ML23033A098
| ML23033A098 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/03/2023 |
| From: | Nancy Salgado Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation |
| Kuntz R | |
| References | |
| EPID L-2022-LLR-0059 | |
| Download: ML23033A098 (5) | |
Text
February 3, 2023 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - AUTHORIZATION AND SAFETY EVALUATION FOR ALTERNATIVE REQUEST I6R-09, REVISION 0, (EPID L-2022-LLR-0059)
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 Plant Name and Units: Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2 Docket Nos.: 50-254 and 50-265 APPLICATION INFORMATION Submittal Date: July 25, 2022 Submittal Agencywide Documents Access and Management System (ADAMS) Accession No.: ML22206A143 Supplement Date: January 12, 2023 Supplement ADAMS Accession No.: ML23012A083 Alternative Provision: The licensee requested an alternative under Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1).
Applicable Code Edition and Addenda: The code of record for the sixth 10-year inservice inspection (ISI) interval is the 2017 Edition of the ASME Code,Section XI.
Applicable Inservice Inspection (ISI) Program Interval and Interval Start/End Dates: The sixth 10-year ISI interval is scheduled to begin on April 2, 2023, and end on April 1, 2033.
ISI Requirement: The regulations in 10 CFR 50.55a(g)(4) state, in part, that American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the applicable editions and addenda of the ASME Code to the
extent practical within the limitations of design, geometry, and materials of construction of the components. ASME Code Class MC and CC pressure retaining components and their integral attachments must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI of the applicable editions and addenda of the ASME Code, subject to the conditions listed in paragraphs (b)(2)(vi), (viii), and (ix) of section 50.55a, to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The regulations in 10 CFR 50.55a(g)(4)(ii) states, in part, that the ISI of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of Section 50.55a 18 months before start of the 120-month inspection interval, subject to the conditions listed in paragraph (b) of Section 50.55a.
Brief Description of the Proposed Alternative: The licensee proposed to use the ISI-related nondestructive examination (NDE) provisions of the 2013 Edition of the ASME Code, section XI, subject to the conditions in 10 CFR 50.55a(b)(2), for the ASME Code Class 1, 2, 3, and MC components during the first period of the sixth 10-year ISI interval. Section 5 and Table request for additional information (RAI)-3.1 of the supplement dated January 12, 2023, identify these provisions. Table RAI-3.2 of the supplement dated January 12, 2023, discusses any changes, differences, newly added, and/or more stringent NDE requirements in the 2017 Edition of ASME Code, section XI, as compared to the proposed 2013 Edition.
The licensee stated that the fifth 10-year ISI interval began on April 13, 2013, and is scheduled to end on April 1, 2023. The code of record for the fifth 10-year ISI interval is the 2007 Edition and 2008 Addenda of the ASME Code, section XI. By Safety Evaluation dated April 17, 2020 (ML20099D955), the NRC authorized the use of the 2013 Edition in lieu of the 2007 Edition and 2008 Addenda of the ASME Code, section XI, for all NDE activities in the remainder of the fifth 10-year ISI interval.
As the basis for alternative, the licensee stated that its nuclear fleet currently uses a common ASME Code edition specifically for the NDE requirements which allows the ISI-related NDE across the fleet are performed in accordance with a standardized fleet program. The standardized NDE requirements and procedures are currently based on the 2013 Edition of the ASME Code, section XI. While the licensee manages the overall ISI program requirements in site-specific documents under plant-specific code editions, the NDE program is controlled in common corporate procedures that are implemented across the licensees entire nuclear fleet.
The proposed alternative will allow the Quad Cities, Units 1 and 2, ISI-related NDE activities to remain standardized with the rest of the licensees fleet. This supports the licensees ability to maximize efficiencies, minimize human performance and procedure error traps, and optimize use of internal operating experience (OE), as all licensees fleet continue to utilize common procedures, processes, trainings, and knowledge for NDE implementation.
For additional details on the alternative request, I6R-09, Revision 0, please refer to the documents located at the ADAMS Accession Nos. identified above.
STAFF EVALUATION The NRC staff evaluated alternative request, I6R-09, Revision 0, pursuant to 10 CFR 50.55a(z)(1). The NRC staffs evaluation focused on whether there exists major difference between the licensees proposed edition (which is the 2013 Edition) and the latest editions (which is the 2017 Edition) of the ASME Code, section XI, incorporated by reference in 50.55a(a), and whether applicable conditions in 50.55a will be met. The NRC staff finds that if
these two criteria are met, the proposed alternative provides an acceptable level of quality and safety.
In evaluating the licensees proposed alternative, the NRC staff verified that, Use of the 2013 Edition as opposed to the 2017 Edition of the ASME Code,Section XI for the ISI-related NDE activities during the first inspection period of the sixth 10-year ISI interval will continue to ensure an acceptable level of quality and safety because there are no major differences between two editions and the licensee will comply with all applicable conditions in paragraph (b)(2) of 10 CFR 50.55a.
The licensee stated that it will comply with all related ISI requirements of the 2013 Edition of the ASME Code,Section XI associated with the NDE.
The licensee stated that Appendix XI, Repair/Replacement Activities for Class 3 Polyethylene Piping, of the 2017 Edition will be used since this appendix does not exist in the 2013 Edition.
The licensee confirmed that all relief and alternative requests approved by the NRC for the fifth 10-year ISI interval of Quad Cities, Units 1 and 2, will not be used during the first inspection period of the sixth 10-year ISI interval unless the licensee seeks prior NRCs approval.
The licensee confirmed that the length of Quad Cities, Units 1 and 2, fifth and sixth 10-year ISI intervals will not be affected by the approval of the alternative request, I6R-09, Revision 0, and the requirements of ASME Code,Section XI, IWA-2430, Inspection Intervals, will be complied.
Based on the above, the NRC staff determined that the licensees proposed alternative (i.e., use of the ISI-related NDE provisions of the 2013 Edition of the ASME Code,Section XI for the Class 1, 2, 3, and MC components in the first inspection period of the sixth 10-year ISI interval) is acceptable and provides reasonable assurance of structural integrity and safety.
CONCLUSION As set forth above, the NRC staff determines that the licensees proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1).
Therefore, the NRC staff authorizes the use of the alternative request, I6R-09, Revision 0, at Quad Cities, Units 1 and 2, for the duration of the first inspection period of the sixth 10-year ISI interval which is scheduled to start on April 2, 2023.
All other ASME 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: A. Rezai, NRR Date: February 3, 2023 Digitally signed by Joel S.
Joel S. Wiebe Date: 2023.02.03 Wiebe 12:16:25 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc: Listserv
ML23033A098 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DNRL/NPHP/BC NAME RKuntz SRohrer MMitchell DATE 2/2/2023 2/2/2023 2/1/2023 OFFICE NRR/DORL/LPL3/BC NAME NSalgado (JWiebe for)
DATE 2/3/2023