ML23181A150

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Combined Response to Request for Additional Information and Supplemental Information in Support of LAR to Relocate Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report
ML23181A150
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 06/30/2023
From: Lueshen K
Constellation Energy Generation
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23181A149 List:
References
RS-23-079
Download: ML23181A150 (1)
v • d • e


Text

4300 Winfield Road Warrenville, IL 60555 Constellation 630 657 2000 Office PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 RS-23-079 June 30, 2023 10 CFR 2.390 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

References:

LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-37 4 Combined Response to Request for Additional Information and Supplemental Information in Support of LAR to Relocate Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report

1. Letter from K. Lueshen (Constellation Energy Generation, LLC) to Nuclear Regulatory Commission, "License Amendment Request - Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report," dated November 10, 2022 (ML22332A449)
2. Letter from K. Lueshen (Constellation Energy Generation, LLC) to Nuclear Regulatory Commission, "Supplemental Information Regarding License Amendment Request-Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report," dated January 10, 2023. (ML23010A227)
3. Email from Nuclear Regulatory Commission to J. Taken (Constellation Energy Generation, LLC), "LaSalle PTLR amendment request (EPID L-2022-LLA-0173)," dated June 2, 2023.

In Reference 1, Constellation Energy Generation, LLC (CEG) requested an amendment to Renewed Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2 to replace the existing reactor vessel heatup and cooldown rate limits and the pressure and temperature limit curves with references to the Pressure and Temperature Limits Report (PTLR).

June 30, 2023 U.S. Nuclear Regulatory Commission Page2 In Reference 2, CEG submitted supplemental information to correct editorial errors found following submittal of Reference 1.

A regulatory audit to support the NRC's review of the license amendment request was performed from April 10, 2023 to May 5, 2023.

In Reference 3, NRC requested additional information to support its review of Reference 1.

This letter is being submitted to respond to the Reference 3 and to provide supplemental information to support the NRC's review of Reference 1.

The following are intended to replace the items submitted in Reference 1:

o "LaSalle County Generating Station Unit 1 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18," LAS-FLU-001-R-005, Rev. 1 (Non-Proprietary) o "LaSalle County Generating Station Unit 1 Fluence Methodology Report," LAS-FLU-001-R-010 Attachment 1, Rev. 1 (Non-Proprietary Version) o "LaSalle County Generating Station Unit 2 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18," LAS-FLU-001-R-002, Rev. 1 (Non-Proprietary) o "LaSalle County Generating Station Unit 2 Fluence Methodology Report," LAS-FLU-001-R-008 Attachment 1, Rev. 1 (Non-Proprietary Version) o "LaSalle County Generating Station Unit 1 Fluence Methodology Report -

Licensing Report Attachment 1," LAS-FLU-001-R-009 Attachment 1, Rev. 1 (Proprietary Version) o "LaSalle County Generating Station Unit 2 Fluence Methodology Report -

Licensing Report Attachment 1," LAS-FLU-001-R-007 Attachment 1, Rev. 1 (Proprietary Version)

Attachments 1 through 6 to this letter contain information necessary to supplement Reference 1 :

  • : LaSalle County Generating Station Units 1 and 2 Pressure and Temperature Limits Report (PTLR) for 54 Effective Full-Power Years (EFPY), Rev. 3 (Non-Proprietary) o "LaSalle County Generating Station Unit 1 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18," LAS-FLU-001-R-005, Rev. 1 (Non-Proprietary) o "LaSalle County Generating Station Unit 1 Fluence Methodology Report," LAS-FLU-001-R-010 Attachment 1, Rev. 1 (Non-Proprietary Version)

Attachments 5, 6, and 9 contain Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 5 and 6 and 9 this document may be decontrolled.

