RS-12-203, Supplement to Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request I5R-01

Supplement to Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request I5R-01

ML12333A262
Person / Time
Site:	Quad Cities
Issue date:	11/28/2012
From:	Simpson P Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-12-203
Download: ML12333A262 (4)

Text

RS-12-203 10 CFR 50.55a November 28, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 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:

Supplement to Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request I5R-01

Reference:

Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. NRC, "Quad Cities Nuclear Power Station, Units 1 and 2, Fifth Interval Inservice Inspection Program Plan and Relief Requests," dated September 28, 2012 In the referenced letter, Exelon Generation Company, LLC (EGC) submitted relief requests associated with the fifth inservice inspection (ISI) interval for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. Upon further review of Relief Request 15R-01, it became apparent that 10 CFR 50.55a(a)(3)(ii) is the appropriate relief criterion for this request. Therefore, EGC requests to supersede the version of 15R-01 in the referenced letter with the version in the attachment to this letter in its entirety.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

Attachment:

10 CFR 50.55a Request Number 15R-01, Revision 1 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Quad Cities Nuclear Power Station

)

1 RS-12-203 November 28, 2012 u.s. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 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 10 CFR 50.55a

Subject:

Supplement to Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request 15R-01

Reference:

Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. NRC, "Quad Cities Nuclear Power Station, Units 1 and 2, Fifth Intervallnservice Inspection Program Plan and Relief Requests," dated September 28, 2012 In the referenced letter, Exelon Generation Company, LLC (EGC) submitted relief requests associated with the fifth inservice inspection (lSI) interval for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. Upon further review of Relief Request 15R-01, it became apparent that 10 CFR 50.55a(a)(3)(ii) is the appropriate relief criterion for this request. Therefore, EGC requests to supersede the version of 15R-01 in the referenced letter with the version in the attachment to this letter in its entirety.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

Respectfully, Patrick R. Simpson Manager - Licensing

Attachment:

10 CFR 50.55a Request Number 15R-01, Revision 1 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Quad Cities Nuclear Power Station

)

1 RS-12-203 November 28, 2012 u.s. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 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 10 CFR 50.55a

Subject:

Supplement to Quad Cities Nuclear Power Station Fifth Inservice Inspection Interval Relief Request 15R-01

Reference:

Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. NRC, "Quad Cities Nuclear Power Station, Units 1 and 2, Fifth Intervallnservice Inspection Program Plan and Relief Requests," dated September 28, 2012 In the referenced letter, Exelon Generation Company, LLC (EGC) submitted relief requests associated with the fifth inservice inspection (lSI) interval for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. Upon further review of Relief Request 15R-01, it became apparent that 10 CFR 50.55a(a)(3)(ii) is the appropriate relief criterion for this request. Therefore, EGC requests to supersede the version of 15R-01 in the referenced letter with the version in the attachment to this letter in its entirety.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

Respectfully, Patrick R. Simpson Manager - Licensing

Attachment:

10 CFR 50.55a Request Number 15R-01, Revision 1 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Quad Cities Nuclear Power Station

ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 1 of 3)

Request for Relief for Inspection of Standby Liquid Control Nozzle Inner Radius In Accordance with 10 CFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty without Compensating Increase in Level of Quality and Safety 1.

ASME Code Component(s) Affected:

1 IWB-2500, Table IWB-2500-1 B-D B3.100 Inspection of Standby Liquid Control Nozzle Inner Radius Unit 1: N10 Unit 2: N10 Unit 1: M73106 Sh. 1 Unit 2: M-3116 Sh. 1 2.

Applicable Code Edition and Addenda

The Inservice Inspection Program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2007 Edition through the 2008 Addenda.

===3.

Applicable Code Requirement===

IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.

Table IWB-2500-1 requires a volumetric examination to be performed on the inner radius section of all reactor pressure vessel nozzles each inspection interval.

===4.

Reason for Request===

Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with the Code requirements impose hardship without a compensating increase in the level of quality and safety.

The Standby Liquid Control (SBLC) nozzle, as shown in Figure 15R-01.1, is designed with an integral socket to which the boron injection piping is fillet welded. The SBLC nozzle is located near the bottom of the vessel in an area which is inaccessible for ultrasonic examinations from the inside surface of the RPV. Therefore, ultrasonic examinations would need to be performed from the outside diameter of the RPV. As shown in Figure 15R-01.1, the ultrasonic beam would need to travel through the full thickness of the vessel into a complex cladding/socket configuration. These geometric and material reflectors inherent in the design prevent a meaningful examination from being performed on the inner radius of the SBLC nozzle.

