ML22327A263

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Authorization and Safety Evaluation for Alternative Request No. I6R-01, Rev. 0
ML22327A263
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 11/30/2022
From: Robert Kuntz
Plant Licensing Branch III
To: Rhoades D
Constellation Energy Generation
Kuntz R
References
EPID L-2022-LLR-0036
Download: ML22327A263 (4)


Text

November 30, 2022 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 - AUTHORIZATION AND SAFETY EVALUATION FOR ALTERNATIVE REQUEST NO. I6R-01, REV. 0 (EPID L-2022-LLR-0036)

LICENSEE INFORMATION Recipients Name and Address: Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555 Licensee: Constellation Energy Generation, LLC (CEG)

Plant Name and Units: Quad Cities Power Station Units 1 and 2 (Quad Cities)

Docket Nos.: Quad Cities Unit 1: 50-254 Quad Cities Unit 2: 50-265 APPLICATION INFORMATION Submittal Date: March 25, 2022 Submittal Agencywide Documents Access and Management System (ADAMS) Accession No.: ML22084A597 Supplement Date: August 10, 2022 Supplement ADAMS Accession No.: ML22223A084 Alternative Provision: The applicant requested an alternative under Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.55a(z)(2).

Applicable Code Edition and Addenda: American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME BPV Code), 2017 Edition with no addenda.

Applicable Inservice Inspection (ISI) Program Interval: The sixth 10-year interval which is scheduled to begin April 2, 2023, and end on April 1, 2033 ISI Requirements: For ASME BPV Code Class 1 nozzles, the ISI requirements are those specified in Paragraph IWB-2411 of the ASME BPV Code, Section XI, which requires the licensee to perform volumetric examinations of the inside radii of reactor pressure vessel nozzles as specified in ASME BPV Code, Section XI, Table IWB-2500-1 (Examination Category B-D) once every 10-Year ISI interval.

Examination Category B-D, Item No. B3.100, Nozzle Inside Radius Section Note (6) of Table IWB-2500-1 (B-D) allows a VT-1 visual examination of the nozzle inner radius in accordance with IWB-2500(g) in lieu of the volumetric examination. IWB-2500(g) references mathematical criteria in IWB-2500(f), which must be met in order to perform the visual examination in lieu of the volumetric examination. NRC conditioned IWB-2500 (f) and (g) in 10 CFR 50.55a(b)(2)(xxi)(B) to require, in part, that the licensee maintain records demonstrating that the criteria in IWB-2500(f) are met, in the case that the licensee elects to perform the visual examination in lieu of the volumetric examination.

Brief Description of the Proposed Alternative: In Section 4 of I6R-01, Rev. 0, the licensee described the geometric configuration of the Quad Cities Standby Liquid Control (SBLC) nozzles. The licensee stated that performing the required volumetric examination of the SBLC nozzles would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The licensee proposed to perform a VT-2 visual examination of the SBLC nozzle as part of the Class 1 leakage test and maintain compliance with technical specification surveillance requirements for reactor coolant pressure boundary leakage, as an alternative to the volumetric examination or VT-1 examination.

For additional details on the licensees request, please refer to the documents located at the ADAMS Accession Nos. identified above.

STAFF EVALUATION The licensee cited several hardships for this case, including the need for low-angle ultrasonic probes, complex metallurgy due to the unique socket configuration of the nozzle, the lack of qualified ultrasonic equipment, and high dose rates for plant personnel. The NRC staff reviewed these factors and determined that, taken together, they constitute a hardship.

As part of their review of the proposed alternative, the NRC staff requested additional information on materials of construction, the examination history of the nozzle-to-vessel weld, the examination history of the subject nozzle inner radius, and the potential to perform a VT-1 examination in accordance with IWB-2500(g) of Section XI. The licensee responded in the supplement dated August 10, 2022. The licensee stated that the reactor pressure vessel plates were fabricated out of SA-302 Grade B low-alloy steel and that the SBLC nozzle forging was fabricated out of SA-336 low-alloy steel. The licensee stated that the nozzle-to-vessel weld has received four ultrasonic examinations with no identified indications. The licensee stated that, while the SBLC nozzle inner radius has not received ultrasonic examination, it has received VT-2 examination. The licensee further stated that plant personnel has not identified any relevant conditions or signs of leakage as part of the VT-2 examination. Finally, the licensee stated that performance of the VT-1 examination in accordance with IWB-2500(g) of Section XI also presents a hardship due to the removal of vessel internals components that would be required to access to the SBLC nozzle inner radius location.

The NRC staff finds that the examination history of the nozzle-to-vessel weld provides confidence in the performance of the nozzle inner radius, since the weld was constructed with similar materials and experiences a similar environment as the nozzle inner radius location.

Regarding the potential for a VT-1 examination, the NRC staff determined that removal of various lower plenum vessel internals components to perform the examination constitutes a hardship. Overall, the NRC staff finds that the licensees responses in the supplement dated August 10, 2022, are acceptable.

CONCLUSION The NRC staff determined that compliance with the specified requirements results in a hardship or unusual difficulty without a compensating increase in quality or safety.

The proposed alternative provides reasonable assurance of leak tightness of the subject components.

The NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(2).

The NRC staff authorizes the use of proposed alternative I6R-01, Rev. 0, at Quad Cities 1 and 2 for the sixth inservice inspection interval which is scheduled to begin April 2, 2023, and to end on April 1, 2033.

All other ASME BPV Code, Section XI, requirements for which an alternative was not specifically requested and authorized remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: David Dijamco Date: November 30, 2022 Digitally signed by Nancy Nancy L. L. Salgado Date: 2022.11.30 Salgado 13:20:50 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc: Listserv

ML22327A263 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DNRL/NVIB/BC NRR/DORL/LPL3/BC NAME RKuntz SRohrer DWidrevitz (acting) NSalgado DATE 11/23/2021 11/25/2022 11/5/2022 11/30/2022