RS-13-107, Supplement to Fifth Inservice Inspection Interval Relief Requests I5R-01, I5R-02, and I5R-07
| ML13154A248 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/03/2013 |
| From: | Simpson P Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-13-107 | |
| Download: ML13154A248 (14) | |
Text
4301 1
j 0JU RS-1 3-107 RS-13-107 10 CFR SO.SSa 50.55a June 3,2013 June 3, 2013 U. S.
U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission ATTN: Document A TIN: Document Control Desk Control Desk Washington, D.C. 20555-0001 Washington, D.C. 20SSS-0001 Dresden Nuclear Dresden Nuclear Power Power Station, Station, Units Units 22 and and 33 Renewed Facility Operating License Renewed Facility Operating License Nos. DPR-19 Nos. DPR-19 andand DPR-25 DPR-2S NRC Docket Nos. 50-237 NRC Docket Nos. SO-237 and S0-249 and 50-249
Subject:
Subject:
Supplement Supplement to to Dresden Dresden Nuclear Nuclear Power Power Station Station Fifth Fifth Inservice Inservice Inspection Inspection Interval Interval Relief Requests 15R-01, 15R-02, Relief Requests ISR-01, ISR-02, and 15R-07and ISR-07
References:
References:
1.
- 1. Letter Letter from from D. D. M.
M. Gullott Gu"ott (Exelon (Exelon Generation Generation Company, Company, LLC (EGC)) (EGC>> to to U.
U. S.
S.
NRC, "Dresden NRC, "Dresden Nuclear NuclearPower PowerStation, Station, Units Units 22 and and 3,3,Fifth Fifth Interval Inservice Intervallnservice Inspection Program Plan Inspection Program Plan and and Relief Relief Requests,"
Requests," dated September 28, 2012 28,2012 2.
- 2. Letter Letter from from P. P. R.
R. Simpson Simpson (EGC)
(EGC) to to U.
U. S.
S. NRC, NRC, "Supplement "Supplementto to the theDresden Dresden Nuclear Power Nuclear Power StationStation Fifth Fifth Inservice Inservice Inspection Inspection Interval Interval Relief ReliefRequest Request 15R-01," dated November ISR-01," dated November 19, 2012 19,2012 3.
- 3. Letter Letter from from P. P. R.
R. Simpson SimpsQn (EGC)
(EGC) to to U.
U. S.
S. NRC, NRC, "Supplement "Supplementto tothe theDresden Dresden Nuclear Nuclear Power Power Station Station and and Quad Quad Cities Cities Nuclear NuclearPower PowerStation StationFifth Fifth Inservice Inservice Inspection Inspection Interval IntervalRelief ReliefRequest Request15R-02,"
ISR-02," dated dated November November28, 28, 2012 2012 In In the the referenced referenced letters, letters, EGC EGC submitted submitted relief relief requests requests and and supplemental supplemental information information associated with the fifth inservice inspection (ISI) interval for Dresden associated with the fifth inservice inspection (lSI) interval for Dresden Nuclear NuclearPowerPowerStation Station (DNPS), Units 2 and 3. During the NRC's review of the referenced (DNPS), Units 2 and 3. During the NRC's review of the referenced documents, theNRC documents, the NRCfound found that thatadditional additionalinformation informationisisrequired requiredtotosupport supportitsitsreview review ofof Relief Requests Relief Requests 15R-01, ISR-01, 15R-02, ISR-02, and and 15R-07.
ISR-07. The The requested requested information informationisisprovided provided ininthetheattachments attachmentsto tothis thisletter.
letter.
June 3, 2013 3,2013 U. S.
U. S. Nuclear Regulatory Commission Page 2 EGC continues to request approval of of these these relief relief requests requests by by September September 28,28, 2013, 2013, to to support support examination of of components components during during the the DNPS, DNPS, Unit Unit 22 Fall Fall 2013 2013 refueling refueling outage outage which which isis currently scheduled to occur occur within the fifth fifth 10-year 10-year ISI lSI interval.
interval.