June 30, 2023 U.S. Nuclear Regulatory Commission Page 3 o

"LaSalle County Generating Station Unit 2 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18," LAS-FLU-001-R-002, Rev. 1 (Non-Proprietary) o "LaSalle County Generating Station Unit 2 Fluence Methodology Report," LAS-FLU-001-R-008 Attachment 1, Rev. 1 (Non-Proprietary Version)

  • : "LaSalle County Generating Station Unit 1 Fluence Methodology Report -

Licensing Report Attachment 1," LAS-FLU-001-R-009 Attachment 1, Rev. 1 (Proprietary Version)

  • : "LaSalle County Generating Station Unit 2 Fluence Methodology Report -

Licensing Report Attachment 1," LAS-FLU-001-R-007 Attachment 1, Rev. 1 (Proprietary Version)

Attachments 5 and 6 contain information proprietary to TransWare. CEG requests that these documents be withheld from public disclosure in accordance with 10 CFR 2.390(b)(4). An affidavit supporting this request is contained in Attachment 1. Attachments 3 and 4 contain nonproprietary versions of this information. contains the Response to Request for Additional Information in Reference 3. contains information proprietary to GE-Hitachi Nuclear Energy Americas LLC (GEH). CEG requests that this document be withheld from public disclosure in accordance with 10 CFR 2.390(b)(4). An affidavit supporting this request is contained in Attachment 8. There are no attachments containing nonproprietary versions of this information because the entire document is considered proprietary.

The information contained in this supplement and response to request for additional information does not alter the conclusion in Reference 1 regarding the no significant hazards consideration or the environmental considerations.

CEG is notifying the State of Illinois by transmitting a copy of this letter (without attachments) to the designated State Officials in accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b).

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Jason C. Taken at (630) 657-3660.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of June 2023.

Attachments 5, 6, and 9 contain Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 5 and 6 and 9 this document may be decontrolled.

June 30, 2023 U.S. Nuclear Regulatory Commission Page4 Respectfully, Kevin Lueshen Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

cc:

  • : LaSalle County Generating Station Units 1 and 2 Pressure and Temperature Limits Report (PTLR) for 54 Effective Full-Power Years (EFPY), Rev. 3 (Non-Proprietary) o "LaSalle County Generating Station Unit 1 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18," LAS-FLU-001-R-005, Rev. 1 (Non-Proprietary) o "LaSalle County Generating Station Unit 1 Fluence Methodology Report," LAS-FLU-001-R-010 Attachment 1, Rev. 1 (Non-Proprietary Version) o "LaSalle County Generating Station Unit 2 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18," LAS-FLU-001-R-002, Rev. 1 (Non-Proprietary) o "LaSalle County Generating Station Unit 2 Fluence Methodology Report," LAS-FLU-001-R-008 Attachment 1, Rev. 1 (Non-Proprietary Version)
  • : "LaSalle County Generating Station Unit 1 Fluence Methodology Report -

Licensing Report Attachment 1," LAS-FLU-001-R-009 Attachment 1, Rev. 1 (Proprietary Version)

  • : "LaSalle County Generating Station Unit 2 Fluence Methodology Report -

Licensing Report Attachment 1," LAS-FLU-001-R-007 Attachment 1, Rev. 1 (Proprietary Version)

  • : Response to Request for Additional Information
  • : Feedwater Nozzle Safe End Dimensions Used in Stress Reports 22A5552 and 22A5537 (Proprietary Version)

U.S. NRC Region Ill, Regional Administrator (without attachments)

U.S. NRC Senior Resident Inspector, LaSalle County Station (without attachments)

Illinois Emergency Management Agency - Division of Nuclear Safety (without attachments)

Attachments 5, 6, and 9 contain Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 5 and 6 and 9 this document may be decontrolled.

