ML21316A051

Notification of Deviation from Pressurized Water Reactor Owners Group (PWROG) Report WCAP-17451-P, Revision 1, Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections

ML21316A051
Person / Time
Site:	Ginna
Issue date:	11/12/2021
From:	Swift P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WCAP-17451-P, Rev 1 ER-AA-4003
Download: ML21316A051 (1)

Text

Paul M. Swift Site Vice President RE. Ginna Nuclear Power Plant Exelon Generation 1503 Lake Rd.

Ontario. NY 14519 315-791-5200 Office www.exeloncorp.com November 12, 2021 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 RE . Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Notification of Deviation from Pressurized Water Reactor Owners Group (PWROG) Report WCAP-17451-P, Revision 1, "Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections" Exelon Generation Company, LLC (EGC) is providing notification that Ginna, Unit 1, has processed a deviation from a Nuclear Energy Institute (NEI) 03-08, "Guideline for the Management of Materials Issues," Revision 4, "Needed" work product element in PWROG report WCAP-17 451-P, Revision 1, with appropriate justification and documentation.

Control Rod Guide Tube (CRGT) Guide Card Wear Measurement (GCWM) is a "Needed" requirement specified in WCAP-17451-P, Revision 1, which the document listed in MRP-227, Revision 1-A containing the examination requirements for CRGT guide cards . Ginna Unit 1 has elected to defer wear measurements of its CRGT guide cards from G1 R43 refueling outage in Fall 2021 to G1R49 refueling outage in Fall 2030.

NEI 03-08 allows deviation from "Needed" elements with the appropriate justification and documentation . The deviation was approved with the appropriate levels of EGC management.

Attachment 1 provides the Ginna Unit 1 Control Rod Guide Tube (CRGT) Guide Card Wear Measurements Deviation - Technical Evaluation ECP-21-000368.

This notification is provided for information only. No approval or action is expected. If you have any questions, please contact Mr. Chris Bradshaw at (315) 791-3246.

There are no regulatory commitments contained in this letter.

Respectfully,

- ~Q ~~

Paul Swift Attachment 1: Ginna Unit 1 Control Rod Guide Tube (CRGT) Guide Card Wear Measurements Deviation -Technical Evaluation ECP-21-000368 cc: RC Regional Administrator, Region 1 NRC Project Manager, Ginna NRC Resident Inspector, Ginna (e-mail)

Attachment 1 Ginna Unit 1 Control Rod Guide Tube (CRGT) Guide Card Wear Measurements Deviation - Technical Evaluation ECP-21-000368

ER-AA-4003 Revision 5 ATTACHMENT 2 MDMP Deviation Form Page 1 of 1 Utility: Exelon Applicable Site(s) and Unit No. : R.E. Ginna Nuclear Power Plant Unit 1 Utility Contact(s): Diane Render - Fleet Reactor Internals Program Engineer, Peter Logar - Ginna Programs Engineering Manager, Kayla Iazzetta - Ginna Reactor Internals Program Engineer, Heather Malikowski - Fleet Asset Protection Programs Manager Issue Program (IP) activity or document: WCAP-17451, Revision l , "Reactor Internals Guide Tube Wear -

Westinghouse Domestic Fleet Operational Projections" Scope I Description of Deviation: Control Rod Guide Tube (CRGT) Guide Card wear measurements require reinspection no later than 10 years after baseline inspection per WCAP-17451, Revision 1. The deviation defers this reinspection to a maximum of20 EFPY after baseline inspection per WCAP-17451, Revision 2, the latest industry approved revision of the guidance. The justification is based on Ginna's technical evaluation of their baseline guide card wear measurements using the latest approved industry guidance.

Reason for Deviation: Technical evaluation ECP-21-000368 supports deviation from the WCAP-17451, Revision 1 requirement of Guide Card Wear Measurement reinspection 10 years after baseline inspection. The technical evaluation results align with WCAP-17451, Revision 2 requirements for reinspection 20 EFPY past baseline inspections. Revision 2 of this document has not yet been NRC approved by reference in WCAP-17096-NP, Revision 3, "Reactor Internals Acceptance Criteria Methodology and Data Requirements," but has been industry accepted.

IR Number:_0=-4.:....4.:....4'"'"7..;:.0...:..43"'-------------- EC Number: ECP-21-000368 Time Frame the Deviation will be in Effect: The deviation will be in effect until WCAP-17096-NP, Revision 3, which references WCAP-17451, Revision 2, has been approved for use by the NRC.

Deviation to this IP document is classified as MANDATOR~

_i(ri,L ~ ~ ~'.gitally signed by lazzetta, Kayla Prepared By: l "'(J~ Date 2021092309:0312-04*00* Date:

Digitally signed by Rice, Mathew Rice1 Mathew M. M.

