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Category:Letter
MONTHYEARIR 05000456/20230042024-02-0202 February 2024 Integrated Inspection Report 05000456/2023004 and 05000457/2023004 ML24025C7242024-01-29029 January 2024 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000456/2024002; 05000457/2024002 IR 05000457/20230112024-01-25025 January 2024 2B Auxiliary Feedwater Pump Diesel Fuel Oil Dilution Report 05000457/2023011 and Preliminary Greater than Green Finding and Apparent Violation ML24018A0362024-01-17017 January 2024 Paragon Energy Solutions, Defect with Detroit Diesel/Mtu Fuel Injectors P/N R5229660 Cat Id 0001390618 RS-24-004, Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators2024-01-11011 January 2024 Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators ML23348A2162023-12-15015 December 2023 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0030 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000456/20200232023-12-15015 December 2023 Baseline Security Inspection Document; 05000456/2023/402; 05000457/2023/402 ML23277A0032023-12-11011 December 2023 Issuance of Amendments Regarding Adoption of TSTF-370 ML23339A0452023-12-0505 December 2023 Request for Information for an NRC Post-Approval Site Inspection for License Renewal Inspection Report 05000546/2024010 ML23313A1552023-12-0101 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23331A8922023-11-22022 November 2023 Supplement - Braidwood Security Rule Exemption Request ISFSI Docket No. Reference 05000457/LER-2023-001, Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case2023-11-17017 November 2023 Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case ML23321A0442023-11-17017 November 2023 Notification of Deviation from Electric Power Research Institute (EPRI) Topical Report MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline RS-23-118, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums RS-23-114, Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2023-11-0101 November 2023 Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds IR 05000456/20234012023-10-18018 October 2023 Security Baseline Inspection Report 05000456/2023401 and 05000457/2023401 IR 05000456/20230102023-10-18018 October 2023 Functional Engineering Inspection Commercial Grade Dedication Report 05000456/2023010 and 05000457/2023010 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-108, Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles2023-10-11011 October 2023 Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles RS-23-105, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2023-10-10010 October 2023 Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections RS-23-093, License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel.2023-09-29029 September 2023 License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel. ML23226A0062023-09-19019 September 2023 Review of License Renewal Commitment Number 10 Submittal ML23180A1692023-09-11011 September 2023 Calvert Cliff Units 1 & 2, and R.E. Ginna Plant - Withdrawal of Proposed Alternatives to American Society of Mechanical Engineers (ASME) Requirements (Epids L-2022-LRR-0074, 0076, 0079, 0091, 0092, 0093 and 0094) IR 05000456/20230052023-08-30030 August 2023 Updated Inspection Plan for Braidwood Station Report 05000456/2023005 and 05000457/2023005 ML23234A2462023-08-25025 August 2023 Confirmation of Initial License Examination IR 05000456/20230022023-08-0303 August 2023 Integrated Inspection Report 05000456/2023002 and 05000457/2023002 ML23188A1292023-07-26026 July 2023 Issuance of Amendment Nos. 233 and 233 Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 ML23087A0762023-07-13013 July 2023 Issuance of Amendment Nos. 232 and 232 Revision of Technical Specifications for the Ultimate Heat Sink ML23191A8442023-07-10010 July 2023 05000456; 05000457 Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III RS-23-083, Withdrawal - Proposed Alternatives Related to the Steam Generators2023-06-27027 June 2023 Withdrawal - Proposed Alternatives Related to the Steam Generators RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23110A1152023-06-12012 June 2023 Environmental Assessment and Finding of No Significant Impact Related to a Requested Increase in Ultimate Heat Sink Temperature (EPID L-2023-LLA-0042) (Letter) RS-23-074, Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-06-0909 June 2023 Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-075, Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process2023-06-0707 