.2.10, "Periodic Inspection of Steam Dryers." Further, the Acoustic Side Branch modification was installed to reduce Steam Dryer acoustic loading.
This issue was previously identified as a concern at QCNPS and added to the Reactor Internals Program for periodic inspection.
Two events related to in vessel components other than the steam dryers, which are being adequately managed by existing QCNPS AMPs. This includes an event identified in the previous EPU OE review completed by Dresden related to degradation of feedwater sparger bracket keepers. This component is within the scope of license renewal and requires aging management. This issue was previously identified as a concern at QCNPS and added to the Reactor Internals Program for periodic inspection.
October 18, 2012 U. S. Nuclear Regulatory Commission Page 3* Three flow accelerated corrosion issues that are bounded by the requirements of the QCNPS Flow Accelerated Corrosion program, AMP B.1.11." One raw water related issue that is bounded by the QCNPS Open Cycle Cooling Water program, AMP B.1.13.C. One of the 49 events noted impingement induced damage which resulted in greater than anticipated wear at another station. This event noted that a recent Measurement Uncertainty Recapture uprate project may have contributed to the increased wear.QCNPS has recognized similar aging effects, which are being addressed under the corrective action program. To date the QCNPS events do not appear to be directly related to EPU conditions, but they do constitute aging effects on passive components that are in the License Renewal scope. This wear mechanism has been noted as"Mechanical Degradation" effects including:
 
: 1) Liquid Droplet Impingement, 2)Cavitation, and 3) Steam flashing.
October 18, 2012 U. S. Nuclear Regulatory Commission Page 3 Three flow accelerated corrosion issues that are bounded by the requirements of the QCNPS Flow Accelerated Corrosion program, AMP B.1.11.
Component specific corrective actions to date have included design changes to reduce the aging effects with positive results.Programmatically, QCNPS and the Exelon Fleet have been reviewing the events included in the Mechanical Degradation category and determining appropriate actions.This issue has been entered into the corrective action process to ensure that a review is completed to determine actions which require inclusion into a license renewal AMP.Exelon has been working with the industry on issues related to Mechanical Degradation, and, through NEI, has provided comments to the NRC on its draft License Renewal Interim Staff Guidance LR-ISG-2012-01, "Wall Thinning Due to Erosion Mechanisms." This ISG is currently expected to be issued as a final document in the first quarter of 2013. Exelon will review and evaluate this document, when issued, to determine if changes to existing AMP(s) or creation of new AMP(s) is appropriate to manage these aging effects.Should you have any questions concerning this letter, please contact Mr. Wally J. Beck at (309) 227-2800.Respectfully, 4Tim nley Site-ice President Quad Cities Nuclear Power Station cc: NRC Senior Resident Inspector  
" One raw water related issue that is bounded by the QCNPS Open Cycle Cooling Water program, AMP B.1.13.
-Quad Cities Nuclear Power Station}}
C. One of the 49 events noted impingement induced damage which resulted in greater than anticipated wear at another station. This event noted that a recent Measurement Uncertainty Recapture uprate project may have contributed to the increased wear.
QCNPS has recognized similar aging effects, which are being addressed under the corrective action program. To date the QCNPS events do not appear to be directly related to EPU conditions, but they do constitute aging effects on passive components that are in the License Renewal scope. This wear mechanism has been noted as "Mechanical Degradation" effects including: 1) Liquid Droplet Impingement, 2)
Cavitation, and 3) Steam flashing. Component specific corrective actions to date have included design changes to reduce the aging effects with positive results.
Programmatically, QCNPS and the Exelon Fleet have been reviewing the events included in the Mechanical Degradation category and determining appropriate actions.
This issue has been entered into the corrective action process to ensure that a review is completed to determine actions which require inclusion into a license renewal AMP.
Exelon has been working with the industry on issues related to Mechanical Degradation, and, through NEI, has provided comments to the NRC on its draft License Renewal Interim Staff Guidance LR-ISG-2012-01, "Wall Thinning Due to Erosion Mechanisms." This ISG is currently expected to be issued as a final document in the first quarter of 2013. Exelon will review and evaluate this document, when issued, to determine if changes to existing AMP(s) or creation of new AMP(s) is appropriate to manage these aging effects.
Should you have any questions concerning this letter, please contact Mr. Wally J. Beck at (309) 227-2800.
Respectfully, 4Tim nley Site-ice President Quad Cities Nuclear Power Station cc: NRC Senior Resident Inspector - Quad Cities Nuclear Power Station}}

Latest revision as of 21:00, 11 January 2025

License Renewal Commitment for Evaluation of Operating Experience at Extended Power Uprate Levels Prior to Period of Extended Operation
ML12319A410
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 10/18/2012
From: Hanley T
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
SVP-12-094
Download: ML12319A410 (3)


Text

Exelkn Exelon Generation Company, LLC www.exeloncorp.com Quad Cities Nuclear Power Station Nuclear 22710 2o6th Avenue North Cordova, I L 61242-9740 SVP-12-094 October 18, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 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:

License Renewal Commitment for Evaluation of Operating Experience at Extended Power Uprate Levels Prior to Period of Extended Operation

Reference:

