RS-24-127, Response to Request for Additional Information Related to Alternative Request RV-08, Revision 1
| ML24338A265 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/03/2024 |
| From: | Humphrey M Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-24-127 | |
| Download: ML24338A265 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-24-127 10 CFR 50.55a December 3, 2024 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:
Response to Request for Additional Information Related to Alternative Request RV-08, Revision 1
References:
- 1. Letter from M. D. Humphrey (Constellation Energy Generation, LLC) to U.S.
NRC, "Alternative Request RV-08, Revision 1, Associated with Safety Relief Valve Testing Interval," dated August 20, 2024
- 2. Email from L. Cruz Rosado (U.S. NRC) to K. Nicely (Constellation Energy Generation, LLC), "Request for Additional Information RE: Quad Cities 1 and 2 - Alternative RV-08, Rev 1, SRV Testing Interval," dated November 6, 2024 In Reference 1, Constellation Energy Generation, LLC (CEG) submitted an alternative request to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), associated with the sixth 10-year inservice testing interval at Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS).
Specifically, CEG requested to implement Revision 1 to alternative RV-08 for the testing interval of the QCNPS Target Rock safety relief valves.
In Reference 2, the NRC requested additional information that is needed to complete review of alternative RV-08, Revision 1. In response to this request, CEG is providing the attached information.
December 3, 2024 U.S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Ken Nicely at (779) 231-6119.
Respectfully, Mark Humphrey Sr. Manager Licensing Constellation Energy Generation, LLC
Attachment:
Response to Request for Additional Information Related to Alternative Request RV-08, Revision 1 cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector - QCNPS Humphrey, Mark D.
Digitally signed by Humphrey, Mark D.
Date: 2024.12.03 15:03:43 -06'00'
ATTACHMENT Response to Request for Additional Information Related to Alternative Request RV 08, Revision 1 Page 1 RAI-EMIB-1 At QCNPS, there is a single Target Rock 3-Stage, model 74-67F, safety relief valve installed on the main steam lines inside the drywell for each reactor unit. The NRC-authorized Alternative Request RV-08 allows the licensee to test the Target Rock SRV in each unit every 48 months from the previous test, rather than every outage that would have been required to meet ASME OM Code, Division 1, Mandatory Appendix I, "Inservice Testing of Pressure Relief Devices in Water-Cooled Reactor Nuclear Power Plants," Section I-1320, "Test Frequencies, Class 1 Pressure Relief Valves," paragraph (a), 5-Yr Test Interval, for a minimum 20-percent sample every 24 months.
Revision 1 to RV-08 retains the 48-month test interval previously authorized but proposes to alter the start date of the 48-month interval such that it starts upon installation in the plant rather than on the date of the as-left set pressure test. Revision 1 to Alternative Request RV-08 does not alter the requirement in ASME OM Code, Appendix I, Section I-1320, paragraph (a), to test Class 1 pressure relief valves at least once every 5 years beginning from the date of the as-left set pressure test for each valve. In addition, Revision 1 to Alternative Request RV-08 does not alter the requirement in ASME OM Code, Appendix I, Section I-1320, paragraph (b), Replacement with Pretested Valves, subparagraph (2), to test valves removed from service within 12 months of removal from the system.
The licensee is requested to discuss its plans for controlling the time period (i.e., "when a valve is in storage" as stated in the submittal) between the arrival of the SRV on site from the testing facility and its installation in the plant to meet the ASME OM Code requirement that the test interval for any installed valve shall not exceed 5 years.
Response
Constellation Energy Generation, LLC (CEG) controls the time period of each Target Rock SRV through reviews of the paperwork provided by the vendor to ensure the Code intervals are met. A preventive maintenance (PM) activity (i.e., PM 181816-01) is performed annually to ensure certification dates of valves in storage are acceptable and that valves will not exceed the 5-year requirement. PM 35901-01 and PM 35902-01 are also performed annually to verify valves were tested within the required timeframe and documents the installation date and how long they are installed before being removed.