There are no regulatory regulatory commitments commitments contained contained in in this this letter.
letter.
Should you have any questions concerning this letter, please please contact Mr. Mitchel A.
contact IVlr. A. Mathews at (630) 657-2819.
Patrick R. Simpson Manager -- Licensing Licensing Exelon Generation Company, LLC LLC Attachments:
- 1. Response to NRC Request for Additional InformationInformation
- 2. Dresden Nuclear Power Station Fifth ISI lSI Interval Interval Risk-Informed Risk-Informed Inservice Inservice Inspection Inspection (RISI)
(RISI)
Summary Tables
ATTACHMENT 1 ATTACHMENT
Response
Response to to NRC Request for Additional Information Based on Based on the the staffs staff's review of of Relief Relief Request Request 15R-01:
ISR-01:
NRC Request NRC Request 15R-01-1.
ISR-01-1. Discuss in Discuss in the the Relief Relief Request why why the proposed proposed alternative provides reasonable assurance of of structural integrity or or leak leak tightness of the subject component(s).
Exelon Generation Exelon Generation Company.
proposed alternative looks for and verifies structural integrity and leak The proposed leak tightness tightness by by ensuring ensuring no leakage no leakage atat nominal nominal operating operating pressure pressure during during thethe Class Class 11 System System Leak Leak test.
test. This test is a Code required Code required exam exam thatthat verifies verifies nonothrough through wall wall leakage leakagefor forthe theentire entire Class Class 11 boundary.
boundary. It is performed performed prior to start-up to start-up and and unit operation every outage to provide confidence there there isis no no leakage. The Standby leakage. The Standby Liquid Liquid Control nozzle nozzle is included as part of this test. Passing Passing of thistest of this test with no identified through wall with wall leakage at the nozzle provides reasonable reasonable assurance assurance of of structural structural integrity and and leak tightness of the Standby Standby Liquid Liquid Control Control nozzle.
nozzle.
During normal During normal plant plant operation.
operation, the Standby Liquid Control nozzle is inaccessible inaccessible for direct direct visual observation based observation based on its location in the drywell. This This does not preclude the nozzle frombeing does not preclude the nozzle from being monitored. Leakage from the nozzle would be collected ininthe monitored. Leakage from the nozzle would be collected thedrywell drywellsumps, sumps,prompting promptingactionaction from the station.
from station. No No leakage leakage from from this this nozzle nozzle has has ever ever been been observed observed at at Dresden Dresden Nuclear Nuclear Power Station (DNPS), Units 2 2 and and 33 from from this this location.
location.
NRC Request NRC Request15R-01-2.
ISR-01-2. Discuss Discuss in in the Relief Request how the Relief how the specified requirements of of this section would result resultin in hardship or unusual or unusual difficulty difficulty without a compensating increase in In the the level level ofofquality quality and and quality and quality and safety.safety.
EGC Response:
EGC Response:
Based on the configuration configuration of of the the nozzle nozzle as as discussed discussed in in Reference Reference 2, the required required exam exam is is extremely difficult to perform, difficult to perform, and may may not yield information that could be used to ascertainthe not yield information that could be used to ascertain the structural integrity of structural integrity ofthe thecomponent.
component. The The nozzle nozzledesign designcontains containsreflectors reflectors that thatdodonot notallow allowaa meaningful exam to be be performed.
performed. Additionally, Additionally,the theperformance performanceofofthis thisexam examwould wouldresult resultinin significant radiation dose to plant workers.
significant radiation dose to plant workers. Without the guarantee guaranteeof ofobtaining obtaining meaningful meaningful
- results, results. the performance of this exam would be be contrary contrary to industry and NRC NRC practices practicesrelated related to maintaining radiation radiation dose as low as reasonably achievable achievable (ALARA),
(ALARA). and represent represent hardship hardship without without aa compensating compensating increase increasein in quality quality and and safety.
safety.
