JAFP-21-0032, Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting
| ML21110A092 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 04/20/2021 |
| From: | David Gudger Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| JAFP-21-0032, NMP1L3394, RS-21-053 | |
| Download: ML21110A092 (10) | |
Text
10 CFR 50.55a RS-21-053 JAFP-21-0032 NMP1L3394 April 20, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Response to Request for Additional Information Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation April 20, 2021 Page 2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 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 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244
Subject:
Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting
References:
- 1) Letter from D. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting, dated December 1, 2020 (ML20336A008)
- 2) Email from B. Purnell (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), Exelon Generation Company, LLC -
Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting, dated March 1, 2021 (ML21062A065)
In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) requested a proposed alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," on the basis that the alternative provides an acceptable level of quality and safety. This proposed alternative concerns completion of a Repair/Replacement Plan and Form NIS-2, Owners Report for Repair/Replacement Activity or the NRC approved alternative Form NIS-2A, Repair/Replacement Certification Record, contained in Code Case N-532-5. Specifically, Exelon proposes to forego preparation and completion of a Repair/Replacement Plan and Form NIS-2 (or NIS-2A) for pressure retaining bolting that is not classified as Examination Category B-G-1, B-G-2, or C-D.
In the Reference 2 email, the U.S. Nuclear Regulatory Commission Staff requested additional information. Attached is our response.
There are no regulatory commitments contained in this letter.
Response to Request for Additional Information Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation April 20, 2021 Page 3 If you have any questions, please contact Tom Loomis at (610) 765-5510.
Respectfully, David T. Gudger Senior Manager - Licensing Exelon Generation Company, LLC
Attachment:
Response to Request for Additional Information
Response to Request for Additional Information Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation April 20, 2021 Page 4 cc:
Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - James A. FitzPatrick Nuclear Power Plant NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - Quad Cities Nuclear Power Station NRC Project Manager - R.E. Ginna Nuclear Power Plant Maryland DNR - S. Seaman Pennsylvania DEP - W. DeHaas NYSERDA - A. L. Peterson Illinois Emergency Management Agency - Division of Nuclear Safety
Attachment Response to Request for Additional Information
Response to Request for Additional Information Page 1 of 5 Request for Additional Information (RAI) 1:
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Background===
Section 3 of the application identifies the applicable requirements of the ASME BPV Code,Section XI, including the following:
Paragraph IWA-4141 requires the Owner to provide or cause to be provided a Repair Replacement Program, a Repair Replacement Plan, and specification requirements for repair/replacement activities.
Paragraph IWA-4142 states, in part, that the organization that performs repair/replacement activities shall establish a Quality Assurance Program for control of their activities in accordance with the Repair/Replacement Program and Plans.
Section 5 of the application states, in part:
Quality Assurance Program and system/component specification requirements remain in place during application of this relief request; therefore, these technical requirements remain unchanged. The specific requirements will not be documented in a Repair/Replacement Plan but are currently implemented through the normal planning, procurement, and maintenance processes.
Documentation of the work activity and replacement bolting is achieved through the normal processes of procurement, planning, and maintenance.
Replacement bolting will receive Construction Code and Owners Requirements NDE [nondestructive examination] as part of the normal procurement and receipt inspection processes which identify applicable Construction Code and Owners Requirements. The Construction Code and Owners Requirements for NDE will be documented in the procurement and receipt records.
Request Describe the normal planning, procurement, maintenance, and receipt inspection processes for pressure retaining bolting not included within Examination Categories B-G, B-G-2, or C-D.
Explain how these processes will ensure that the replacement of such bolting will be performed in accordance with the requirements in the ASME BPV Code,Section XI, and that this activity will be adequately documented. Explain how the Quality Assurance Program and system/component specification requirements remain in place and applicable for such bolting in the absence of repair/replacement plans.