Code Class:

Reference:

Examination Category:

Item Number:

==

Description:==

Component Number:

Drawing Number:

ATTACHMENT 10 CFR SO.SSa Relief Request ISR-01 Revision 1 (Page 1 of 3)

Request for Relief for Inspection of Standby Liquid Control Nozzle Inner Radius In Accordance with 10 CFR SO.SSa(a)(3)(ii)

Hardship or Unusual Difficulty without Compensating Increase in Level of Quality and Safety

1.

ASME Code Component(s) Affected:

Code Class:

Reference:

Examination Category:

Item Number:

==

Description:==

Component Number:

Drawing Number:

1 IWB-2500, Table IWB-2500-1 B-D B3.100 Inspection of Standby Liquid Control Nozzle Inner Radius Unit 1: N10 Unit 2: N10 Unit 1: M~3106 Sh. 1 Unit 2: M-3116 Sh. 1

2.

Applicable Code Edition and Addenda

The Inservice Inspection Program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2007 Edition through the 2008 Addenda.

3.

Applicable Code Requirement

IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.

Table IWB-2500-1 requires a volumetric examination to be performed on the inner radius section of all reactor pressure vessel nozzles each inspection interval.

4.

Reason for Request

Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with the Code requirements impose hardship without a compensating increase in the level of quality and safety.

The Standby Liquid Control (SBLC) nozzle, as shown in Figure 15R-01.1, is designed with an integral socket to which the boron injection piping is fillet welded. The SBLC nozzle is located near the bottom of the vessel in an area which is inaccessible for ultrasonic examinations from the inside surface of the RPV. Therefore, ultrasonic examinations would need to be performed from the outside diameter of the RPV. As shown in Figure 15R-01.1, the ultrasonic beam would need to travel through the full thickness of the vessel into a complex cladding/socket configuration. These geometric and material reflectors inherent in the design prevent a meaningful examination from being performed on the inner radius of the SBLC nozzle.

ATTACHMENT 10 CFR SO.SSa Relief Request ISR-01 Revision 1 (Page 1 of 3)

Request for Relief for Inspection of Standby Liquid Control Nozzle Inner Radius In Accordance with 10 CFR SO.SSa(a)(3)(ii)

Hardship or Unusual Difficulty without Compensating Increase in Level of Quality and Safety

1.

ASME Code Component(s) Affected:

Code Class:

Reference:

Examination Category:

Item Number:

==

Description:==

Component Number:

Drawing Number:

1 IWB-2500, Table IWB-2500-1 B-D B3.100 Inspection of Standby Liquid Control Nozzle Inner Radius Unit 1: N10 Unit 2: N10 Unit 1: M~3106 Sh. 1 Unit 2: M-3116 Sh. 1

2.

Applicable Code Edition and Addenda

The Inservice Inspection Program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2007 Edition through the 2008 Addenda.

3.

Applicable Code Requirement

IWB-2500 states that components shall be examined and tested as specified in Table IWB-2500-1.

Table IWB-2500-1 requires a volumetric examination to be performed on the inner radius section of all reactor pressure vessel nozzles each inspection interval.

4.

Reason for Request

Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with the Code requirements impose hardship without a compensating increase in the level of quality and safety.

The Standby Liquid Control (SBLC) nozzle, as shown in Figure 15R-01.1, is designed with an integral socket to which the boron injection piping is fillet welded. The SBLC nozzle is located near the bottom of the vessel in an area which is inaccessible for ultrasonic examinations from the inside surface of the RPV. Therefore, ultrasonic examinations would need to be performed from the outside diameter of the RPV. As shown in Figure 15R-01.1, the ultrasonic beam would need to travel through the full thickness of the vessel into a complex cladding/socket configuration. These geometric and material reflectors inherent in the design prevent a meaningful examination from being performed on the inner radius of the SBLC nozzle.

ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 2 of 3)

In addition, the inner radius socket attaches to the piping which injects boron at locations far removed from the nozzle. Therefore, the SBLC nozzle inner radius is not subjected to turbulent mixing conditions that are a concern at other nozzles.

Compliance with the applicable Code requirements would require an ultrasonic examination to be performed on the outside diameter of the RPV. Geometric and material reflectors would prevent a meaningful examination, resulting in inaccurate data. Based on this, the Code requirements impose hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(a)(3)(ii).

===5.