(1) Letter from Keith R Jury (Exelon Generation Company, LLC) to U.S.NRC, "Additional Commitments for License Renewal," dated October 8, 2004 (2) NUREG 1796, "Safety Evaluation Report Related to the License Renewal of the Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2" As a result of recommendations from the Advisory Committee on Reactor Safeguards (ACRS) review of the Quad Cities Nuclear Power Station (QCNPS) License Renewal Application, Exelon Generation Company, LLC (EGC), committed in Reference 1 to perform an evaluation of operating experience at extended power uprate (EPU) levels prior to the period of extended operation. The commitment is intended to ensure that operating experience at EPU levels is properly addressed by the aging management programs (AMPs). The results of the evaluation (including experience from Dresden, QCNPS and other plants operating at EPU) are to be submitted to the NRC for review prior to entering the period of extended operation (i.e., December 14, 2012). The commitment was also documented in the Reference 2 Safety Evaluation. The purpose of this letter is to document completion of the commitment for QCNPS Units 1 and 2. There are no new regulatory commitments contained in this letter.

EGC has performed an operating experience review and evaluation to ensure that operating experience at EPU levels is properly addressed by the QCNPS AMPs. The review included experience reported by both EGC and non-EGC plants. The method of review and a summary of the results are presented below.

October 18, 2012 U. S. Nuclear Regulatory Commission Page 2 Method of Review Institute of Nuclear Power Operations (INPO) Significant Event Report, SER 5-02, "Lessons Learned from Power Uprates," was reviewed to determine if the insights provided in this document are adequately addressed by the QCNPS AMPs. No issues were identified that require additional action under an AMP. Given that this document was published in 2002, a review of more recent operating experience was completed.

The INPO website contains an updated listing of events associated with operation at power uprate conditions. As of August 17, 2012, the website contained 185 operating experience reports. Each of these reports was reviewed and evaluated to determine if the Operating Experience (OE) indicated a potential aging effect for evaluation against the QCNPS AMPs. This original review identified 49 events for further review. These 49 events are discussed in more detail below (Results of Review).

Results of Review A. Thirty-five of the 49 events identified issues not requiring aging management associated with license renewal. This included:

Components not included in the scope of license renewal at QCNPS.

" Components that are included in the scope of license renewal, but are active components that do not require aging management under license renewal.

OE related to systems in license renewal scope, but the specific event does not impact a component that is in license renewal (e.g., Feedwater heater internals, where only the Feedwater heater shells are in scope).

Vibration issues related to EPU conditions which QCNPS addressed with plant modifications including the main steam Acoustic Side Branch modification. These actions have been confirmed as successful in resolving the vibration issues associated with EPU, therefore, addition to existing AMPs is not required.

B. Thirteen of the 49 events were found to be bounded by existing QCNPS AMPs including:

Seven events related to steam dryer performance. The steam dryers have been replaced on both units at QCNPS with a new robust design and are managed for aging under AMP B.2.10, "Periodic Inspection of Steam Dryers." Further, the Acoustic Side Branch modification was installed to reduce Steam Dryer acoustic loading.

Two events related to in vessel components other than the steam dryers, which are being adequately managed by existing QCNPS AMPs. This includes an event identified in the previous EPU OE review completed by Dresden related to degradation of feedwater sparger bracket keepers. This component is within the scope of license renewal and requires aging management. This issue was previously identified as a concern at QCNPS and added to the Reactor Internals Program for periodic inspection.

October 18, 2012 U. S. Nuclear Regulatory Commission Page 3 Three flow accelerated corrosion issues that are bounded by the requirements of the QCNPS Flow Accelerated Corrosion program, AMP B.1.11.

" One raw water related issue that is bounded by the QCNPS Open Cycle Cooling Water program, AMP B.1.13.

C. One of the 49 events noted impingement induced damage which resulted in greater than anticipated wear at another station. This event noted that a recent Measurement Uncertainty Recapture uprate project may have contributed to the increased wear.

QCNPS has recognized similar aging effects, which are being addressed under the corrective action program. To date the QCNPS events do not appear to be directly related to EPU conditions, but they do constitute aging effects on passive components that are in the License Renewal scope. This wear mechanism has been noted as "Mechanical Degradation" effects including: 1) Liquid Droplet Impingement, 2)

Cavitation, and 3) Steam flashing. Component specific corrective actions to date have included design changes to reduce the aging effects with positive results.

Programmatically, QCNPS and the Exelon Fleet have been reviewing the events included in the Mechanical Degradation category and determining appropriate actions.

This issue has been entered into the corrective action process to ensure that a review is completed to determine actions which require inclusion into a license renewal AMP.

Exelon has been working with the industry on issues related to Mechanical Degradation, and, through NEI, has provided comments to the NRC on its draft License Renewal Interim Staff Guidance LR-ISG-2012-01, "Wall Thinning Due to Erosion Mechanisms." This ISG is currently expected to be issued as a final document in the first quarter of 2013. Exelon will review and evaluate this document, when issued, to determine if changes to existing AMP(s) or creation of new AMP(s) is appropriate to manage these aging effects.

Should you have any questions concerning this letter, please contact Mr. Wally J. Beck at (309) 227-2800.

Respectfully, 4Tim nley Site-ice President Quad Cities Nuclear Power Station cc: NRC Senior Resident Inspector - Quad Cities Nuclear Power Station