Page Page 11 of of77
ATTACHMENT1I ATTACHMENT Response to Response to NRC NRC Request Requestfor for Additional Additional Information Information NRC Request NRC Request 15R-01 15R-01-3. -3. Provide Provide aa technical technical basis basis as as to to why why the the ultrasonic ultrasonic testing testing is not required.
required.
EGC Response:
EGC Response:
Due to Due to the the design design of of the the component.
component, an an ultrasonic ultrasonic testtest does does notnot provide provide any any data data that thatcould couldbebe used for determining the condition of the nozzle. The complex used for determining the condition of the nozzle. The complex cladding/socket configuration cladding/socket configuration impedes EGC's impedes EGC's ability ability toto obtain obtain ultrasonic ultrasonic test test results results that that would would be be meaningful meaningful or or useful useful in in determining the structural integrity and leak tightness of the Standby Liquid Control nozzle.
determining the structural integrity and leak tightness of the Standby Liquid Control nozzle.
Based on Based on the the staffs staff's review review of of Relief Relief Request 15R-02:
Request 15R*02:
NRC Request NRC Request 15R-02-1.
15R-02-1. Do the Do the augmented augmented inspection inspection programs programs for for IGSCC IGSCC Category B-G (Generic Letter 88-01),
(Generic Letter 88-01), service water integrity (Generic Letter 89-13), FAC 13), FAC (Generic (Generic Letter Letter 89-09),
89-09), and high-energy line break (HELB)(USNRC Branch Technical Position (HELB)(USNRC Branch Technical Position MEB MEB 33-1)- 1) remain unaffected (as unaffected (as described in the initial DNPS RI-lSl RI-ISI submittal submittal dated October dated October 18, 2000) by 18,2000) by the the RI -ISI program developed RI-ISI developed for for the the fifth interval?
fifth interval?
EGC Response:
EGC Response:
For the DNPS For the DNPS fifth fifth inservice inservice inspection inspection (ISI) (lSI) interval, interval, the the treatment treatment of ofthe theabove abovereferenced referenced augmented augmented inspection inspection programs programs remains remains unaffected unaffected in in comparison comparisonwith with the theRisk-Informed Risk-Informed Inservice Inspection Inservice Inspection (RISI)(RISI) Program implemented in Program implemented in the the fourth fourth lSIISI interval.
interval. No No changes changes are are being being made made in in the the fifth fifth ISI lSI interval interval that that alter alter thethe implementation implementation methodology methodologyof ofthe theaugmented augmented programs programs or or RISI RISI Program.
Program.
NRC NRC Request Request15R-02-2.
15R-02-2. Are Are thethe inspection inspection locationslocations in the DNPS RI-ISI RI-ISI programs programs that that have have been been developed developed for for the the fifth fifth 10 -year interval 10-year interval the same same locations locations as as those those in the fourth interval interval RI-ISIRI-ISI programs programs approved in the NRC staff's September approved in the NRC staff's September 4, 2003, safety 4, 2003, safety evaluation?
evaluation? IfIfnot, not, please please summarize summarize the the changes changes to to the the program and what caused program and what caused those changes. those changes.
EGC EGC Response:
Response
The The RISI RISI Program Program isisrequired required to toandandhashasbeen beenmaintained maintainedas asaaliving livingprogram programassessing asseSSing component component and configuration changes and major Probabilistic Risk Assessment(PRA) and configuration changes and major Probabilistic Risk Assessment (PRA)model model revisions revisions throughout the fourth lSI interval. As part of the fifth lSI interval update process, the throughout the fourth ISI interval. As part of the fifth ISI interval update process, the consequence consequence and and degradation degradationassignments assignmentsand andresultant resultantcomponent componentrisk riskrankings rankingshavehavebeen been confirmed confirmed or or updated, updated, element elementselections selectionshave havebeenbeenadjusted, adjusted,and andthe therisk riskimpact impactassessment assessment has has been revised. The final R1SI evaluation for the previous fourth lSI intervalwas been revised. The final RISI evaluation for the previous fourth ISI interval wasRevision Revision55 dated dated January 2010. The latest evaluation, Revision 6, dated December 2012. is thecurrent January 2010. The latest evaluation, Revision 6, dated December 2012, is the current evaluation evaluation developed developed as as part part of of the the new new fifthfifth interval interval RISI RISI Program.
