ML092930148

Comment (5) of David P. Helker on Behalf of Exelon Generation Company, LLC Opposing Draft Regulatory Guide DG-1222, Control of Preheat Temperature for Welding of Low-Alloy Steel.

ML092930148
Person / Time
Site:	Dresden, Peach Bottom, Point Beach, Byron, Braidwood, Limerick, Quad Cities, Zion, LaSalle
Issue date:	10/01/2009
From:	David Helker Exelon Corp, Exelon Generation Co, Exelon Nuclear
To:	Rulemaking, Directives, and Editing Branch
References
74FR31993 00005, DG-1222
Download: ML092930148 (1)

Text

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October 1, 2009 Rulemaking and Directives Branch.,....5....

Office of Administration Mail Stop TWB-05-BO1 M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments Concerning Draft Regulatory Guide DG-1222, "Controlof PreheatTemperature for Welding of Low-Alloy Steel" (Federal Register Notice 74FR31993, dated July 6, 2009)

Exelon Generation Company, LLC (Exelon) is submitting this letter in response to a request from the Nuclear Regulatory Commission (NRC) for comments concerning Draft Regulatory Guide DG-1222, "Controlof PreheatTemperature for Welding of Low-Alloy Steel." DG-1222 is proposed Revision 1 to Regulatory Guide 1.50 (same title), dated May 1973.

10CFR50, Appendix B, requires that measures be established to ensure control of materials and of special processes such as welding and that proper process monitoring be performed.

DG-1222 describes a method acceptable to the NRC for implementing these requirements with regard to the control of welding for low-alloy steel components during initial fabrication.

Exelon appreciates the opportunity to comment on DG-1222, and offers the following comments for consideration by the NRC.

General Comments Section C, "Regulatory Position" Item 2 states that: "Forproduction welds, the preheat temperature should be maintaineduntil final postweld heat treatment or a hydrogen bakeout is performed between 200 and 400 0C (400 and 750 "F) for a minimum of four hours.... " Exelon considers the minimum "four-hour" period to be excessive for leaner material chemistries, thinner materials, and standard groove weld joint design and high heat input weld processes. Exelon suggests that a graduated scale approach be considered to allow for the variance associated with the factors previously discussed.

If you have any questions or require additional information, please do not hesitate to contact Mr.

Richard Gropp at 610-765-5557.

Respectfully, David P. Helker - S -* * -* '

Manager - Licensing