ML090500702
| ML090500702 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/2009 |
| From: | David M Plant Licensing Branch III |
| To: | Simpson P Exelon Corp |
| marshall david 415-1547 | |
| References | |
| TAC ME0598, TAC ME0599 | |
| Download: ML090500702 (1) | |
Text
From:
Marshall David Sent:
Friday, February 13, 2009 11:59 AM To:
patrick.simpson@exeloncorp.com Cc:
Lisa.Schofield@exeloncorp.com; ken.nicely@exeloncorp.com; Carol Nove; Ted Sullivan; Matthew Mitchell; Terence Chan; Russell Gibbs
Subject:
Supplemental Information Required: Braidwood Relief Request 13R-04 (ME0598/9)
- Pat, By letter dated February 5, 2009, Exelon Generation Company, LLC (the licensee) submitted a relief request for Braidwood Station, Units 1 and 2 (ADAMS Accession Number ML090370190).
The February 5, 2009 letter requested authorization to use augmented non-destructive examinations performed during previous refueling outages as an alternative to the reactor vessel bottom-mounted instrument penetration examination program required in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(6)(ii)(E), Footnote
- 1. The purpose of this message is to provide the results of the Nuclear Regulatory Commission (NRC) staff's acceptance review of this relief request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review was also intended to identify whether the request has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Pursuant to 10 CFR 50.55a(a)(3)(i), the applicant shall demonstrate that the proposed alternative would provide an acceptable level of quality and safety.
The NRC staff has reviewed the application and has concluded that the information delineated below is necessary to enable the staff to proceed with its detailed technical review and make an independent assessment regarding the acceptability of the proposed relief request in terms of regulatory requirements and the protection of public health and safety. The information requested was discussed with your staff on February 12, 2009.
In order to make the application complete, the NRC staff requests that you supplement the application to address the information requested by February 27, 2009. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by this date, the application will not be accepted for review pursuant to 10 CFR 2.101. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
In accordance with our process as described in LIC-109, "ACCEPTANCE REVIEW PROCEDURES," I am placing a copy of this email in ADAMS as a publicly-available, official agency record.
Sincerely, Marshall David Senior Project Manager (301) 415-1547
The licensee provided limited information to justify the ultrasonic testing (UT) techniques used.
The licensee referred to NUREG-1863 as its justification for the adequacy of its UT technique.
The text that the licensee referred to was a brief summary of high level information that industry had provided to the NRC staff. This part of the NUREG was not an evaluation of industry's UT.
In order to complete its review, the NRC staff will need documentation that describes the UT/ET techniques that the licensee used and a detailed description of how the licensee demonstrated the adequacy of those techniques.
In addition, the request states, "The CRDM [control rod drive mechanism] head penetration demonstration program was used as the basis for the BMI demonstration program." The NRC staff has reviewed MRP-166, "Demonstration of Equipment and Procedures for the Inspection of Alloy 600 Bottom Mounted Instrumentation (BMI) Head Penetrations," which relates to the UT/ET techniques that the licensee may have used. MRP-166 (page 1-1) notes that BMI demonstrations differ from CRDM demonstrations as there are significantly different nozzle configurations and sizes. In light of this statement, if MRP-166 is part of the licensee's basis for the UT/ET inspections performed, the licensee should justify its use of the CRDM penetration demonstration as the basis for the BMI demonstration program and provide a detailed comparison of the demonstration for the lower head penetrations with the demonstration industry used to justify the UT techniques for the CRDM inspections required by NRC Order EA 03-009.