Program. The Thechanges changesinininspection inspection Page Page 22of of7 7
ATTACHMENT 1 ATIACHMENT1 Response to NRC Response to NRC Request Request for Additional Information Information locations from locations from the the initial initial fourth fourth interval interval RISI Program (i.e.,(Le., Revision Revision 33 dateddated December December2002)2002) to to the new the new fifth fifth interval interval RISI RISI Program Program are are summarized summarized in in the the Tables Tables 11and and 22below.
below.
Table 1: DNPS Unit 2 Selection Summa Intend 4 In al 5 ^;
R Rart^
tts s tt i '04ii (RISIRe to High High 49 49 58 *n Limited Exam Coverage Limited
- n Plant/Component Plant/Component Modifications
- n Revisions 1 PRA Model Revisions' Medium Medium 47 55 55 *n Limited Exam Coverage
- n Plant/Component Plant/Component Modifications
- n Revisions1 PRA Model Revisions' Total Total 96 96 113 1 Latest incorporated Latest incorporated revision is PRA PRA Model Model DR209A DR209A Table 2:
Table 2: DNPS DNPS Unit Unit 33 Selection Selection Summary Summa lnterval4;, II"nterval Risk
" ` Exams- Exams- l Affecting Chan Rangy RIM N^1)' Mt Revs.
High High 41 41 50 0 *n Limited Exam Coverage 5
n* Plant/Component Plant/Component Modifications Modifications n* PRA Model Revisions' Revisions1 Medium Medium 50 50 56 n* Limited Exam CoverageCoverage n* Plant/Component Plant/Component Modifications Modifications n* PRA Model Revisions' Revisions 1 Total Total 91 91 106 106
'1 Latest incorporated revision is PRA PRA Model Model DR209A DR209A Limited Exam Coverage - The The welds welds selected selected for for examination examination were were changed changed in in some some cases cases toto optimize optimize examination examination codecode coverage.
coverage.
Plant Plant Modifications Modifications -- As As discussed discussed above, above, the the RISI RISI Program Program has hasbeen been maintained maintained throughout the fourth ISI lSI interval as a living program. Various Variousminor minorplant plant modifications modifications were were installed installed throughout throughout thethe interval interval and and were wereevaluated evaluatedforforimpact impact to the the RISI RISI Program, Program, and and when when applicable, applicable, changes changesto tothe theRISI RISIscope scopeandandelement element selections selections werewere made.
made. No Nomajor majorcomponent componentreplacements replacementsor ornew newsystem system installations installations were were mademade during during this this period period affecting affecting the theRISIRISI program.
program.
Page Page 33 of of 77
ATTACHMENT 1I ATIACHMENT Response to NRC Response to NRC Request for Request for Additional Information Information PRA Model Revisions PRA -Model The Revisions DNPS PRA - TheModelDNPS PRA applicable to thetoinitial Model applicable fifthfifth the initial interval interval RISI Program RISI Program was was revised revised in in December December 2009 2009 and and issued issued as as Model Model DR209A.
DR209A. This This revision of revision of the the model model waswas incorporated incorporated into into Revision Revision 5Sof of the the RISI RISI Program Program in in January 2010.
January 2010. As As the the model model is is updated updated throughout throughout the the interval, interval, impact impact on on the the RISI RISI Program is Program is assessed assessed and and the the program program is is updated updated as as necessary.
necessary.
