BYRON 2005-0054, Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors.

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Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors.
ML051400295
Person / Time
Site: Byron Constellation icon.png
Issue date: 05/20/2005
From: Kuczynski S
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
1.10.0101, BL-04-001, BYRON 2005-0054
Download: ML051400295 (5)


Text

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corpkoin ExelF\i i.icl eflarM hyn I 44 C N~IC ~e ~n F B By B 1) C J/~4 May 20, 2005 LTR: BYRON 2005-0054 File: 1.10.0101 United States Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Byron Station Unit 1 Facility Operating License No. NPF-37 NRC Docket No. STN 50-454

Subject:

Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors

Reference:

(1) Letter from Keith R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U. S. NRC, Initial response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors, dated July 27, 2004 On May 28, 2004, the NRC issued NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. This bulletin requires the following information be submitted to the NRC within 60 days of plant restart following the next inspection of the Alloy 82/1 82/600 pressurizer penetration and steam space piping connections:

a statement indicating that the inspections described in the licensees response to item (1)(c) of this bulletin were completed and a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, followup NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings or boric acid, and any corrective actions taken and/or repairs made as a result of the indications found.

May 20, 2005 U.S. Nuclear Regulatory Commission Page 2 Pursuant to 10 CFR 50.54, Conditions of licenses, paragraph (f), the Attachment to this letter provides the Byron Station, Unit 1 60-day response. This response is due to the NRC by May 24, 2005.

Should you have any questions or desire additional information regarding this letter, please contact William Grundmann, Regulatory Assurance Manager, at (815) 406-2800.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on __________________ _________________________

Stephen E. Kuczynski Site Vice President Byron Nuclear Generating Station

Attachment:

Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01

ATTACHMENT Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01 Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors

Attachment Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01 On May 28, 2004, the NRC issued NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. This bulletin requires the following information be submitted to the NRC within 60 days of plant restart following the next inspection of the Alloy 82/182/600 pressurizer penetration and steam space piping connections:

(2) Within 60 days of plant restart following the next inspection of the Alloy 82/182/600 pressurizer penetrations and steam space piping connections, the subject PWR licensees should either:

(a) submit to the NRC a statement indicating that the inspections described in the licensees response to item (1)(c) of this bulletin were completed and a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, followup NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found, or (b) if the licensee was unable to complete the inspections described in response to item (1)(c) of this bulletin, submit to the NRC a summary of the inspections performed, the extent of the inspections, the methods used, a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, followup NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found. In addition, supplement the answer which you provided to item (1)(d) above to explain why the inspections that you completed were adequate for the purpose of maintaining the integrity of your facilitys RCPB and for meeting all applicable regulatory requirements which pertain to your facility.

Response

Statement indicating inspections described in licensees response to item (1)(c) were completed and description of the as-found condition of the pressurizer shell Page 1 of 2

Attachment The Byron Station response to item (1)(c) of this bulletin, documented in Reference 1, is summarized as follows:

Byron Station will perform a 100% BMV examination of all affected pressurizer penetrations and piping connections during the next refueling outage. The visual examinations will continue to be performed by certified Level Il/Ill visual examiners qualified in the detection and assessment of boric acid leakage. The examinations will be documented in accordance with procedures ER-AA-335-015 and ER-AP-331-1002 with written reports.

Examinations as described above (100% bare metal visual examination of all affected Byron Station, Unit 1 Alloy 82/182/600 pressurizer penetrations and piping connections) were performed during Byron Station, Unit 1 refueling outage 13 (i.e., Bi Ri 3) in March 2005. The examinations of all five pressurizer steam space penetrations and adjacent pressurizer shell surfaces were performed with the system depressurized and at ambient temperature. The examinations were documented in accordance with Exelon corporate procedures ER-AA-335-0i5, VT-2 Visual Examination, ER-AP-33 1-1001, Boric Acid Corrosion Control (BACC) Inspection Locations, Implementation and Inspection Guidelines, and ER-AP-331-1002, Boric Acid Corrosion Control Program Identification, Screening, and Evaluation.

The examinations, performed by VT-2 qualified personnel, were performed after insulation was removed from the top of the pressurizer and the five associated penetrations. The penetration examinations were a direct visual examination of the full circumference of each penetration, thereby ensuring any boric acid leakage would be easily identified. No evidence of boric acid deposits associated with reactor coolant system leakage was identified during the examination of the five penetrations and adjacent pressurizer shell surfaces.

Findings of Relevant Indications, Followup NDE, Summary of Relevant NDE Indications, and Summary of Disposition of any Findings No followup NDE or disposition of NDE indications or findings was required based on the results of the examinations of the five penetrations and adjacent pressurizer shell surfaces.

Corrective Actions Taken There were no corrective actions taken since no evidence of boric acid leakage was identified and no followup NDE or disposition of findings was required.

