ML080740325

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Evaluation of New Information Related to Alloy 82/182 Pressurizer Butt Weld Inspections Confirmatory Action Letter NRR-07-008
ML080740325
Person / Time
Site: Braidwood 
Issue date: 03/14/2008
From: Catherine Haney
Plant Licensing Branch III-2
To: Pardee C
Exelon Generation Co
Gratton C, NRR/DORL/LPL3-2, 415-1055
References
TAC MD7295, NRR-07-008
Download: ML080740325 (2)


Text

March 14, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNIT 2 - EVALUATION OF NEW INFORMATION RELATED TO ALLOY 82/182 PRESSURIZER BUT WELD INSPECTIONS RE:

CONFIRMATORY ACTION LETTER NRR-07-008 (TAC NO. MD7295)

Dear Mr. Pardee:

On March 22, 2007, the U.S. Nuclear Regulatory Commission (NRC) issued Confirmatory Action Letter (CAL) No. NRR-07-008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070740294) regarding dissimilar metal welds in the pressurizer surge, spray, and safety/relief nozzle-to-safe end welds at Braidwood Station (Braidwood), Unit 2. The CAL and the supporting commitment letter (ADAMS Accession No. ML070520499) indicate that inspection and mitigation actions may be conducted during your spring 2008 refueling outage, contingent on the industry providing an analysis that demonstrates an acceptable level of safety to the NRC for the operation of these welds until the spring of 2008.

The NRC received MRP-216, Rev. 1, Materials Reliability Program: Advanced FEA [Finite Element Analysis] Evaluation of Growth of Postulated Circumferential PWSCC [Primary Water Stress-Corrosion Cracking] Flaws in Pressurizer Nozzle Dissimilar Metal Welds, on August 13, 2007 (ADAMS Accession No. ML072410235). Based on our review of this report, NRC concluded that the analysis provided adequate justification to permit inspections during your spring 2008 refueling outage, and that the analysis was applicable to Braidwood, Unit 2. On September 7, 2007, the NRC issued a letter to Exelon Generation Company, LLC (ADAMS Accession No. ML072430292), informing you that a plant shutdown by December 31, 2007, was no longer needed and Braidwood, Unit 2 could continue to operate until the spring 2008 outage.

On March 4, 2008, the NRC became aware of emerging information regarding certain welds in nozzles on a retired pressurizer from a pressurized-water reactor facility. This was related to new reports (ADAMS Accession Nos. ML080701017 and ML080701020) on weld examinations of those nozzles. This information raised questions regarding the technical basis for the September 7, 2007, letter. The NRC dispatched technical experts in non-destructive examination to independently review industry analyses and actions regarding this matter. On March 13, 2008, a public meeting was held in NRC Headquarters, Rockville, MD, with representatives of the eight licensees whose plants had not yet shut down for spring 2008 outages and who are subject to commitments to inspect or mitigate similar welds during spring 2008 outages.

The NRC has evaluated the non-destructive automated phased array ultrasonic examination performed since March 4, 2008, and concluded there is reasonable assurance that there is no structurally significant service-related degradation in those nozzles that would alter the conclusions provided in our letter dated September 7, 2007, that allowed continued operation of Braidwood, Unit 2 until the spring 2008 refueling outage. The NRC will continue to evaluate new information as it becomes available. All other requirements of the CAL and the supporting commitment letter regarding enhanced inspection and leakage monitoring requirements for the reactor coolant system and associated reports remain valid.

The CAL will remain open until all CAL commitments pertaining to Braidwood, Unit 2 are complete.

Current NRC guidance regarding CALs is contained in the NRC Enforcement Policy and the NRC Enforcement Manual, which are available at the NRC web site at http://www.nrc.gov/about-nrc/regulatory/enforcement.html (click on Enforcement Policy or Enforcement Guidance) or by contacting the Government Printing Office (GPO) toll-free at 1-888-293-6498. The GPO is open from 7:00 a.m. to 9:00 p.m. EST, Monday through Friday (except Federal holidays).

In accordance with Title 10 of the Code of Federal Regulations, Part 2, Section 390, of the NRC's "Rules of Practice," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm.html.

Sincerely,

/RA by Tim McGinty for/

Catherine Haney, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. STN 50-457 cc: See next page

The NRC has evaluated the non-destructive automated phased array ultrasonic examination performed since March 4, 2008, and concluded there is reasonable assurance that there is no detectable structurally significant operational degradation in those nozzles that would alter the conclusions provided in our letter dated September 7, 2007, that allowed continued operation of Braidwood, Unit 2 until the spring 2008 refueling outage. The NRC will continue to evaluate new information as it becomes available. All other requirements of the CAL and the supporting commitment letter regarding enhanced inspection and leakage monitoring requirements for the reactor coolant system and associated reports remain valid.

The CAL will remain open until all CAL commitments pertaining to Braidwood, Unit 2 are complete.

Current NRC guidance regarding CALs is contained in the NRC Enforcement Policy and the NRC Enforcement Manual, which are available at the NRC web site at http://www.nrc.gov/about-nrc/regulatory/enforcement.html (click on Enforcement Policy or Enforcement Guidance) or by contacting the Government Printing Office (GPO) toll-free at 1-888-293-6498. The GPO is open from 7:00 a.m. to 9:00 p.m. EST, Monday through Friday (except Federal holidays).

In accordance with Title 10 of the Code of Federal Regulations, Part 2, Section 390, of the NRC's "Rules of Practice," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm.html.

Sincerely,

/RA by Tim McGinty for/

Catherine Haney, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. STN 50-457 cc: See next page DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsAcrsAcnw&mMailCenter RidsEdoMailCenter RidsNrrOd RidsNrrDci RidsNrrDciCpnb RidsNrrDirs RidsNrrDorl RidsNrrDorlLpl3-2 RidsNrrLAJBurkhardt RidsNrrLAEWhitt RidsNrrPMMMarkley RidsNrrPMMDavid RidsOEMailCenter RidsOgcRp RidsRgn3MailCenter RLickus, R-III SLO MWidman, EDO R-III RJStrasma, OPA R-III ESullivan, NRR/DCI/CPNB ADAMS Accession No. ML080740325

(*) by e-mail

(**) see previous concurrence NRR-106 OFFICE DCI/CPNB DCI/CPNB/BC DORL/LPL3-2/PM DORL/LPL4/LA NAME TSullivan TChan MDavid, CG for JBurkhardt DATE 3/14/08, w/comments 3/14/08 3/14/08 3/14/08 OFFICE DORL/LPLIII-2/BC NRR/DCI/D DRP/D, R-III NRR/DORL/D NAME RGibb, CG for MEvans CPederson, SWest for Chaney, TJM for DATE 3/14/08 3/14/08 3/14/08 3/14/08 OFFICIAL AGENCY RECORD

Braidwood Station Units 1 and 2 cc:

Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355 Pittsburgh, PA 15230 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, IL 60935 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Dr., Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 1035 Outer Park Dr Springfield, IL 62704 County Executive Will County Office Building 302 N. Chicago Street Joliet, IL 60432 Attorney General 500 S. Second Street Springfield, IL 62701 Plant Manager - Braidwood Station Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Site Vice President - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Senior Vice President - Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Manager Regulatory Assurance - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Midwest Operations Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood, Byron and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555