ML072290419
| ML072290419 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Limerick, Clinton, Quad Cities, LaSalle |
| Issue date: | 09/05/2007 |
| From: | Gratton C NRC/NRR/ADRO/DORL/LPLIII-2 |
| To: | Crane C AmerGen Energy Co, Exelon Generation Co |
| Gratton C, NRR, DORL, 415-1055 | |
| References | |
| TAC MD5352, TAC MD5353, TAC MD5354, TAC MD5355, TAC MD5356, TAC MD5357, TAC MD5358, TAC MD5359, TAC MD5360, TAC MD5361, TAC MD5362, TAC MD5363 | |
| Download: ML072290419 (12) | |
Text
September 5, 2007 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Generation Company, LLC AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: RELIEF REQUEST TO USE OF THE BOILING WATER REACTOR VESSEL AND INTERNALS PROJECT GUIDELINES (TAC NOS. MD5352 THRU MD5363)
Dear Mr. Crane:
By letter to the Nuclear Regulatory Commission (NRC) dated April 19, 2007, Exelon Generation Company, LLC and AmerGen Energy Company, LLC submitted a request to use the Boiling Water Reactor Vessel and Internals Project (BWRVIP) guidelines in lieu of specific American Society of Mechanical Engineer Boiler and Pressure Vessel Code requirements for the subject plants.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The NRC staff sent a draft of the enclosed questions by facsimile to the licensee on August 16, 2007. During a conference call with your staff on August, 24, 2007, to clarify the intent of the questions, the NRC staff agreed that the responses to Question 1 and Question 3 could be combined into a single response, and that a response to Question 2 was not necessary because the information that was requested was already contained in docketed material.
In a followup discussion with your staff on August 27, 2007, it was agreed that the licensees staff would provide a response to the enclosed questions by October 5, 2007.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of
C. Crane efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055.
Sincerely,
/RA/
Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-461; 50-237 and 50-249; 50-373 and 50-374; 50-352 and 50-353; 50-219; 50-277 and 50-278; and 50-254 and 50-265
Enclosure:
Request for Additional Information cc w/encl: See next page
C. Crane efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055.
Sincerely,
/RA/
Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-461; 50-237 and 50-249; 50-373 and 50-374; 50-352 and 50-353; 50-219; 50-277 and 50-278; and 50-254 and 50-265
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrLAEWhitt RidsAcrsAcnwMailCenter RidsNrrPMCGratton RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr RidsNrrPMSSands RidsNrrPMJHughey GCheruvenki, NRR RidsNrrPMEMiller RidsNrrPMPBamford RidsNrrDciCvib RidsNrrPMMThorpe-Kavanaugh ADAMS Accession Number: ML072290419 NRR-088 OFFICE LPL3-2/PM LPL3-2/LA DCI/CVIB/BC LPL3-2/BC NAME CGratton EWhitt MMitchell RGibbs DATE 8/29/07 8/27/07 8/29/07 9/5/07 OFFICIAL RECORD COPY
Clinton Power Station, Unit No. 1 cc:
Senior Vice President - Operations Support via e-mail Illinois Emergency Management Agency Division of Disaster Assistance &
Preparedness 1035 Outer Park Dr.
Springfield, IL 62704 Director - Licensing and Regulatory Affairs via e-mail Manager Licensing - Clinton, Dresden, Quad Cities via e-mail Vice President - Regulatory Affairs via e-mail Manager Regulatory Assurance - Clinton via e-mail Site Vice President - Clinton Power Station via e-mail Plant Manager - Clinton Power Station via e-mail Document Control Desk - Licensing via e-mail Associate General Counsel via e-mail Senior Resident Inspector U.S. Nuclear Regulatory Commission via e-mail Chairman of DeWitt County c/o County Clerks Office DeWitt County Courthouse Clinton, IL 61727 J. W. Blattner Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603
Dresden and Quad Cities Nuclear Power Stations, Units 1 and 2 cc:
Site Vice President - Dresden Nuclear Power Station via e-mail Plant Manager - Dresden Nuclear Power Station via e-mail Manager Regulatory Assurance - Dresden via e-mail Dresden Senior Resident Inspector U.S. Nuclear Regulatory Commission via e-mail Chairman Grundy County Board Administration Building 1320 Union Street Morris, IL 60450 Site Vice President - Quad Cities via e-mail Plant Manager - Quad Cities via e-mail Manager Regulatory Assurance - Quad Cities via e-mail Quad Cities Senior Resident Inspector U.S. Nuclear Regulatory Commission via e-mail David C. Tubbs MidAmerican Energy Company via e-mail Vice President - Law and Regulatory Affairs MidAmerican Energy Company One River Center Place 106 E. Second Street P.O. Box 4350 Davenport, IA 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.