In Reference In Reference 33 above, above, the the changes changes in in risk risk from from thethe pre-RISI pre-RISI Section Section XI XI program program to to the thefifth fifth interval RISI interval RISI Program were provided to demonstrate demonstrate that that the the acceptance acceptance criteria criteria forfordelta-core delta-core damage frequency damage frequency (Delta-CDF)
(Delta-CDF) and and delta-large delta-large earlyearly release release frequency frequency (Delta-LERF)
(Delta-LERF) described described in Regulatory in Regulatory Guide Guide 1.174, "An Approach 1.174, "An Approach for for Using USing Probabilistic Probabilistic Risk Risk Assessment Assessmentin in Risk-Risk-Informed Decisions Informed Decisions on on Plant-Specific Plant-Specific Changes Changes to to the the Licensing Licensing Basis,"
Basis," were were met.met. As As stated stated above, the above, the latest evaluation developed as as part part ofof the the new new fifth fifth interval interval RISIRISI Program Program isis Revision 66 dated Revision dated December 2012. 2012. The The latest latest evaluation evaluation resulted resulted in in slight slight changes changes to to the the delta-CDF and delta-LERF values provided in Reference 3. The revised values, based on delta-CDF and delta-LERF values provided in Reference 3. The revised values, based on the the latest evaluation, are listed in Table 3 below. The revised values remain latest evaluation, are listed in Table 3 below. The revised values remain within the acceptance within the acceptance criteria described criteria described in in Regulatory Regulatory Guide Guide 1.174.
1.174.
Table 3: Change in Risk from Pre-RISI Section XI Pro ram to Fifth Interval RISI Proar Stati o n `: : 1 ) it- l C Ita-IL R DNPS Unit DNPS Unit 22 4.62E-9 4.62E-9 2.03E-09 DNPS Unit DNPS Unit 33 3.00E-09 3.00E-09 9.85E-09 9.8SE-09 NRC Request NRC Request 15R-02-3.
15R-02-3. If there are changes in the inspection locations for for the the DNPS DNPS fifth 10-year interval RI-ISI fifth 10-year interval RI-ISI programs programs please provide information for the fifth interval program regarding: examinations examinations
/system/components
/systemlcomponents /degradation /degradation mechanisms mechanisms /class, Iclass, etc.
similar similar to that provided in Tables 2, 2, 3, 4, 5 and 5 and 6 of6 of the original submittal of of the RI-ISI program RI-/SI program for the DNPS third 10-year for the DNPS third 10-year inservice inspection interval dated October October 18, 18, 2000 (ADAMS Accession Accession No. ML003762371).
MLOO3762371).
EGC EGC Response:
Response
A summary summary of of the the changes changes to to the the inspection inspectionlocations locationsbetween betweenthe theoriginal originalRISI RISIProgram Program implemented in the fourth ISI lSI interval and the revised program prepared for thefifth interval and the revised program prepared for the fifthISIlSIinterval interval is is contained in the response to NRC Request No. ISR-02-2 above. Updated Tables 2through contained in the response to NRC Request No. 15R-02-2 above. Updated Tables 2 through66 similar similar to to those those provided provided in in the the original original submittal submittal of ofthe the RISI RISI Program Programare areprovided providedinin Attachment Attachment 2. 2.
Page Page 44 of of77
ATTACHMENT 1 ATIACHMENT1 Response to Response to NRC Request for Additional Information Information NRC Request NRC Request 15R-02-4.
15R-02-4. The The description description and and disposition of of the gap identified identified in Attachment 11 of Attachment of relief request request 15R-0215R*02 for for supporting supporting requirement DA-C12 does DA*C12 does not not address address the the requirements requirements in the American Society of Mechanical Engineers (ASME)IAmerican (ASME)/American Nuclear Nuclear Society (ANS) RA-Sa-2009, Society RA-Sa-2009, "Addenda "Addenda to to ASMEIANS ASME/ANS RA-S-200B:
RA-S-2008:
Level 1/Large Early Release Frequency Standard for Level11Large Probabilistic Risk Assessment for Nuclear Power Plant Applications." ProvideProvide verification verification that that a review was conducted that shows support system dependencies are are properly properly captured as required by the standard.
standard. In addition, In addition, specify whether specify whether peer-review or self*assessment self-assessment results indicate whether this supporting requirement is categorized as capability Category I or not-met.
not-met. IfIfcategorized categorized as "not-met", provide the disposition that ascertains the supporting requirement Is is now capability Category Category I.