June 2023 Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process RS-23-050, Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube.2023-05-22022 May 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube. ML23138A1342023-05-18018 May 2023 Information Meeting with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Braidwood Station and Byron Station ML23132A0472023-05-12012 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ML23130A0072023-05-10010 May 2023 Submittal of Core Operating Limits Report Cycle 24, Rev. 16 IR 05000456/20230012023-05-0808 May 2023 Integrated Inspection Report 05000456/2023001 and 05000457/2023001 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI ML23118A0202023-04-28028 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report ML23110A3202023-04-21021 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection RS-23-056, Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 102023-04-20020 April 2023 Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 10 RS-23-055, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors2023-04-10010 April 2023 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors ML23095A1292023-04-0505 April 2023 Steam Generator Tube Inspection Report for Refueling Outage 23 ML23094A1352023-04-0404 April 2023 Request for Information for Nrc Commercial Grade Dedication Inspection Inspection Report 05000456/2023010 05000457/2023010 RS-23-052, License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-03-24024 March 2023 License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations 2024-02-02
[Table view] Category:Safety Evaluation
MONTHYEARML23277A0032023-12-11011 December 2023 Issuance of Amendments Regarding Adoption of TSTF-370 ML23241A9092023-09-19019 September 2023 Enclosure 2 - Non-Proprietary - Review of License Renewal Commitment Number 10 Safety Evaluation ML23188A1292023-07-26026 July 2023 Issuance of Amendment Nos. 233 and 233 Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 ML23087A0762023-07-13013 July 2023 Issuance of Amendment Nos. 232 and 232 Revision of Technical Specifications for the Ultimate Heat Sink ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI ML22364A0242023-03-0101 March 2023 R. E. Ginna Nuclear Power Plant Issuance of Amendments Nos. 231, 231, 232, 232, and 154 Regarding Adoption of TSTF-246 ML22293B8052022-11-30030 November 2022 Constellation Energy Generation, Llc_Fleet - Request to Authorize Use Honeywell Mururoa V4F1 R Supplied Air Suits ML22307A2462022-11-10010 November 2022 Proposed Alternative to the Requirements of the American Society of Mechanical Engineers Boiler & Pressure Vessel Code (EPIDs L-2021-LLR-0035 and L-2021-LLR-0036) ML22210A0312022-08-30030 August 2022 Issuance of Amendments Nos. 230, 230, 230, and 230, Respectively, Regarding Adoption of Technical Specifications Task Force Traveler (TSTF) 501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control ML22173A1812022-08-11011 August 2022 Issuance of Amendment No. 229 to Remove License Condition ML22173A2142022-08-10010 August 2022 Issuance of Amendments Nos. 228 and 228 Revision of Technical Specifications for the Ultimate Heat Sink ML22095A2702022-05-12012 May 2022 Issuance of Amendment Nos. 227, 227, 229, 229, and 245, Respectively, Regarding Adoption of TSTF 273, Safety Function Determination Program Clarifications ML22090A0862022-04-29029 April 2022 Amendments to Adopt TSTF-541,Rev.2,Add Exceptions to Surveillance Requirements for Valves,Dampers Locked in Actuated Position ML22026A4892022-03-22022 March 2022 Issuance of Amendment Nos. 225, 225, 227, 227, and 148, Respectively, Regarding Issues Identified in Westinghouse Documents (EPID L-2021-LLA-0066) Nonproprietary ML21347A0382022-01-13013 January 2022 Issuance of Amendments to Revise Reactor Coolant Leakage Requirements ML21277A2482021-11-16016 November 2021 Letter with Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (Public Version) ML21280A0782021-10-27027 October 2021 Proposed Alternative to Use of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case N-893 (Epids L-2020-LLR-0147 and L-2020-LLR-0148) ML21230A2062021-09-0303 September 2021 Proposed Alternative to Use ASME OM Code Case OMN-28 ML21216A2202021-08-0505 August 2021 Proposed Alternative to Eliminate Certain Documentation Requirements for Pressure Retaining Bolting ML21134A0062021-08-0303 August 2021 Proposed Alternatives to the Requirements of the American Society of Mechanical Engineers Boiler & Pressure Vessel Code (Epids L-2020-LLR-0099 and