Response
The Exelon Quality Assurance Program specifies all requirements whether or not Section XI applies. Work orders are prepared in advance of scheduled maintenance activities. Work Planners reserve bolting materials in accordance with the plant piping specifications, component specifications, or applicable drawings. Bolting materials are classified in
Response to Request for Additional Information Page 2 of 5 accordance with site requirements and procured in accordance with those requirements, which are governed by ASME, ASTM, or material specifications based on site requirements. In accordance with Exelons Quality Assurance Topical Report, safety-related bolting materials receive a quality receipt inspection by a qualified individual, which includes physical inspections and documentation review. When bolting materials are installed, material traceability information, such as a unique material identifier or purchase order number, is documented in the work order and available for review as part of the completed work order package.
This relief request proposes to forego preparation and completion of a Repair/Replacement Plan Form and the associated Forms NIS-2 (or NIS-2A) for replacement of pressure retaining bolting that is not classified as Examination Category B-G-1, B-G-2, or C-D. This relief request will not be applied to activities that involve replacement of bolting that has experienced unacceptable service-induced degradation or that is being driven by a design change. The plant Quality Assurance Program and the plant system and component Specification requirements will remain in place and implemented for bolting replacements that occur under the alternatives of this relief request just as they are today.
No technical or process changes are being requested under this relief request. The proposed alternative is simply to remove the administrative Forms required by current Code for the Repair/Replacement Plan Form and the associated Forms NIS-2 (or NIS-2A). The plant work management systems, procurement specifications, installation procedures, and work order documentation will remain in place and be implemented to assure the work activity and material are adequately controlled and documented for these routine replacements of the subset of bolting described above.
RAI 2
Background
Section 5 of the application states, in part:
The current Form NIS-2 (or NIS-2A) provides documented evidence of compliance with Section XI for repair/replacement activities by obtaining Owner and Authorized Inspection Agency signatures. The proposed alternative would use current work control, procurement, and records retention processes to assure that the Authorized Inspection Agency has access to records of bolting replacement in order to maintain Code oversight; however, there will be no Repair/Replacement Plan or Form NIS-2 (or NIS-2A) presented to the agency in order to complete the Form approval. Owner and Authorized Inspection Agency reviews of completed work orders applying this relief request will be documented in records associated with the work management process (e.g., hard copy signature in work order documentation and electronic work order review records (commonly referred to as Post Work Review)).
Request Describe how Exelons work control, procurement, and records retention processes will demonstrate that repair/replacement activities were adequately performed and the associated requirements of the ASME BPV Code,Section XI, were met. Describe how these processes will permit verification and certification by the Authorized Inspection Agency that the applicable Section XI requirements for repair/replacement activities have been met. Confirm that the licensees processes discussed above will be readily available for review by NRC inspectors.
Response to Request for Additional Information Page 3 of 5
Response
Exelon understands that the wording presented in the second to last paragraph of Section 5 of the relief request may have confused the proposed alternative discussed throughout the request. Exelon will clarify this paragraph with the following revision and additional explanation to the wording contained in that paragraph:
The current Form NIS-2 (or NIS-2A) provides documented evidence of compliance with Section XI for repair/replacement activities by obtaining Owner and Authorized Inspection Agency signatures. This relief request proposes to forego preparation and completion of the Repair/Replacement Plan and associated Form NIS-2 (or NIS-2A) for replacement of pressure retaining bolting that is not classified as Examination Category B-G-1, B-G-2, or C-D. The proposed alternative will use existing work control, procurement, and records retention processes to assure adequate controls of these routine bolting replacements. The Authorized Inspection Agency will have access to these site work control systems for review at their discretion. Should the Authorized Inspection Agency choose to review certain completed work orders that fall under this relief request, the work management system will be used to document any agency comments during the work order records review, commonly referred to as the post-work review process.
Documentation of the work activity and replacement bolting will be maintained through the normal plant processes of procurement, planning, and maintenance. Close-out reviews will continue to be completed through the normal post-work review process to assure appropriate documentation of work performed and material traceability is achieved. These processes and work control systems including the associated work orders and procurement documentation will be available at each site for review by NRC Inspectors.