EGC Response:
EGC Response:
Supporting requirement Supporting requirement (SR) (SR) DA-C12 DA-C12 in in the the American American Society Society of ofMechanical Mechanical Engineers/American Nuclear Society RA-Sa-2009 (ASMEIANS 2009 Engineers/American Nuclear Society RA-Sa-2009 (ASME/ANS 2009PRA PRAStandard)
Standard)addresses addresses the unavailability of frontline systems due to the unavailability of support systems. The the unavailability of frontline systems due to the unavailability of support systems. TheDNPS DNPS gap listed gap listed in in Attachment Attachment 11 of of the the submittal submittal refers refers to to supporting supporting requirement requirementDA-C12 DA-C12ininthe theRA-RA-Sb-2005 version Sb-2005 version of of the the standard, standard, not the 2009 not the 2009 Standard.
Standard. DA-C12DA-C12ininthe the2009 2009Standard Standard isis equivalent to equivalent to DA-CI1 DA-C 11 a a in the 2005 in the 2005 version version of the standard.
of the standard. The TheDNPS DNPSFPIE FPIEPRAPRAusedusedininthe the RISI analysis meets DA-C1 la with a Capability RISI analysis meets DA-C11 a with a Capability Category I. Category I.
Based Based on the staff's on the staff's review review ofofRelief ReliefRequest Request15R-07:
NRC NRC Request Request15R-07-1.
/5R-07-1. The staff staff requests that that the licensee licensee identify identify whether whether there are any any furnace-sensitized stainless steel vessel attachment attachment welds welds associated associated with with the RVI components at at the the Dresden Nuclear Nuclear Power Power Station, Units 22 and 3. ItItis isrequested requestedthat thatthe thelicensee licensee provide provide an an explanation explanation regarding regarding the the type type ofofinspection inspection program program and and anyany additional additional augmented augmented inspection inspection program program that that are implemented implemented for for any any existing furnace-sensitized stainless stainless steel steel attachment attachment welds welds in these boiling water reactor (BWR) units.
units.
EGC EGC Response:
Response
Dresden Dresden Nuclear Nuclear Power PowerStation Station (DNPS),
(DNPS),Unit Unit2 2does doeshavehavefurnace-sensitized furnace-sensitizedstainlessstainlesssteel steel vessel vessel attachment welds associated with the RVI components, but DNPS, Unit 3 does not. The attachment welds associated with the RVI components, but DNPS, Unit 3 does not. The furnace- sensitized stainless furnace-sensitized stainless steel steel vessel vessel attachment attachment weldswelds on on Unit Unit22will will be beexamined examinedinin accordance accordance withwith the the inspection inspection recommendations recommendationsofofBWRVIP-48-A, BWRVIP-48-A,"Vessel "VesselID 10Attachment Attachment Weld Weld Inspection and Evaluation Guidelines," as discussed in DNPS Updated FinalSafety Inspection and Evaluation Guidelines," as discussed in DNPS Updated Final Safety Analysis Analysis Report Report (UFSAR),
(UFSAR), Appendix AppendixA, A, Section SectionA.1.4, A 1.4,"BWR "BWRVessel VesselID 10Attachment AttachmentWelds."
Welds."
Page Page 55 of of 77
ATTACHMENT 1
Response
Response to to NRC Request for Additional Information Request 15R-07-2.
NRC Request /SR-07-2. The staff requests that the licensee confirm whether The whether NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Retum 0619, Return Line Nozzle Cracking,"
Cracking." will be used for the inspection inspection of feedwater sparger tee welds and feedwater sparger piping piping brackets.
EGC Response:
Yes. NUREG-0619, Yes. NUREG-0619, "BWR Feedwater Nozzle and and Control RodRod Drive Return Return Line Nozzle Cracking," will Cracking," will be be used used for for the the inspection inspection of of feedwater feedwater sparger tee welds and and feedwater feedwatersparger sparger piping brackets.
piping NRC Request Request15R-07-3.