Rock Island, IL 61201 LaSalle County Station, Units 1 and 2 cc:
Site Vice President - LaSalle County Station via e-mail Plant Manager - LaSalle County Station via e-mail Manager Regulatory Assurance - LaSalle via e-mail LaSalle Senior Resident Inspector U.S. Nuclear Regulatory Commission via e-mail Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, IL 60603 Assistant Attorney General 100 W. Randolph St. Suite 12 Chicago, IL 60601 Chairman LaSalle County Board 707 Etna Road Ottawa, IL 61350 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601
Limerick Generating Station, Unit Nos. 1 and 2 cc:
Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Associate General Counsel Exelon Generating Company, LLC 4300 Winfield Road Warrenville, IL 60555
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224 Board of Supervisors Peach Bottom Township 545 Broad Street Ext.
Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236
Oyster Creek Nuclear Generating Station cc:
Site Vice President - Oyster Creek Nuclear Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Kathryn M. Sutton, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Oyster Creek Nuclear Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731
REQUEST FOR ADDITIONAL INFORMATION REGARDING A REQUEST FOR RELIEF FOR CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-461; 50-237 AND 50-249; 50-373 AND 50-374; 50-352 AND 50-353; 50-219; 50-277 AND 50-278; AND 50-254 AND 50-265 By letter dated April 19, 2007, Exelon Generation Company, LLC and AmerGen Energy Company, LLC (the licensee) submitted Relief Request (RR) RS-07-058 for its boiling-water reactor (BWR) fleet. The licensee proposed to use BWRVIP guidelines as an alternative to certain requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for inservice inspection (ISI) of reactor vessel internal (RVI) components. The NRC staff has reviewed the information the licensee provided that supports the proposed RR and has the following questions:
(1) In a letter dated October 1, 2003, Entergy Nuclear Operations Inc. (Entergy), the licensee of the Vermont Yankee Nuclear Power Station (VYNPS), submitted a similar RR in which the licensee proposed to implement the BWRVIP guidelines in lieu of ASME Code Section XI requirements for the VYNPSs RVI components. In a supplemental letter dated January 22, 2004, (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML040690734), Entergy submitted details of the inspections for the RVI components that are consistent with the BWRVIP inspection guidelines. The Nuclear Regulatory Commission (NRC) staff, in its safety evaluation (SE) dated September 19, 2005, approved the VYNPSs RR.
The NRC staff requests that the licensee provide inspection requirements and inspection frequencies for the following units similar to those addressed in VYNPSs (ADAMS Accession No. ML040690734). This information will enable the NRC staff to perform an effective review of the BWRVIP inspection criteria that will be implemented by the licensee.
(1) Clinton Power Station, Unit No. 1 (2) Dresden Nuclear Power Station, Units 2 and 3 (3) LaSalle County Station, Units 1 and 2 (4) Limerick Generating Station, Units 1 and 2 (5) Oyster Creek Nuclear Generating Station (Oyster Creek)
(6) Peach Bottom Atomic Power Station, Units 2 and 3 (7) Quad Cities Nuclear Power Station, Units 1 and 2 (2) Deleted (3) Identify whether the following RVI components in each of the units specified in question (1) have previously experienced cracking due to stress corrosion cracking, intergranular stress corrosion cracking, irradiation-assisted stress corrosion cracking (IASCC) or cyclic loading and identify the extent of cracking. Also provide information regarding the inspection methods and inspection frequencies that were used thus far, and the corrective actions that were taken when degradation was identified in these RVI components.
(1) Core plate hold-down bolts (2) Top guide grid beams and hold-down assemblies (3) Core shroud welds (4) Core shroud support welds (5) Core spray piping (6) Core Spray nozzle and thermal sleeve (7) Core spray spargers (8) Jet pump assembly and Jet pump beams (9) Jet pump diffuser (10) Jet pump riser welds and thermal sleeves (11) Control Rod Drive (CRD) guide tube (12) CRD stub tube (13) In-core housing (14) Dry tube (15) Instrument penetartions (16) Vessel inside diameter brackets (17) Low Pressure Coolant Injection couplings (18) Fuel support castings (19) CRD nozzle (20) Steam dryer (21) Moisture separator (22) Surveillance capsule specimen holder (23) Lower plenum (24) Feedwater sparger (4) The NRC staff requests that the licensee identify whether there are any furnace-sensitized stainless steel vessel attachment welds associated with the RVI components in the plants identified in question (1). It is requested that the licensee provide an explanation regarding the type of inspection program and any additional augmented inspection program that are implemented for any existing furnace-sensitized stainless steel attachment welds in these BWR units.