Lueshen, Kevin Digitally signed by Lueshen, Kevin Date: 2023.06.30 12:20:38 -05'00'

ATTACHMENT 1 TransWare Enterprises Inc. Affidavits

ATTACHMENT 2 LaSalle County Generating Station Units 1 and 2 Pressure and Temperature Limits Report (PTLR) for 54 Effective Full-Power Years (EFPY), Rev. 3 (Non-Proprietary)

ATTACHMENT 3 "LaSalle County Generating Station Unit 1 Reactor Pressure Vessel Fluence Evaluation -

End of Cycle 18," LAS-FLU-001-R-005, Rev. 1 (Non-Proprietary}

"LaSalle County Generating Station Unit 1 Fluence Methodology Report Attachment 1,"

LAS-FLU-001-R-010 Attachment 1, Rev. 1 (Non-Proprietary Version}

ATTACHMENT 4 "LaSalle County Generating Station Unit 2 Reactor Pressure Vessel Fluence Evaluation -

End of Cycle 18," LAS-FLU-001-R-002, Rev. 1 (Non-Proprietary)

"LaSalle County Generating Station Unit 2 Fluence Methodology Report Attachment 1,"

LAS-FLU-001-R-008 Attachment 1, Rev. 1 (Non-Proprietary Version)

ATTACHMENT 5 "LaSalle County Generating Station Unit 1 Fluence Methodology Report - Licensing Report Attachment 1," LAS-FLU-001-R-009 Attachment 1, Rev. 1 (Proprietary Version)

ATTACHMENT 6 "LaSalle County Generating Station Unit 2 Fluence Methodology Report - Licensing Report Attachment 1," LAS-FLU-001-R-007 Attachment 1, Rev. 1 (Proprietary Version)

ATTACHMENT 7 Response to Request for Additional Information RAI No. LSCS-PTLR-LAR-1 Scope of RAJ: Design Dimensions for Calculation of P-T Limits Background and Basis for Request:

The PTLR uses the following equations in BWROG Report No. BWROG-TP-11-022-A, Rev. 1, to derive the P-T point sets for assessed RPV components that were evaluated for the P-T limit curves provided in the LAR:

  • Equation 2.5.2-2 for Panow values of the limiting RPV beltline shell component
  • Equation 2.5.3-2 for Panow values of the RPV bottom head
  • Either equations 2.5.3-3a or 2.5.3-3b for applied Kit thermal stress intensity values, equations 2.5.3-5a, 2.5.3-5b, or 2.5.3-5c for Kip-applied pressure stress intensity values and Equation 2.5.3-6 for Panow values of the non-beltline RPV N2 feedwater nozzle or for N6 low pressure coolant injections nozzle in the RPV beltline region The Panow equations or K-type stress intensity equations use component-specific dimensional data as inputs, including component wall thickness ("t") and inside radius ("Ri") dimensions for Panow calculations of limiting beltline shell and the bottom head dome, and some nozzle-specific dimensions if either finite element modeling solutions or Welding Research Council WRC-175 methods are used for Panow or K-type stress intensity solutions for the nozzle types. During the audit, the staff was able to confirm that SIA Calculation No. 2001063.301, 2001063.302 and 2001063.305, Rev. 2 provided the applicable component-specific information, with the exception of the dimensional design data specifically needed for calculations of the N6 feedwater (FW) nozzles in the LSCS units.

Request: Provide all dimensional design data needed for the P-T limit calculations of the LSCS Unit 1 and 2 RPV FW nozzles, including inside and outside radius values for the region of the RPV shell adjoined to the FW nozzles, and any additional nozzle-specific dimensions needed for the calculations (e.g., necessary nozzle corner radius values or wall thickness values).

CEG RESPONSE:

The feedwater nozzles were evaluated by finite element analysis (FEA) per site-specific geometry for Unit 1 and Unit 2. Nozzle unirradiated initial RT NDT values were compared to applied Stress Intensity Factor values that were evaluated at the Extraction Path at the 1/4 T thickness for nozzle geometry.

The nozzle-specific dimensions for the FEA are provided in nozzle drawings and are included in.

ATTACHMENT 7 Response to Request for Additional Information Nozzle Forging-to-Base-metal Weld Extraction Path Figure 1: Example of Nozzle Extraction Path (Example N2 Nozzle, Not Feedwater) [Error!