ISR-07-3. Section 4.1 item 5S of of the BWRVIP - 100-A report, BWRVIP-100-A report, "Updated Assessment of of the Fracture Toughness of of Irradiated Irradiated Stainless Steel for BWR Core Shrouds, Shrouds,"" states that fracture toughness values ofof stainless steel materials that are exposed to a neutron fluence value greater than 1 X 1021 nlcm2 greater than n/cm2 (E >> 11 MeV)
Mel/) are lower than those used in Appendix C of of the BWRVIP- 76 BWRVIP-76 report,report, "BWR Core Shroud Inspection and Flaw Evaluation Guidelines."
and Flaw Evaluation Guidelines. "
Identify whether whether the the core core shroud shroud welds welds and base materials will be exposed to a neutron fluence value greater than I1X X 1021 1021 nlcm2 (E > 1 MeV) during the current lSI interval. Sincethe n1cm2 (E > 1 MeV) during the current ISI interval. Since the inspection frequency in the BWRVIP-76 report is based on fracture toughness values which which are are not not consistent consistentwith with the the BWRVIP-100-A report, report, the staff staff requests that the licensee address the following issue:
The inspection The inspection frequency frequency and and strategy strategy that are specified specified in Section 3 of the BWRVIP-76 3 of BWRVlP*76 reportreport require require further further evaluation taking into account the lower fracture toughness values that that are are specified specifiedin inthe theBWRVIP-100-A BWRVIP-100-A report.report.
EGC Response:
Not applicable atat this time as nono shroud shroud or or reactor reactor pressure pressure vessel vessel structures structures areare predicted predicted toto be exposed exposed to to aa neutron neutron fluence fluence ofofgreater greaterthanthan 11 X 1021 n/cm2 X 1021 n/cm 2 (E (E > 11 MeV)
MeV) during the current 120-month 120-month ISI lSI interval.
interval. Moreover, Moreover, no no current current estimations estimations predict predict crossing crossing this this threshold threshold atat any any point point during during the the future.
future.
Page Page 66 of of 77
ATTACHMENT 1 ATTACHMENT Response to Response toNRC NRC Request Requestfor forAdditional AdditionalInformation Information NRC Request NRC Request 15R-07-4. Dresden and Quad Cities (DIQC)
ISR*07*4. Dresden (D/QC) Safety Safety Evaluation Report, "NUREG-1796, Related to the License Renewal of "NUREG-1796, of the Dresden Station, Units 2 and 3 and Quad Cities Nuclear Nuclear Power Station, Units 1 and Station, Units Power Station, and 2," License Renewal Commitment (LRA) #9 in Appendix A of of NUREG-1796 states that the licensee should implement the staff staff approved AMP for the steam dryers D/QC units.
at the DIQC units. In In July July 2009, 2009, the the BWRVIP BWRVIP issued a staff BWRVIP- 139-A, "BWR approved topical report BWRVIP-139-A, "BWR Vessel and and Internals Project, Steam Dryer Inspection and Flaw Evaluation Evaluation Guidelines." TheThe staff staffrequests requests that that the the licensee licensee confirm confirm that that itit will comply with the guidelines guidelines addressed addressed in in the the BWRVIP-139-A BWRVIP-139-A report as per per LRA #9 in NUREG-1796.
EGC Response:
EGC Response:
DNPS will comply with the guidelines addressed in in the BWRVIP-139-A, "BWR Vessel and "BWRVessel Internals Project, Internals Project, Steam Dryer Inspection and Flaw Evaluation Guidelines," as discussed discussed inin DNPS UFSAR, Appendix A, Section A.2.10, "Periodic Inspection of Steam "Periodic Inspection of Steam Dryers."Dryers."
NRC Request Request 15R-07-5.
