ML21314A536

From kanterella
Jump to navigation Jump to search

Summary of November 8, 2021, Meeting with Energy Harbor Nuclear Corp. Regarding Its Proposed Alternate for Examination of Steam Generator Welds at
ML21314A536
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 11/18/2021
From: Blake Purnell
Plant Licensing Branch III
To: Brown T
Energy Harbor Nuclear Corp
Purnell B
References
Download: ML21314A536 (5)


Text

November 18, 2021 LICENSEE: ENERGY HARBOR NUCLEAR CORP.

FACILITY: DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1

SUBJECT:

SUMMARY

OF NOVEMBER 8, 2021, MEETING WITH ENERGY HARBOR NUCLEAR CORP. REGARDING ITS PROPOSED ALTERNATE FOR EXAMINATION OF STEAM GENERATOR WELDS AT DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 (EPID L-2021-LLR-0067)

By application dated September 13, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21256A119), Energy Harbor Nuclear Corp. (the licensee) submitted a request for a proposed alternative to certain requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, Codes and standards, for Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). Specifically, in accordance with 10 CFR 50.55a(z)(1),

the application requests U.S. Nuclear Regulatory Commission (NRC) approval to increase the inservice inspection (ISI) interval for the steam generator (SG) welds and nozzle inner radii from 10 years to 30 years. These ISI requirements are specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI, as incorporated by reference in 10 CFR 50.55a.

The proposed alternative is based on the methodology described in Electric Power Research Institute (EPRI) Report No. 3002015906, Technical Bases for Inspection Requirements for PWR [Pressurized-Water Reactor] Steam Generator Class 1 Nozzle-to-Vessel Welds and Class 1 and Class 2 Vessel Head, Shell, Tubesheet-to-Head, and Tubesheet-to-Shell Welds, 2019 (ADAMS Accession No. ML20225A141), and EPRI Report No. 3002014590, Technical Bases for Inspection Requirements for PWR Steam Generator Feedwater and Main Steam Nozzle-to-Shell Welds and Nozzle Inside Radius Sections, April 2019 (ADAMS Accession No. ML19347B107) (collectively, the EPRI Reports).

On November 8, 2021, an observational public meeting was held between the NRC staff and representatives for the licensee to discuss the draft NRC staff request for addition information (RAI) for the proposed alternative (ADAMS Accession No. ML21301A099). Specifically, the meeting focused on draft RAI-3, RAI-6, and RAI-12. The meeting notice and agenda are available in ADAMS at Accession No. ML21300A145. A list of attendees is enclosed.

The Davis-Besse SGs were replaced in 2014. The SG welds and nozzle inner radii were subject to preservice inspection (PSI), but the first set of ISIs has not been completed. The licensee stated that two weld inspections have not been completed. In draft RAI-12, the NRC staff stated, in part, that:

By letters dated January 11 and July 16, 2021 (ADAMS Accession Nos.

ML20352A155 and ML21167A355, respectively), the NRC approved proposed alternatives to extend the inspection interval for SG welds and nozzle inner radii at Vogtle Electric Generating Plant, Units 1 and 2 (Vogtle), and Millstone Power

Station, Unit No. 2 (Millstone), respectively. These approved alternatives were both based, in part, on the EPRI Reports and were identified as precedents in Section 7 of the proposed alternative for Davis-Besse. Vogtle, Millstone, and EPRI generally concluded that the ISI interval for SG welds and nozzles could be extended when only PSI without any other post-PSI examinations had been performed. However, in the associated NRC safety evaluations, the NRC staff found that these general conclusions were unacceptable because, in part, these general conclusions do not account for the effect of the combination of the most significant parameters or the added uncertainty of low probability events.

During the public meeting, the licensee stated that its application addressed the significant parameters and uncertainties discussed in the NRC safety evaluations for the precedents. The licensee noted that its application conservatively assumed that only PSI had been performed.

In addition, the licensee stated that the ISIs have not found any indications for the SG welds and nozzle inner radii that have been performed. Therefore, the licensee concluded that there was a small likelihood of finding anything during the ISI of the remaining welds. The licensee stated that Tables E-1, E-2, and E-3 in the application include all the important parameters. The licensee also stated that the probabilities of leakage and rupture of a SG weld are several orders of magnitude below the acceptance criteria of 10-6 per year and the change in risk associated with extending the ISIs from 10 years to 30 years is small.

The NRC staff stated that it appears the licensee is making a risk-based argument, whereas the NRC staff uses risk-informed decision-making. The NRC staff stated that, consistent with the NRCs risk-informed principles, there needs to be some performance monitoring (i.e., ISI) of the SG welds and nozzle inner radii. The NRC staff further stated there are still some unknowns and, therefore, the probabilities determined by the PROMISE code used by the licensee may be impacted.

In draft RAI-6, the NRC staff requests that the licensee provide the following information:

Discuss the acceptability of the KIC value used for the beginning and ending of heatup and cooldown transients for calculating the probability of failure and probability of leakage of the Davis-Besse SG welds and nozzle inside radii.

During the meeting, the NRC staff stated that it would be acceptable for the licensee to reference acceptable KIC values used for other plants.

In draft RAI-3, the NRC staff requests that the licensee provide the plant-specific analysis used to support its application. The licensee clarified that the plant-specific analysis is provided in Tables E-1, E-2, and E-3 of the application. The licensee stated that the plant-specific analysis used representative components and stress multipliers. The licensee also stated it performed plant-specific runs of the PROMISE code, and that it could provide the input and output files in response to draft RAI-3. The NRC staff stated that it would consider whether performing an audit of the input and output files through an online portal would be beneficial.

The licensee stated that it would let the NRC project manager know in a few days how long it would take to respond to the RAI. The NRC project manager noted that the licensee requested approval by March 2022, and, if the licensee took an extended amount of time to respond to the RAI, the NRC staff may not be able to complete its review within the requested timeframe.

There were no public comments and no public meeting feedback forms were received. No regulatory decisions were made at this meeting.

Please direct any inquiries to me at 301-415-1380 or Blake.Purnell@nrc.gov.

/RA/

Blake Purnell, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES NOVEMBER 8, 2021, MEETING WITH ENERGY HARBOR NUCLEAR CORP.

Name Affiliation Blake Purnell NRC John Tsao NRC Angie Buford NRC David Rudland NRC Dan Widrevitz NRC Carolyn Wolf NRC Jack Bell NRC David Dijamco NRC Phil Lashley Energy Harbor Kathleen Nevins Energy Harbor Alan Scheanwald Energy Harbor Daniel Patten Energy Harbor Andrew Bishop Energy Harbor Kevin Allen Energy Harbor Scott Chesworth Structural Integrity Dedhia Dilip Structural Integrity Mo Uddin Structural Integrity Nat Cofie Structural Integrity Enclosure

Notice ML21300A145; Summary ML21314A536 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME BPurnell SRohrer NSalgado BPurnell DATE 11/17/21 11/17/21 11/18/21 11/18/21