Reference source not found] [Error! Reference source not found]

Reference:

1. TransWare Topical Report, LAS-FLU-001-R-005, Revision 1, "LaSalle County Generating Station Unit 1 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18", February 2023.
2. TransWare Topical Report, LAS-FLU-001-R-002, Revision 1, "LaSalle County Generating Station Unit 2 Reactor Pressure Vessel Fluence Evaluation - End of Cycle 18", February 2023.
3. General Electric Specification, 22A5552, Revision 1. Contains General Electric Proprietary Information.
4. General Electric Specification, 22A5537, Revision 2. Contains General Electric Proprietary Information.

RAI No. LSCS-PTLR-LAR-2 Scope of RA/: Omitted One-Quarter Thickness (1/4t) Adjusted Reference Temperature (ART)

Value for LSCS, Unit 1, Middle Shell Axial Weld #3-308, BG.

Background and Basis for Request:

During the audit, the licensee confirmed that Table 7 in the PTLR was missing a 1/4t ART line item calculation and value for LSCS, Unit 1, middle shell axial weld 3-308, BG at 54 effective full power years (54 EPFY).

ATTACHMENT 7 Response to Request for Additional Information Request: Provide the 54 EPFY 1/4t ART calculation and all related input values for middle shell axial weld 3-308, BG.

CEG RESPONSE:

The response to RAI No. LSCS-PTLR-LAR-2 can be found in Attachment 2 Table 7 (Page 46 of 51, under "Unit 1 Middle Shell Axial Welds:").

RAI No. LSCS-PTLR-LAR-3 Scope of RAJ: Potential Inconsistency Between P-T Limit Curves Figures (Figures 1 - 6) in the PTLR and Corresponding P-T Limit Curve Figures in SIA Calculation 2001063.305, Revision 2.

Background and Basis for Request:

The LAR indicates that the P-T limit curves provided in Figures 1 - 6 were calculated in accordance with the approved guidance and methodology in BWROG Report No. BWROG-TP-11-022-A, Rev. 1. The LAR states that the P-T limit curves are documented in in SIA Calculation No. 2001063.305, Rev. 1. During the audit the staff was provided with SIA Calculation 2001063.305, Rev. 2 as the source of the P-T curves. However, the staff noted that the P-T curves in this calculation were not consistent with those in the LAR.

Request:

(1) Clarify which version of SIA Calculation No. 2001063.305 documents the basis for the P-T limit curves intended for use in the PTLR.

(2) Describe and justify the differences between the LAR and SIA Calculation No.

2001063.305, revisions 1 and 2. Do these changes affect consistency with the methodology of BWROG Report No. BWROG-TP-11-022-A, Rev. 1?

(3) Revise, as necessary, the LAR to ensure that the basis for the P-T limits in the LAR is consistent with the identified reference documents.

CEG RESPONSE:

Basis calculation information and the associated PTLR information have been reconciled, as shown within Attachment 2 in Table 1 through Table 6 (and associated Figure 1 through Figure 6). The most recent version of the basis calculation is 2001063.305 Revision 2. These calculations abide by the methodology document BWROG-TP-11-022-A Revision 1.

Specifically, the PTLR follows the Curve A (pressure and hydrostatic leak test), Curve B (core not critical), and Curve C (core critical) approaches, as defined by the methodology document, 10 CFR 50 Appendix G, and Regulatory Guide 1.99 Revision 2. The nozzle evaluations were analyzed according to the methodology document and all components with fluence greater than 1.0 x 1017 n/cm2 (E > 1 MeV) have been assessed within the calculation.

The composite curves have been generated from limiting component curves in the upper vessel (including feedwater nozzle), beltline (including beltline nozzles), and bottom head, with vessel

ATTACHMENT 7 Response to Request for Additional Information material information component-specific geometries. Input fluence information was generated per fluence analyses abiding by Regulatory Guide 1.190.

ATTACHMENT 8 GE-Hitachi Nuclear Energy Americas, LLC Affidavit

ATTACHMENT 9 Feedwater Nozzle Safe End Dimensions Used in Stress Reports 22A5552 and 22A5537 (Proprietary Version)

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