L-2020-LLR-0100) ML21154A0462021-07-13013 July 2021 Issuance of Amendments Nos. 222 and 222 Revision of Technical Specifications for the Ultimate Heat Sink ML21166A1682021-06-25025 June 2021 ML21060B2812021-04-0202 April 2021 Issuance of Amendments Nos. 221, 221, 224, and 224 Regarding Technical Specifications 3.8.1, AC Sources-Operating ML21054A0082021-03-10010 March 2021 Issuance of Amendment Nos. 220 and 220 One-Time Deferral of Steam Generator Tube Inspections ML21063A0162021-03-0808 March 2021 Relief from the Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Alternative to 10 CFR 50.55a(z)(2) ML21039A6362021-02-17017 February 2021 R. E. Ginna - Proposed Alternative to Use the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Case N-885 ML21028A6732021-02-0303 February 2021 Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI (EPID L-2020-LLR-011 ML20317A0012020-12-28028 December 2020 Non-Proprietary, Issuance of Amendment Nos. 219, 219, 223, and 223, Revise Loss-of-Coolant Accident Methodology in TS 5.6.5, Core Operating Limits Report (COLR) ML20287A1302020-11-0505 November 2020 Review of Quality Assurance Program Changes ML20269A2002020-09-30030 September 2020 Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI (EPID L2020-LLR-0117 ML20245E4192020-09-24024 September 2020 Issuance of Amendments Nos. 218 and 218 Revision of Technical Specifications for the Ultimate Heat Sink ML20163A0462020-09-18018 September 2020 Issuance of Amendments Nos. 217, 217, 221, and 221, Revise Technical Specification 5.6.6 to Allow Use of Areva Np Topical Report BAW-2308 ML20167A0072020-09-11011 September 2020 R. E. Ginna - Issuance of Amendment Nos. 216, 216, 220, 220, and 143 - Adoption of TSTF-567, Rev. 1, Add Containment Sump Technical Specifications to Address GSI-191 Issues ML20149K6982020-09-10010 September 2020 Issuance of Amendment Nos. 215, 215, 219, and 219 Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML20232A1712020-09-0101 September 2020 Request to Use Alternative Code Case OMN-26 ML20153A8042020-07-31031 July 2020 Co. - Issuance of Amendments Revising Emergency Action RA3 ML20141L6362020-07-10010 July 2020 Issuance of Amendments Based on TSTF-427,Allowance for Nontechnical Specification Barrier Degradation on Supported System Operability,Rev 2 ML20134H9402020-07-0808 July 2020 Issuance of Amendments Revising the High Radiation Area Administrative Controls ML20118C4292020-06-0909 June 2020 Issuance of Amendments Revision of Technical Specifications for the Ultimate Heat Sink ML20133K0932020-05-14014 May 2020 Relief from the Requirements of the ASME Code ML20111A0002020-05-0101 May 2020 Issuance of Amendment No. 209, Revision Technical Specification 5.5.9, Steam Generator (SG) Program, for One-Time Revision to Frequency of SG Tube Inspections (Exigent Circumstances) ML20113F0412020-04-30030 April 2020 Proposed Alternative to the Submittal Schedule for Certain Reports (COVID-19) ML20021A0702020-04-0606 April 2020 Issuance of Amendments to Delete License Conditions for Decommissioning Trusts ML19331A7252020-02-14014 February 2020 Issuance of Amendments Revising Emergency Action Levels ML20028E3992020-02-0404 February 2020 Proposed Alternative to Use ASME Code Case N-879 ML19269C5342019-09-27027 September 2019 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19240B1122019-09-0909 September 2019 Proposed Alternative to the Requirements of the American Society of Mechanical Engineers Code ML19190A0812019-08-28028 August 2019 Issuance of Amendments Regarding Limiting Condition of Operation for Inoperability of Snubbers ML19192A2442019-07-18018 July 2019 Proposed Alternative to Use ASME Code Cases N-878 and N-880 ML19136A3862019-06-0505 June 2019 Relief from the Requirements of the American Society of Mechanical Engineers Code 2023-09-19
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Text
Mr. Charles G. Pardee November 8, 2007 Senior Vice President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2 - RELIEF REQUEST (I2R-49)
REGARDING INSERVICE INSPECTION PROGRAM ALTERNATIVE METHOD (TAC NOS. MD5996 AND MD5997)
Dear Mr. Pardee:
By letter dated July 10, 2007 (Agencywide Document Access And Management System Accession No. ML071910315), the Exelon Generation Company, LLC, (the licensee) submitted Relief Request (I2R-49) proposing an alternative to the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a, concerning certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for certain inservice inspection (ISI) programs at Braidwood Station (Braidwood), Units 1 & 2.