Proposed Alternative and Basis for Use===

As an alternate examination, Exelon Generation Company, LLC will perform a VT-2 visual examination of the subject nozzles at Quad Cities Nuclear Power Station, Units 1 and 2, each refueling outage in conjunction with the Class 1 System Leakage Test.

6.

Duration of Proposed Alternative:

Relief is requested for the Fifth Ten-Year Inspection Interval Quad Cities Nuclear Power Station Units 1 and 2.

===7.

Precedents===

Quad Cities Nuclear Power Station, Units 1 and 2, fourth inspection interval relief request 14R-01 was authorized in an NRC safety evaluation dated January 28, 2004.

The Fifth inspection interval relief request utilizes a similar approach that was previously approved.

Dresden Nuclear Power Station, Units 2 and 3, fourth inspection interval relief request 14R-01 was authorized in an NRC safety evaluation dated September 4, 2003.

ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 2 of 3)

In addition, the inner radius socket attaches to the piping which injects boron at locations far removed from the nozzle. Therefore, the SBLC nozzle inner radius is not subjected to turbulent mixing conditions that are a concern at other nozzles.

Compliance with the applicable Code requirements would require an ultrasonic examination to be performed on the outside diameter of the RPV. Geometric and material reflectors would prevent a meaningful examination, resulting in inaccurate data. Based on this, the Code requirements impose hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(a)(3)(ii).

5.

Proposed Alternative and Basis for Use:

As an alternate examination, Exelon Generation Company, LLC will perform a VT-2 visual examination of the subject nozzles at Quad Cities Nuclear Power Station, Units 1 and 2, each refueling outage in conjunction with the Class 1 System Leakage Test.

6.

Duration of Proposed Alternative:

Relief is requested for the Fifth Ten-Year Inspection Interval Quad Cities Nuclear Power Station Units 1 and 2.

7.

Precedents:

Quad Cities Nuclear Power Station, Units 1 and 2, fourth inspection interval relief request 14R-01 was authorized in an NRC safety evaluation dated January 28,2004.

The Fifth inspection interval relief request utilizes a similar approach that was previously approved.

Dresden Nuclear Power Station, Units 2 and 3, fourth inspection interval relief request 14R-01 was authorized in an NRC safety evaluation dated September 4,2003.

ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 2 of 3)

In addition, the inner radius socket attaches to the piping which injects boron at locations far removed from the nozzle. Therefore, the SBLC nozzle inner radius is not subjected to turbulent mixing conditions that are a concern at other nozzles.

Compliance with the applicable Code requirements would require an ultrasonic examination to be performed on the outside diameter of the RPV. Geometric and material reflectors would prevent a meaningful examination, resulting in inaccurate data. Based on this, the Code requirements impose hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(a)(3)(ii).

5.

Proposed Alternative and Basis for Use:

As an alternate examination, Exelon Generation Company, LLC will perform a VT-2 visual examination of the subject nozzles at Quad Cities Nuclear Power Station, Units 1 and 2, each refueling outage in conjunction with the Class 1 System Leakage Test.

6.

Duration of Proposed Alternative:

Relief is requested for the Fifth Ten-Year Inspection Interval Quad Cities Nuclear Power Station Units 1 and 2.

7.

Precedents:

Quad Cities Nuclear Power Station, Units 1 and 2, fourth inspection interval relief request 14R-01 was authorized in an NRC safety evaluation dated January 28,2004.

The Fifth inspection interval relief request utilizes a similar approach that was previously approved.

Dresden Nuclear Power Station, Units 2 and 3, fourth inspection interval relief request 14R-01 was authorized in an NRC safety evaluation dated September 4,2003.

ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 3 of 3)

FIGURE 15R-01.1 2 INCH STANDBY LIQUID CONTROL NOZZLE 6 1/4" Cladding Pipe (Stainless Stee 1.453" 1/8" Min

/

3/4" R Min 6 3/8"--- 3 3/4" ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 3 of 3)

FIGURE 15R-01.1 2 INCH STANDBY LIQUID CONTROL NOZZLE Pipe (Stainless Steel)

Safe-End (Stainless Steel)

Nozzle Cladding ATTACHMENT 10 CFR 50.55a Relief Request 15R-01 Revision 1 (Page 3 of 3)

FIGURE 15R-01.1 2 INCH STANDBY LIQUID CONTROL NOZZLE Pipe (Stainless Steel)

Safe-End (Stainless Steel)

Nozzle Cladding