JAFP-18-0014, Response to Request for Additional Information on Submittal of Relief Request JAF-15R-05 Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702)

Response to Request for Additional Information on Submittal of Relief Request [[::JAF-15R-05|JAF-15R-05]] Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702)

ML18064A278
Person / Time
Site:	FitzPatrick
Issue date:	03/02/2018
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-18-0014
Download: ML18064A278 (5)

Text

Exelon Generation@ 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.55a March 2, 2018 JAFP-18-0014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Submittal of Relief Request [[::JAF-15R-05|JAF-15R-05]] Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702)

References:

1) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Submittal of Relief Request [[::JAF-15R-05|JAF-15R-05]] Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702)," dated September 29, 2017

2) Email from B. Venkataraman (U.S. Nuclear Regulatory Commission) to T. Loomis and C. Williams (Exelon Generation Company, LLC),

"FitzPatrick - Request for Additional Information Re: Relief Request:

[[::JAF-15R-05A|JAF-15R-05A]], [[::JAF-15R-05|JAF-15R-05]] Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702) (EPID: L-2017-LLR-0093),"

dated February 2, 2018 In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) requested relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)

Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components."

Relief Request [[::JAF-15R-05|JAF-15R-05]] proposed an alternative to the requirements contained in Table IWB-2500-1 concerning nozzle-to-vessel weld and nozzle inner radii examination requirements.

In the Reference 2 email, the U.S. Nuclear Regulatory Commission requested additional information. Attached is our response.

Relief Request [[::JAF-15R-05|JAF-15R-05]] Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702)

March 2, 2018 Page 2 No regulatory commitments are contained in this letter. Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

Sincerely, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information cc: Regional Administrator, NRC Region I USNRC Senior Resident Inspector, NRR USNRC Project Manager, NRA

Attachment Response to Request for Additional Information

5215 Hellyer Ave.

Suite 210 San Jose, CA 95138-1025 Phone: 408-978-8200 Fax: 408-978-8964 www.structint.com wwong@structint.com March 1, 2018 Report No. 1800152.401.R0 Quality Program: Nuclear Commercial

Subject:

Normal Operating Probability of Failure for Code Case N-702 Using VIPERNOZ SI Calculation No. 1700858.301 Revision 1 determined that probability of failure (PoF) per reactor year due to a Low Temperature Over Pressure (LTOP) event for the RPV nozzle-to-shell-weld and RPV nozzle blend radii in the FitzPatrick reactor recirculation inlet (N2) nozzles are below the acceptance criterion of 5x10-6 per year. The work was performed using the same methodology as in BWRVIP-108, which is the technical basis for ASME Code Case N-702 and similar to the work in BWRVIP-05.

In the NRC staffs request for additional information (RAI), sent February 2, 2018 (ADAMS Accession No. ML18033A139), the following information was requested for the staff to complete their review for Exelons Relief Request JAF-I5R-05:

• The NRC staff requests the licensee to report the PoF values for LTOP and normal operation or discuss how the PoF values for LTOP are more limiting than those for normal operation.

In response to the RAI, the PoF due to LTOP and normal operation from 1700858.301 Revision 1 are provided herein for both the RPV nozzle-to-shell-weld and RPV nozzle blend radii in the FitzPatrick N2 nozzles. The maximum PoF per year due to an LTOP event is 3.0x10-9, and the maximum PoF per year due to normal operation is <8.0x10-9. The LTOP PoF includes the LTOP event occurrence of 1 x 10-3. These PoFs are more than three orders of magnitude below the acceptance criterion of 5x10-6 per year.

March 1, 2018 Report No. 1800152.401.R0 Page 2 of 2 Prepared by: Verified by:

3/1/18 3/1/18 Wilson Wong Date S. S. Tang Date Senior Engineer Associate Reviewed by:

3/1/18 Terry J. Herrmann, P.E. Date Senior Associate Approved by:

3/1/18 Wilson Wong Date Senior Engineer