Station Program Manager: Date: 2021.09.23 08:56:23 -05'00' Date:

Dlgltally signed by Everett. Richard Everett, Richard Site Engineering Director: Date: 2021.0927 09'.50:05 -04'00' Date:

Ren d er D.Ian e DN"n=Render, Digitally signed Render, Diane by Diane Corporate IP Owner:______' ____0 *_,._,20_21_"*_*2_71_0'1_*"_s--04_*00_*- - - - - - - - - - - Date:

Digitally signed by Cirilli, James J.

Corporate Asset Management Sr. Mgr: Cirilli, James J. DN: cn= Cirilli, Jam es J.

b'aie* i!Qi!1 Q9 i!7 14*1 Q*!i!I Q4'QQ' Date:

D*iRado, Mark o'*"'"""ed*yolRado,M"k ON: cn=DiRado, Mark Corporate Prag rams Director: ______________0'_'"_20_ 2 "_

0*_ 1 *_

~ '_"_' ,,._

_*0_0* _ _ __

Date:

Digitally signed by Swift, Paul Site Vice President:

Swift, Paul DN: cn=Swift, Paul Date: 2021.10.0612:57:37 --04'00' Date:

Digitally signed by Greenlee, Greenlee, Scot A. ~~~,~*=Greenlee, Scot A.

Senior VP of Eng& Tech Services: Date: 2021.1O.13 09:40:S8 -05'00' Date:

Concurrence Independent of Exelon NIA Date:

(for " Mandatory" IP work product elements only)

ECP-21-000368 RO TECHNICAL EVALUATION Page 2 of 4 ECP No.: ECP-21-000368 Rev. No.: 0000 Reason for Evaluation/Scope:

Ginna Unit 1 has elected to defer the wear measurement reinspection of the Control Rod Guide Tube (CRGT) guide cards from the 2021 refueling outage (G1R43) to the 2030 refueling outage (G1R49). This is a deviation from the NEI 03-08 [Ref l]

"Needed" requirement specified in WCAP-17451-P, Revision 1 [Ref2]. WCAP-17451-P, Revision 1, is listed in MRP-227, Revision 1-A [Ref3], and contains the examination requirements for CRGT guide cards.

In support of license extension activities there are nine Primary Components that must be inspected as a part of MRP-227 for a Westinghouse Pressurized Water Reactor. One of these components is the CRGT guide cards. As a part of the upper internals, CRGT's provide guidance of the Rod Cluster Control Assemblies (RCCAs) above the core fuel assemblies. Each CRGT houses one RCCA that is made up of long, slender rodlets attached to a drive rod by a coupling fixture called a spider. The drive rod steps the RCCA into and out of the fuel assemblies. If needed for core shutdown, the RCCAs can also be released to allow them to drop into the fuel assembly. The individual rodlets are guided inside the CRGTs by approximately one-inch-thick guide cards. The guide cards are located about one foot apart and are guided by a continuous guidance assembly located at the bottom of the lower CRGT assembly. Guide card wear is a primary concern due to the possibility of the loss of guidance of the control rodlets inside of a CRGT. The unsupported length of a rodlet will increase if a loss of guidance occurs.

The examination frequency and coverage for this component is detailed in WCAP-17451-P, Revision 1. Based on the guidance in Section 5.4 of WCAP-17451-P, Revision 1, an initial Guide Card Wear Measurement (GCWM) should take place between 38 and 42 EFPY at 14xl4 CRGT-designed plants such as Ginna. The goal of this recommendation is to ensure that baseline inspections are performed in the Green Zone (i.e. while the guide cards have no low/wear). Ginna's initial GCWM was performed during the 2011 refueling outage at 33.15 EFPY. Based on these initial results, a technical evaluation, ECP 000595 [Ref 4 ], was performed to identify the timeline of the next required inspection as recommended by WCAP-17451-P, Revision 2 [Ref 5]. The results of this technical evaluation show that several guide cards at Ginna have orientations that will exceed W3 and/or W4 wear requirements prior to 27 EFPY, but no CRGT reaches the Red Zone prior to 27 EFPY. Therefore, the maximum reinspection interval of20 EFPY allowed by WCAP-17451-P, Revision 2, can be applied to all CRGTs at Ginna.

Using this evaluation, the next inspection is required in the fall of 2030 (G 1R49). The fall of 2030 outage is 19 years from the last performed inspection in the fall of 2011 during GlR35 and beyond the current operating license for Ginna (ending on 9/18/2029 at approximately 50 EFPY).

Per WCAP-17451-P, Revision 1, the reinspection interval for GCWM is limited to 10 years. This reinspection interval commits Ginna to reinspect during the fall 2021 refueling outage (GlR43) as this is the revision referenced in MRP-227-lA.