Specifically, the licensee proposed using ASME Code Case N-696, Qualification Requirements for Appendix VIII Piping Examination Conducted from the Inside Surface, and a root mean square (RMS) error criterion for flaw sizing that is greater than the ASME Code,Section XI, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds, Paragraph 3.2(b); ASME Code Case N-695, Qualification Requirements for Dissimilar Metal Piping Welds, Paragraph 3.3(c); and Code Case N-696, Paragraph 3.3(d) acceptance criterion for examinations performed from the inside surface of pressure boundary piping. ASME Code Case N-695 is an alternative to Appendix VIII, Supplement 2, Qualification Requirements for Wrought Austenitic Piping Welds, which is referenced in Regulatory Guide (RG) 1.147, Inservice Inspection Code Case Acceptability, ASME Code,Section XI, Division 1. The request is for the second 10-year inservice inspection (ISI) interval which is scheduled to end July 28, 2008, for Unit 1 and October 16, 2008, for Unit 2.
Based on the enclosed review, the NRC staff concludes that ASME Code Case N-696 (qualifying personnel and procedures for examinations performed from the pipe ID on dissimilar metal welds) provides an acceptable level of quality and safety, and therefore, is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the remainder of the second 10-year ISI interval at Braidwood Station.
C. Pardee In addition, the NRC staff concludes that compliance with the ASME Code-required 0.125-inch RMS depth sizing error is impractical, and that the proposed alternative for a coordinated Supplement 2 and Supplement 10 (Code Case N-696) provides reasonable assurance of structural integrity, and therefore, pursuant to 10 CFR 50.55a(g)(6)(i), relief is granted for Braidwood Station, for the second 10-year ISI interval.
The NRC staff's safety evaluation is enclosed.
Sincerely,
/RA/
Russell A. Gibbs, Branch Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457
Enclosure:
Safety Evaluation cc w/encl: See next page
C. Pardee In addition, the NRC staff concludes that compliance with the ASME Code-required 0.125-inch RMS depth sizing error is impractical, and that the proposed alternative for a coordinated Supplement 2 and Supplement 10 (Code Case N-696) provides reasonable assurance of structural integrity, and therefore, pursuant to 10 CFR 50.55a(g)(6)(i), relief is granted for Braidwood Station, for the second 10-year ISI interval.
The NRC staff's safety evaluation is enclosed.
Sincerely,
/RA/
Russell A. Gibbs, Branch Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsRgn3MailCenter LPL3-2 R/F RidsNrrDorlLpl3-2 RidsOgcRp TBloomer, EDO, Region III RidsNrrLAEWhitt RidsAcrsAcnwMailCenter Don Naujock, DCI/CPNB RidsNrrPMMThorpe-Kavanaugh Adams accession no.: ML072760048 *See memo ML072690252 OFFICE LPL3-2/PM LPL3-2/LA DC/CPNB/BC OGC LPL3-2/BC NAME MThorpe- EWhitt TChan* MSmith RGibbs Kavanaugh DATE 10/26/07 10/26/07 9 / 25 /07 10/15/07 11/8/07 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST I2R-49 EXELON GENERATION COMPANY, LLC BRAIDWOOD STATION, UNITS 1 AND 2 SECOND 10-YEAR INSERVICE INSPECTION INTERVAL DOCKET NOS. STN 50-456 AND STN 50-457
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC) dated July 10, 2007 (Agencywide Document Access And Management System (ADAMS) Accession No. ML071910315), the Exelon Generation Company, LLC, (the licensee) submitted a relief request (I2R-49) proposing an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at the Braidwood Station (Braidwood), Units 1 & 2.
Specifically, the licensee proposed using ASME Code Case N-696, Qualification Requirements for Appendix VIII Piping Examination Conducted from the Inside Surface, and a root mean square (RMS) error criterion for flaw sizing that is greater than the ASME Code,Section XI, Appendix VIII, Supplement 10, Qualification Requirements for Dissimilar Metal Piping Welds, Paragraph 3.2(b); ASME Code Case N-695, Qualification Requirements for Dissimilar Metal Piping Welds, Paragraph 3.3(c); and ASME Code Case N-696, Paragraph 3.3(d) acceptance criterion for examinations performed from the inside surface of pressure boundary piping. ASME Code Case N-695 is an alternative to Appendix VIII, Supplement 2, Qualification Requirements for Wrought Austenitic Piping Welds, which is referenced in Regulatory Guide (RG) 1.147, Inservice Inspection Code Case Acceptability, ASME Code Section XI, Division 1. The request is for the second 10-year inservice inspection (ISI) interval which is scheduled to end July 28, 2008, for Unit 1 and October 16, 2008, for Unit 2.