Page 2 of 2

Text

C nip ~ny, C wvvw c xe~ci~

corpkoin ExelF\i i.icl eflarM hyn I 44 C N~IC ~e ~n F B By B 1) C J/~4 May 20, 2005 LTR: BYRON 2005-0054 File: 1.10.0101 United States Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Byron Station Unit 1 Facility Operating License No. NPF-37 NRC Docket No. STN 50-454

Subject:

Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors

Reference:

(1) Letter from Keith R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to U. S. NRC, Initial response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors, dated July 27, 2004 On May 28, 2004, the NRC issued NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. This bulletin requires the following information be submitted to the NRC within 60 days of plant restart following the next inspection of the Alloy 82/1 82/600 pressurizer penetration and steam space piping connections:

a statement indicating that the inspections described in the licensees response to item (1)(c) of this bulletin were completed and a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, followup NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings or boric acid, and any corrective actions taken and/or repairs made as a result of the indications found.

May 20, 2005 U.S. Nuclear Regulatory Commission Page 2 Pursuant to 10 CFR 50.54, Conditions of licenses, paragraph (f), the Attachment to this letter provides the Byron Station, Unit 1 60-day response. This response is due to the NRC by May 24, 2005.

Should you have any questions or desire additional information regarding this letter, please contact William Grundmann, Regulatory Assurance Manager, at (815) 406-2800.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on __________________ _________________________

Stephen E. Kuczynski Site Vice President Byron Nuclear Generating Station

Attachment:

Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01

ATTACHMENT Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01 Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors

Attachment Byron Station Unit 1 60-Day Response to NRC Bulletin 2004-01 On May 28, 2004, the NRC issued NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. This bulletin requires the following information be submitted to the NRC within 60 days of plant restart following the next inspection of the Alloy 82/182/600 pressurizer penetration and steam space piping connections:

(2) Within 60 days of plant restart following the next inspection of the Alloy 82/182/600 pressurizer penetrations and steam space piping connections, the subject PWR licensees should either:

(a) submit to the NRC a statement indicating that the inspections described in the licensees response to item (1)(c) of this bulletin were completed and a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, followup NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found, or (b) if the licensee was unable to complete the inspections described in response to item (1)(c) of this bulletin, submit to the NRC a summary of the inspections performed, the extent of the inspections, the methods used, a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, followup NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found. In addition, supplement the answer which you provided to item (1)(d) above to explain why the inspections that you completed were adequate for the purpose of maintaining the integrity of your facilitys RCPB and for meeting all applicable regulatory requirements which pertain to your facility.

Response

Statement indicating inspections described in licensees response to item (1)(c) were completed and description of the as-found condition of the pressurizer shell Page 1 of 2

Attachment The Byron Station response to item (1)(c) of this bulletin, documented in Reference 1, is summarized as follows:

Byron Station will perform a 100% BMV examination of all affected pressurizer penetrations and piping connections during the next refueling outage. The visual examinations will continue to be performed by certified Level Il/Ill visual examiners qualified in the detection and assessment of boric acid leakage. The examinations will be documented in accordance with procedures ER-AA-335-015 and ER-AP-331-1002 with written reports.

Examinations as described above (100% bare metal visual examination of all affected Byron Station, Unit 1 Alloy 82/182/600 pressurizer penetrations and piping connections) were performed during Byron Station, Unit 1 refueling outage 13 (i.e., Bi Ri 3) in March 2005. The examinations of all five pressurizer steam space penetrations and adjacent pressurizer shell surfaces were performed with the system depressurized and at ambient temperature. The examinations were documented in accordance with Exelon corporate procedures ER-AA-335-0i5, VT-2 Visual Examination, ER-AP-33 1-1001, Boric Acid Corrosion Control (BACC) Inspection Locations, Implementation and Inspection Guidelines, and ER-AP-331-1002, Boric Acid Corrosion Control Program Identification, Screening, and Evaluation.

The examinations, performed by VT-2 qualified personnel, were performed after insulation was removed from the top of the pressurizer and the five associated penetrations. The penetration examinations were a direct visual examination of the full circumference of each penetration, thereby ensuring any boric acid leakage would be easily identified. No evidence of boric acid deposits associated with reactor coolant system leakage was identified during the examination of the five penetrations and adjacent pressurizer shell surfaces.

Findings of Relevant Indications, Followup NDE, Summary of Relevant NDE Indications, and Summary of Disposition of any Findings No followup NDE or disposition of NDE indications or findings was required based on the results of the examinations of the five penetrations and adjacent pressurizer shell surfaces.

Corrective Actions Taken There were no corrective actions taken since no evidence of boric acid leakage was identified and no followup NDE or disposition of findings was required.

Page 2 of 2