ML12291A831
| ML12291A831 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/22/2012 |
| From: | Heather Jones NRC/NRR/DLR/RPOB |
| To: | Pacilio M Exelon Generation Co |
| Jones H, 415-4054 | |
| References | |
| TAC ME8961, TAC ME8962 | |
| Download: ML12291A831 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 22, 2012 Mr. Michael J. Pacilio Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUB..IECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2: REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGE TO COMMITMENT FOR LICENSE RENEWAL (TAC NOS. ME8961 AND ME8962)
Dear Mr. Pacilio:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated May 18, 2012, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12173A423), Exelon Generation Company, LLC submitted a change to a commitment for license renewal regarding visual examinations for identifying aging effects at Quad Cities Nuclear Power Station, Units 1 and 2.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a request for additional information clarification call with members of your staff on October 17, 2012, it was agreed that you would provide a response by December 3,2012. If you have any questions, please contact me by telephone at 301-415-4054 or bye-mail at Heather.Jones@nrc.gov.
Sincerely, Heather M. Jones, Project Manager Subsequent Renewal, Guidance, and Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosure:
Request for additional information cc w/encl: Listserv
REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGE TO COMMITMENT FOR LICENSE RENEWAL EXELON GENERATION COMPANY, LLC.
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 LICENSE NOS. DPR-29 AND DPR-30
Background
Exelon letter dated May 18, 2012, stated that American Society of Mechanical Engineers (ASME) Code VT examinations will not be performed in cases where license renewal visual examinations are outside the formal jurisdiction of the ASME Code,Section XI, for the One Time Inspection, Selective Leaching, Periodic Inspection of Plant Heating System, and Periodic Inspection of Components Subject to Moist Air Environments programs.
In the safety evaluation report for the license renewal of the Dresden and Quad Cities Nuclear Power Stations (NUREG-1796), the U.S. Nuclear Regulatory Commission (NRC or the staff) frequently based its conclusions on statements in the license renewal application (LRA) and responses to requests for information (RAls) that ASME Code VT examinations would be used.
Two examples are:
LRA Section A.1.24, Selective Leaching of Materials (Quad Cities), as modified by Exelon letter RS-03-181 dated October 3,2003, states:
The selective leaching of materials aging management program includes numerous one-time inspections of components of the different susceptible materials to determine if loss of material due to selective leaching is occurring.
These inspections will consist of visual inspection consistent with ASME Section XI VT -1 visual inspection requirements.
NUREG-1796, Section 3.0.3.11.2, Selective Leaching of Materials, states:
The staff concurs with the applicant that the program will provide that aging will be managed because visual inspection will be performed using ASME Section XI VT-1 requirements....
LRA Section A.2.8, Periodic Inspection of Plant Heating System (Quad Cities), as modified by Exelon letter RS-04-046 dated March 25, 2004, states:
The inspection will consist of a visual inspection for the presence of general, crevice, galvanic, and pitting corrosion. The inspection will be performed in accordance with ASME Code requirements. Certified NDE examiners will conduct a VT-3 visual inspection.
NUREG-1796, Section 3.3.2.3.7, Periodic Inspection of Plant Heating System, states:
Inspections will be performed in accordance with ASME Code requirements and certified NDE examiners will conduct a VT-3 visual examination. The staff finds this acceptable because the inspections will identify the aging effects managed by this program.
ASME Code,Section XI, paragraphs IWA-2211 and IWA-2213, provide requirements such as resolving characters, inspection distance offset, illumination, and distinguishing and ENCLOSURE
- 2 differentiation of colors for remote examinations. In addition, subarticle IWA-2200 contains requirements for surface coverage during examinations.
Issue The staff's conclusions in the safety evaluation report were based on statements in the LRA and RAI responses that ASME Code VT examinations would be performed. By citing ASME Code Section XI VT-1 and VT-3 techniques, the program includes requirements essential to an effective examination, regardless of whether the component is within the jurisdiction of the ASME Code. Without the assurance that the Code requirements are in place, and with the limited level of detail provided in the commitment change letter, the staff can no longer determine that aging will be adequately managed.
In addition, the commitment change states, "[t]he examinations will be completed by an examiner certified to perform Section XI VT-3 examinations to provide consistent, high-quality examinations." However, the commitment change does not describe the training and qualification for the equivalent roles of the Level II (e.g., interpret and evaluate results) or Level III (e.g., develop and qualify procedures) for non-Code inspections.
Request Provide justification that the methods used for license renewal visual examinations outside of Code examinations will be effective in detecting aging. For each of the affected programs discussed in the May 18, 2012, letter, include details on the visual examination work instructions (e.g. illumination, examination distance, examination coverage, acceptance criteria) that demonstrate that the staff's conclusions that relied on VT -1 or VT-3 examinations remain valid.
In addition, state the qualifications for personnel involved in writing work instructions, interpreting results, establishing acceptance criteria, and developing and qualifying procedures related to the non-Code inspections.
October 22, 2012 Mr. Michael J. Pacilio Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2: REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGE TO COMMITMENT FOR LICENSE RENEWAL (TAC NOS. ME8961 AND ME8962)
Dear Mr. Pacilio:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated May 18, 2012, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12173A423), Exelon Generation Company, LLC submitted a change to a commitment for license renewal regarding visual examinations for identifying aging effects at Quad Cities Nuclear Power Station, Units 1 and 2.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a request for additional information clarification call with members of your staff on October 17, 2012, it was agreed that you would provide a response by December 3,2012. If you have any questions, please contact me by telephone at 301-415-4054 or bye-mail at Heather.Jones@nrc.gov.
Sincerely, IRA!
Heather M. Jones, Project Manager Subsequent Renewal, Guidance, and Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosure:
Request for additional information cc w/encl: Listserv DISTRIBUTION:
See next page ADAMS Accession No'.. ML12291A831
- concurrence via email OFFICE PM:RSRG/DLR LA:RPB2/DLR*
BC: RSRG IDLR PM: RSRG IDLR NAME HJones IKing YDiaz-Sanabria HJones DATE 10/22/12 10/22/12 10/22/12 10/22/12 OFAC~LRECORDCOPY
Letter to Mr. Pacilio from H. Jones dated October 22,2012
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2: REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGE TO COMMITMENT FOR LICENSE RENEWAL (TAC NOS. ME8961 AND ME8962)
DISTRIBUTION:
E-MAIL:
PUBLIC RidsNrrDlr Resource HJones YDiaz-Sanabria