As a part of the ongoing review for WCAP-17096-NP, Revision 3 [Ref 6], the U.S. Nuclear Regulatory Commission (NRC) is currently reviewing WCAP-17451-P, Revision 2, which allows for a reinspection interval of up to 20 EFPY. The original intent for the Ginna GCWM reinspection plan was to utilize the 20 EFPY reinspection interval allowed by WCAP-17451-P, Revision 2. The NRC acceptance of WCAP-17451-P, Revision 2, is currently delayed due to ongoing issue resolution with other acceptance criteria methodologies within WCAP-17096-NP, Revision 3. The NRC acceptance of WCAP-17451-P, Revision 2, guidance would allow Ginna to defer reinspection from the 2021 outage (10 years past baseline inspection) until the 2030 outage (20 EFPY past baseline inspection). If Ginna's current operating license is not extended, the site would not need to perform GCWM reinspection before decommissioning. Due to delay of the NRC's review of both WCAP-17096-NP, Revision 3, and WCAP-17451-P, Revision 2, Ginna now requires a deviation from the 10 year reinspection interval of WCAP-17451-P, Revision 1.

Per NEI 03-08, a "Needed" work product is "to be implemented wherever possible, but alternative approaches are acceptable".

When a utility determines that "Needed" work product elements will not be fully implemented or will not be implemented in a manner consistent with their intent, or when a work product will not be implemented within the timeframe specified, a technical justification shall be developed. This evaluation justifies delay of the Ginna Unit 1 CRGT GCWM reinspection.

Detailed Evaluation:

During the 2020 outage, Ginna performed a full core offload to complete VT-3 and EVT-1 examinations of the reactor vessel and internals and the UT examinations of the baffle-to-former bolts per the requirements of MRP-227, Revision 1-A. The CRGT GCWM was not completed during the 2020 outage due to the expectation that the guidance in WCAP-17451-P, Revision 2, would be NRC approved by reference in WCAP-17096-NP, Revision 3, before the 2021 refueling outage (G 1R43).

ECP-21-000368 RO TECHNICAL EVALUATION Page 3 of 4 ECP No.: ECP-21-000368 Rev. No.: 0000 The GCWM scope would have required an assumption of an additional level of risk in the 2020 outage associated with coordination and execution of the large scope of activities, and there was added cost without any technical benefit. The 2021 refueling outage (G 1R43) presents the same level of risk as the 2020 outage and the outage window is shorter. If the outage window is extended, it would be solely to accommodate this exam. Deferring the GCWM to 2030 refueling outage (G 1R49) facilitates a favorable outage work risk profile and cost with no compromise on safety.

There is a 20 EFPY maximum reinspection interval in WCAP-17451-P, Revision 2, which is the latest industry approved guidance per NEI 03-08, but it is not yet approved by NRC. This requirement is less conservative than the 10 year reinspection interval guidance in WCAP-17451 -P, Revision 1. After the NRC's acceptance of WCAP-17451-P, Revision 2, the next GWCM would not need to occur before the end of Ginna's current operating license. If Ginna were to pursue a license extension to operate 80-years, the GCWM would take place during the 2030 refueling outage (G 1R49). Performing the CRGT GCWM in 2030 would allow the site ample time to plan for the cost, labor, and time required to complete the examinations.

Per the guidance ofWCAP-17451-P, Revision 1, reinspection of the CRGT guide cards should occur during the Yellow Zone and before the start of the Red Zone. The technical evaluation contained in ECP-19-000595, Revision 0, shows that the CRGTs with the most wear found during the 2011 baseline GCWM inspection will not reach the Red zone prior to the maximum reinspection interval of 20 EFPY allowed by WCAP-17451-P, Revision 2. The results of this evaluation justify the deviation from the GCWM 10 year reinspection interval of WCAP-17451-P, Revision 1. In addition to the results from Ginna's baseline GCWM in 20 11 and the technical evaluation, the industry accepted guidance of WCAP-17451-P, Revision 2, provides technical support of deferring the reinspection to 2030.

Conclusion/Findings:

The proposed Ginn a Unit 1 CRGT GCWM deferral from G 1R43 to G 1R49 is supported through use of the baseline 2011 GCWM results, existing station risk mitigation processes, and bounded by the reinspection timeframe of 20 EFPY in the industry accepted WCAP-17451-P, Revision 2, to ensure safety. Deferral risks are abated through several avenues such as:

expansion of industry CRGT GCWM data during the deferral period and planning time for refueling outage G 1R49 to potentially perform unanticipated corrective maintenance.

References:

1. NEI 03-08, Revision 4, "Guideline for the Management of Materials Issues," October 2020.

2. WCAP-17451-P, Revision 1, "Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections," October 2013.

3. MRP-227, Revision 1-A, "Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines", Product ID 3002017 168, December 2019.

4. ECP-19-000595, Revision 0, "Reactor Vessel Guide Card Wear Evaluation, January 2020.

5. WCAP-17451-P, Revision 2, "Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections, November 2018.

6. WCAP-17096-NP, Revision 3, "Reactor Internals Acceptance Criteria Methodology and Data Requirements, July 2019