2.0 REGULATORY EVALUATION
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(g)(4), ASME Code Class 1, 2, and 3 components must meet the requirements set forth in ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plants Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that all inservice examinations and system pressure tests conducted during the first 10-year interval, and subsequent intervals, comply with the requirements in the latest edition and addenda of ASME Code,Section XI, incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 10-year interval.
For Braidwood, the Code of Record for Units 1 and 2 second 10-year ISI interval is the 1989 Edition of Section XI of the ASME Code.
Alternatives to requirements may be authorized or relief granted by the NRC pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or 10 CFR 50.55a(g)(6)(i). In proposing alternatives or request for relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in Enclosure
hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. Pursuant to 10 CFR 50.55a(g)(4)(iv), ISI items may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to Commission approval. Portions of editions and addenda may be used provided that related requirements of the respective editions and addenda are met.
3.0 TECHNICAL EVALUATION
FOR REQUEST I2R-49 3.1 Affected Components The request is specific to pipe welds.
3.2 Applicable Code For Units 1 and 2, second 10-year ISI interval, the ISI Code of record for ultrasonic testing (UT) examinations is the 1995 Edition with 1996 Addenda of the ASME Code,Section XI, Appendix VIII, Supplement 2 and Supplement 10, Paragraph 3.2(b) (for both supplements) which states that the RMS error for flaw depths estimated by UT shall not exceed 0.125-inch.
3.3 Proposed Alternative The licensee proposed using the Electric Power Research Institute (EPRI) - Performance Demonstration Initiative (PDI) program for the implementation of Appendix VIII, Supplement 10, Paragraph 3.2(b), 0.189-inch RMS error in lieu of the ASME Code-required 0.125-inch RMS criterion.
The licensee proposed using Code Case N-696, Paragraph 3.3(d), with a 0.245-inch RMS criterion in lieu of the required 0.125-inch RMS error.
The difference between 0.189-inch (Supplement 10) and the ASME Code-required 0.125-inch RMS error and the difference between 0.245-inch (Supplement 2) and ASME Code-required 0.125-inch RMS error will be added to the UT measured flaw depth for the purpose of flaw evaluation.
3.4 Licensee Basis for the Alternative The licensee is performing volumetric examinations of all nozzle-to-safe end welds, dissimilar metal (DM) welds, and a select number of adjacent safe end-to-pipe or safe end-to-elbow welds from the inside diameter (ID) surface during the second ten-year ISI inspection interval. If only the DM weld is examined, the licensee will use the NRC approved Code Case N-695 for qualification requirements. However, for a DM weld and an adjacent austenitic similar metal weld examination, the licensee proposed using Code Case N-696 which is a coordinated Supplement 2 and Supplement 10 qualification.
The licensee also proposes using an alternative RMS error depth-sizing requirement as compared to the 0.125-inch RMS error value stated in Supplement 10, Code Case N-695, and Code Case N-696. The licensee contracted the Electric Power Research Institute (EPRI)
Nondestructive Examination (NDE) Center on June 15, 2007 and confirmed that no vendor has successfully demonstrated compliance with the ASME Code required 0.125-inch RMS error for qualification tests performed from the ID surface (for either stand alone Supplement 10 or coordinated Supplement 2 and 10 qualifications).
The licensee has verified through the EPRI-NDE Center that the vendor selected to perform the UT examinations at Braidwood has achieved a 0.245-inch RMS error for the Coordinated Supplements 2 and 10 qualification (as addressed in Code Case N-656) and 0.189-inch RMS error (as addressed in Code Case N-695) for the stand alone Supplement 10 qualification.
3.5 Evaluation The licensees ISI Code of record for Units 1 and 2 second 10-year ISI interval is the 1989 Edition with no addenda. 10 CFR 50.55a(g)(6)(ii)(C)(2) require licensees using the 1989 Edition or earlier editions and addenda ISI Code of record to use the 1995 Edition with 1996 Addenda of the ASME Code,Section XI, Appendix VIII to qualify personnel and procedures for UT examinations. The licensees vendor performed a Supplement 10 (Code Case N-695) and a coordinated Supplement 2 and Supplement 10 (Code Case N-696) performance demonstration as implemented by the EPRI-PDI program. The licensee is requesting to use Code Case N-696 with an 0.245-inch RMS error in lieu of the 0.125-inch RMS error in Paragraph 3.3(d). Code Case N-696 is in the process of being reviewed for endorsement in RG 1.147.