RAI 3
Background
The regulations in 10 CFR 50.55a(z) allow the NRC staff to authorize alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a, but do not allow the staff to approve alternatives to requirements not currently in these paragraphs. The staff does not generally approve alternatives to the requirements in 10 CFR 50.55a beyond the current 10-year inservice inspection (ISI) interval, unless specific circumstances would justify a longer interval. For example, the staff can approve alternatives for the next ISI interval when it is near the end of the current interval and the applicable requirements for the next interval are known (see 10 CFR 50.55a(g)(4)(ii)).
The licensee requested use of the proposed alternative for the remainder of each plants 10-year ISI interval and for the remainder of each plants life. Section 2 of the application identifies the ASME BPV Code edition and addenda applicable to the current 10-year ISI interval for each plant, and Section 3 of the application identifies the specific Code requirements associated with this request. However, the application does not identify the ASME BPV Code edition and addenda nor the specific code requirements applicable to future 10-year ISI intervals. Thus, the licensee has not demonstrated that the proposed alternative is limited to the current requirements in paragraphs (b) through (h) of 10 CFR 50.55a.
Response to Request for Additional Information Page 4 of 5 Request For each plant, either:
(1) Limit the scope of the request to the current 10-year ISI interval; or (2) Identify the specific ASME BPV Code edition and addenda applicable to each future 10-year ISI interval in which the proposed alternative will be used. Identify the applicable code requirements in each future edition and addenda of the ASME BPV Code, unless they are already listed in Section 3 of the application.
Response
The requested duration of the proposed alternative for each Exelon plant is for their current 10-year ISI Interval. Section 2 of the Relief Request has been revised for the Dresden Nuclear Power Station, Units 2 and 3, and the Quad Cities Nuclear Power Station, Units 1 and 2 which are currently being updated using the 2017 Edition of ASME Section XI as endorsed in the latest revision of 10 CFR 50.55a that will be in effect eighteen months prior to the new interval start dates for those plants. The Revised Section 2 table below reflects these revised dates, as noted by the revision bars.
Response to Request for Additional Information Page 5 of 5 PLANT INTERVAL EDITION START END Braidwood Station, Units 1 and 2 Fourth 2013 Edition August 29, 2018 November 5, 2018 July 28, 2028 October 16, 2028 Byron Station, Units 1 and 2 Fourth 2007 Edition, through 2008 Addenda July 16, 2016 July 15, 2025 Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Fifth 2013 Edition July 1, 2019 June 30, 2029 Clinton Power Station, Unit 1 Fourth 2013 Edition July 1, 2020 June 30, 2030 Dresden Nuclear Power Station, Units 2 and 3 Fifth 2007 Edition, through 2008 Addenda January 20, 2013 January 19, 2023 Dresden Nuclear Power Station, Units 2 and 3 Sixth 2017 Edition January 20, 2023 January 19, 2033 James A. FitzPatrick Nuclear Power Plant Fifth 2007 Edition, through 2008 Addenda August 1, 2017 June 15, 2027 LaSalle County Stations, Units 1 and 2 Fourth 2007 Edition, through 2008 Addenda October 1, 2017 September 30, 2027 Limerick Generating Station, Units 1 and 2 Fourth 2007 Edition, through 2008 Addenda February 1, 2017 January 31, 2027 Nine Mile Point Nuclear Station, Unit 1 Fifth 2013 Edition August 23, 2019 August 22, 2029 Nine Mile Point Nuclear Station, Unit 2 Fourth 2013 Edition August 23, 2018 August 22, 2028 Peach Bottom Atomic Power Station, Units 2 and 3 Fifth 2013 Edition January 1, 2019 December 31, 2028 Quad Cities Nuclear Power Station, Units 1 and 2 Fifth 2007 Edition, through 2008 Addenda April 2, 2013 April 1, 2023 Quad Cities Nuclear Power Station, Units 1 and 2 Sixth 2017 Edition April 2, 2023 April 1, 2033 R. E. Ginna Nuclear Power Plant Sixth 2013 Edition January 1, 2020 December 31, 2029