ML22053A291
| ML22053A291 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 02/22/2022 |
| From: | Blake Purnell Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation |
| Kuntz R | |
| References | |
| Download: ML22053A291 (20) | |
Text
NRC Acceptance Review Dresden and Quad Cities Proposed Alternative to Use ASME Code Case N-921 ML22018A106
Ground Rules
- Identify yourself when speaking
- Mute if not speaking
- No regulatory decisions will be made
- Information needed to accept application for review will be discussed
- Technical adequacy will not be discussed
- Related rulemaking will not be discussed 2
Purpose
- Clarify scope of proposed alternative
- Identify information needed to accept application for review
- Identify any additional NRC approvals needed to implement proposed alternative
- Discuss timeframe for licensee to provide supplemental information and additional requests for approval 3
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Background===
- Pre-application meetings:
- 11/4/20 ML20323A033
- 12/18/20 ML20351A283
- 11/16/21 ML21333A153
- Exemption Request (withdrawn)
- 3/3/21 Application ML21063A179
- 4/8/21 NRC Letter ML21077A177
- Proposed Alternative (under acceptance review)
- 1/18/22 Application ML22018A106
- 2/8/22 NRC email ML22039A204 4
Regulatory Requirements
- 50.55a requiresSection XI for ISI/CISI at nuclear power plants
- Inspection Interval: Section XI requires ISI/CISI of components to be completed within a defined 10-year interval for service life of plant
- CoR Update Interval: Separately, 50.55a requires licensees to update the CoR every 10 years to the latest edition/addenda of Section XI incorporated into the rule
- The inspection interval and CoR update interval coincide, but they are separate requirements 5
Regulatory Requirements (Continued)
- 50.55a(z) allows the NRC staff to approve alternatives to specific ASME Code requirements incorporated by reference in 50.55a
- Inspection Interval is an ASME Code requirement that is incorporated by reference in 50.55a
- Rulemaking (preferred) or 50.55a(z) to make changes
- CoR Update Interval is an NRC requirement not an ASME Code requirement
- Rulemaking (preferred) or 50.12 exemption to make changes
- 50.55a(z) cannot be used to make changes 6
Summary of Proposed Alternative
- Adopts Code Case N-921 for current ISI/CISI intervals at Dresden and Quad Cities
- Code Case N-921 allows Inspection Interval to be extended from 10 years to 12 years
- ISI extended from 2023 to 2025
- CISI extended from 2028 to 2030
- Approved alternatives extended?
- One alternative under review extended?
7
NRC Staff Questions and Comments 8
Compliance with 50.55a
- 12-year inspection interval would not align with 120-month CoR update interval
- How will sites comply with the following 120-month requirements?
- 50.55a(g)(4)(ii) CoR update
- 50.55a(b)(5) Conditions on ISI Code Cases
- 50.55a(g)(5) program update and impracticality determinations 9
Compliance with 50.55a (continued)
- When will the CoR and ISI/CISI programs be updated? Will this update be applied to the extended portion of the current inspection interval?
- Will the latest versions of Code Cases in RG 1.147 be applied to extended portion of the inspection intervals?
- When will notifications of impracticality be submitted?
10
ISI During Extended Interval
- Approval is requested near end of the current ISI interval
- What ISI will be performed during the 2-year extension?
11
Justification for Extending Inspection Intervals at Dresden/Quad Cities
- 50.55a(z)(1) requires licensee to demonstrate proposed alternative provides acceptable level of quality and safety
- Application focuses on generic and future benefits
- Technical justification for extending current inspection intervals at Dresden/Quad Cities needs to be provided 12
Inspection Impacts
- Application states: The proposed alternative does not impact inspections required to be performed prior to the end of the license renewal period.
- This implies that the proposed alternative would not change any inservice inspections
- What was meant by this statement?
13
Next ISI/CISI Intervals
- Application request approval for current inspection interval
- Application describes benefits for next inspection interval
- Approval only for current interval cannot have any affect on a future interval
- Will the start date for the next inspection interval be revised or will the current and next inspection interval overlap?
- Describe and provide basis for any changes to the next inspection interval that are being requested as part of this application 14
Extension of Approved Alternatives
- Application lists approved alternatives that will be extended from 10 years to 12 years
- Is application requesting these extensions or will separate requests be provided?
- Provide the revised alternatives
- Provide justification for extending each alternative per 50.55a(z)(1) or z(2) 15
Additional Issues
- Application lists an alternative for extension that has not been approved
- Per LIC-109 linked requests should not be accepted 16
NRC Staff Additional Questions and Comments 17
Wrap-Up
- Summary of additional information to be provided
- Summary of additional approvals needed to implement proposed alternative
- Per LIC-109, the deadline for providing supplemental information is 13 working days
- Can licensee provide supplement and additional requests by March 16?
18
Public Comments 19
Terms and Acronyms
- ASME - American Society of Mechanical Engineers
- Section XI - Section XI (Inservice Inspection) of the ASME Boiler and Pressure Vessel Code
- CoR - Code of Record
- ISI - inservice inspection
- CISI - containment inservice inspection
- 50.55a - Title 10 of the Code of Federal Regulations Section 50.55a
- LIC-109 - Office Instruction for Acceptance Reviews 20