The NRC staff participated in the development of Code Case N-696 in the ASME Code consensus building process. The NRC issued Draft RG Guide (DG) DG-1134, Proposed Revision 15 of Regulatory Guide 1.147, dated October 2006 which referenced Code Case N-696 as acceptable without conditions.
The ASME Code requires that the maximum error for flaw depth measurements, when compared to the true flaw depth, must not exceed 0.125-inch RMS error. The nuclear power industry has been trying to qualify personnel and procedures for examinations performed from the inside pipe diameter of austenitic similar metal (Supplement 2/Code Case N-695) and dissimilar metal welds (Supplement 10/Code Case N-696) since November 2002. However, to date, no personnel or procedure has achieved the ASME Code-required maximum RMS error.
The difficulties are associated with the surface roughness of the field welds. As licensees perform ID UT examinations, they are taking profilometry measurements which can be used to assess the representativeness of the test specimens used to establish the vendors RMS error criterion. At this time, achieving a 0.125-inch maximum RMS error criterion is impractical.
The licensee has stated that the vendor has achieved an 0.189-inch RMS in their Supplement 10 (Code Case N-695) performance demonstration and an 0.245-inch RMS error in their coordinated Supplement 2 and Supplement 10 (Code Case N-696) performance demonstration.
The licensee proposed adding the depth sizing difference between their demonstrated 0.189-inch RMS error and the ASME Code-required 0.125-inch RMS error to the measured flaw value of any flaws in an austenitic similar metal weld, and the difference between the demonstrated 0.245-inch RMS error and the ASME Code-required 0.125-inch RMS error to the measured flaw value of any flaws in dissimilar metal welds.
The NRC staff finds that compliance with the ASME Code-required RMS error criterion is impractical at this time and that adding the difference between the performance demonstrated
depth sizing RMS error and the ASME Code-required depth sizing RMS error to the measured flaw value for determining acceptability according to the standards specified in ASME Section XI, IWB-3500, provides reasonable assurance of structural integrity.
4.0 CONCLUSION
Based on the above review, the NRC staff concludes that Code Case N-696 (qualifying personnel and procedures for examinations performed from the pipe ID on dissimilar metal welds) provides an acceptable level of quality and safety, and therefore, is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the remainder of the second 10-year ISI interval at Braidwood, Units 1 and 2.
Based on the above review, the NRC staff concluded that compliance with the ASME Code-required 0.125-inch RMS depth sizing error is impractical, and that the proposed alternative to use an 0.189-inch RMS error for Supplement 10 (Code Case N-695) and an 0.245-inch RMS error for a coordinated Supplement 2 and Supplement 10 (Code Case N-696) provides reasonable assurance of structural integrity. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), relief is granted for Braidwood, Units 1 and 2 for the second 10-year ISI interval.
The granting of relief is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest, given the consideration of the burden upon the licensee.
All other requirements of the ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: D. Naujock Date: November 8, 2007
Braidwood Station, Units 1 and 2 cc:
Document Control Desk - Licensing Oregon, IL 61061 via e-mail Manager Regulatory Assurance - Braidwood via e-mail Mr. Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Director - Licensing and Regulatory Affairs via e-mail via e-mail Ms. Bridget Little Rorem Associate General Counsel Appleseed Coordinator via e-mail via e-mail Senior Vice President - Midwest Operations Howard A. Learner via e-mail Environmental Law and Policy Center of the Midwest Vice President - Regulatory Affairs via e-mail via e-mail Braidwood Senior Resident Inspector Manager Licensing - Braidwood, Byron U.S. Nuclear Regulatory Commission and LaSalle via e-mail via e-mail Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Illinois Emergency Management Agency Division of Disaster Assistance &
Preparedness via e-mail County Executive via e-mail Attorney General 500 S. Second Street Springfield, IL 62701 Plant Manager - Braidwood Station via e-mail Site Vice President - Braidwood via e-mail Senior Vice President - Operations Support via e-mail Chairman, Ogle County Board Post Office Box 357 Enclosure