(5) In a letter dated October 7, 2005, Entergy Nuclear Operations Inc., the licensee of the James A. FitzPatrick Nuclear Power Plant, submitted a similar RR (ADAMS Accession No. ML052900075) which included the following BWRVIP reports. To maintain consistency, the NRC staff requests that the licensee include the following BWRVIP reports in its response, and make a commitment that it will comply with the inspection requirements specified in these reports.
(1) BWRVIP-25, BWR Core Plate Inspection and Flaw Evaluation Guidelines.
(2) BWRVIP-27-A, BWRVIP Standby Liquid Control System/Core Spray/ Core Plate P Inspection and Flaw Evaluation Guidelines.
(3) BWRVIP-138, BWRVIP Updated Jet Pump Beam Inspection and Flaw Evaluation.
(6) The NRC staff requests that the licensee confirm whether NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking, will be used for the inspection of feedwater sparger tee welds and feedwater sparger piping brackets.
(7) In Table 1 of Attachment A of the submittal dated April 19, 2007, the licensee indicates that VT-3 inspection will be performed per the BWRVIP-48 report, BWR Vessel Internal Project, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines, on the lower surveillance specimen holder bracket welds that are within the beltline region. However, Table 3-2 of the BWRVIP-48 report requires VT-1 examination per Table IWB-2500-1, Item Number B13.20 of ASME Section XI. Therefore, the NRC staff requests that the licensee revise Table 1 of Attachment A of the submittal dated April 19, 2007, to substitute VT-1 for VT-3 for the lower surveillance specimen holder bracket welds that are within the beltline region.
(8) In Table 1 of Attachment A of the submittal dated April 19, 2007, the licensee indicates that the shroud support leg weld (H12) will be inspected per the requirements specified in the staffs SE for the BWRVIP-38 report, BWR Vessel Internal Project, BWR Shroud Support Inspection and Flaw Evaluation Guidelines. However, the NRC staffs final SE for the BWRVIP-38 report indicates that when inspection tooling and methodologies are developed that allow the welds in the lower plenum to be accessible, the guidelines will state that the licensee will inspect these welds with the appropriate non-destructive examination (NDE) methods in order to establish a baseline for these welds. Consistent with these requirements, the NRC staff, therefore, requests that the licensee revise Table 1 of Attachment A of the submittal dated April 19, 2007, to include a commitment that the shroud support leg weld H12 will be inspected with the appropriate NDE methods in order to establish a baseline for these welds when the inspection tooling and methodologies permit such an inspection.
(9) Top guide grid beams are prone to IASCC when they are exposed to a neutron fluence value greater than 5 x 1020 n/cm2 (E > 1 MeV). Top guide grid beams could be exposed to a neutron fluence value greater than this threshold value where by the probability of multiple failures of top guide grid beams is enhanced. Therefore, the NRC staff requests that the licensee provide the method of inspection and inspection frequency for the BWR units top guide grid beams that may potentially be exposed to a neutron fluence value greater than the threshold value during the current ISI interval.
(10) Section 4.1 item 5 of the BWRVIP-100-A report, Updated Assessment of the Fracture Toughness of Irradiated Stainless Steel for BWR Core Shrouds, states that fracture toughness values of stainless steel materials that are exposed to a neutron fluence value greater than 1 X 1021 n/cm2 (E > 1 MeV) are lower than those used in Appendix C of the BWRVIP-76 report, BWR Core Shroud Inspection and Flaw Evaluation Guidelines. Identify whether the core shroud welds and base materials in the BWR units identified in question (1) will be exposed to a neutron fluence value greater than 1 X 1021 n/cm2 (E > 1 MeV) during the current ISI interval.
Since the inspection frequency in the BWRVIP-76 report is based on fracture toughness values which are not consistent with the BWRVIP-100-A report, the staff requests that the licensee confirm the following:
The inspection frequency and strategy for welds that will be exposed to a neutron fluence value greater than 1 X 1021 n/cm2 (E > 1 MeV) during the current ISI interval will be evaluated taking into account the lower fracture toughness values that are specified in the BWRVIP-100-A report.
(11) According to Section 2.0 of the BWRVIP-76 report, core shroud welds shall be inspected every 6 years when the enhanced visual test (EVT-1) method is used for one-sided weld inspections, and shall be inspected every 10 years when the subject welds are examined with the ultrasonic test method. The inspection frequency for the core shroud welds (H1 through H7) as indicated in Table 1 of the submittal dated April 19, 2007, is not consistent with the aforementioned requirement. Therefore, the NRC staff requests that the licensee revise the inspection frequency requirement for the subject welds in Table 1 of the submittal.
(12) Table 2 of the submittal dated April 19, 2007, indicates that four core shroud vertical welds at the Oyster Creek were not inspected during the 2006 refueling outage as required by the BWRVIP-76 report guidelines. The NRC staff requests that the licensee provide technical justification for not performing the scheduled inspections and its plans for performing future inspections of these welds.