ISR-07-S. Consistent with the LRA commitment #9, with respect to the AMP related to the top guide, the licensee should confirm that it will comply with the inspection inspection guidelines guidelines addressed in the BWRVIP-26-A BWRVIP-26*A and BWRVIP-BWRVlp*183 183 reports.
EGC Response:
EGC Response:
DNPS DNPS has hasimplemented implemented the theguidance guidanceprovided provided in BWRVIP-26-A, "BWR Top Guide Guide Inspection and Flaw Flaw Evaluation Guidelines" Evaluation Guidelines" and BWRVIP-183, BWRVIP*183, "Top Guide Grid Beam Inspection and Flaw Evaluation Inspection Evaluation Guidelines,"
Guidelines," as as discussed discussed in DNPS UFSAR, Appendix Appendix A, A,
Section A.1.9, "BWR "BWR Vessel Internals."
Internals."
Page Page 77of7of 7
ATTACHMENT 22 ATTACHMENT Dresden Nuclear Power Power Station Station Fifth Fifth Interval Interval Risk-Informed Risk-Informed Inservice InserviceInspection Inspection(RISI)
(RISI)Summary SummaryTables Tables Page 1 of 5 RISI Final Report Table 2: Failure Potential Assessment RISI Assessment Summary Summary for for Unit Unit22and andUnit 35 Unit35 h
Thermal Fatigue Stress Corrosion Cracking Localized Corrosion Corrosion Flow Sensitive System TASCS TT IGSCC TGSCC ECSCC PWSCC MIC PIT CC E-C FAC CRD'1 CR0 ECCS22 ECCS X X X X
FW X X X X X
HPCI X MS33 MS X X X X X X
4 RCS4 RCS XX X X
RWCU X X X
NOTES:
1.
- 1. Includes scram discharge volume volume (CRDSD).
(CROSO).
RHSP.
- 3. Includes isolation condenser (ISCOCR, ISCOSS).
3.
- 4. Includes
- 4. Includes reactor recirculation recirculation (RR),
(RR), reactor head vent (RHV), jet pump pump (JPIA, (JPIA, JPIB),
JPIB), and and RPV RPV level level instrument instrumentnozzles nozzles (LVLA, LVLB, UVLA, UVLB).
(LVLA, UVLB).
- 5. This This table shows shows the assessed assessed failure failure mechanisms mechanisms for for each system. The each system. TheRISI RISI program program addresses addresses the the cumulative cumulative impact of all mechanisms that that were were identified in each identified in each system.
system.
TASCS - thermal thermal stratification, stratification, cycling cycling and and striping, striping, TT TT -- thermal thermaltransients, transients,IGSCC IGSCC--intergranular intergranularstress stresscorrosion corrosioncracking, cracking, TGSCC - transgranular transgranular stress stress corrosion corrosion cracking, cracking, ECSCC ECSCC -- external externalchloride chloridestress stresscorrosion corrosion cracking, cracking, PWSCC PWSCC -- primary primary corrosion cracking, water stress corrosion cracking, MICMIC-- microbiologically influenced corrosion, microbiologically influenced corrosion, PIT PIT-- pitting, pitting, CC CC -- crevice corrosion, corrosion, E-C -
erosion-cavitation, FAC - flow erosion-cavitation, flow accelerated accelerated corrosion corrosion
ATTACHMENT 2 Dresden Nuclear Nuclear Power Power Station Station Fifth Fifth Interval Interval Risk-Informed Risk-Informed Inservice InserviceInspection Inspection(RISI)
(RISI)Summary SummaryTables Tables Page 2 of 5 RISI RISI Final Report Table 3: 3: Number of Elements (Welds) by Risk Category for Unit Unit 2 High High Risk Medium Risk Low Risk TOTAL Category 6 or All System Category Category 11 Category 2 Category 3 Category 4 Category 5 7 Categories 1
CR0 CRD' 64 64 ECCS22 ECCS 53 148 22 435 638 FW 45 11 56 HPCI 12 32 142 186 I 3
MS MS3 3 16 66 121 86 292 4
RCS RCS4 115 115 95 7 87 304 304 RWCU 10 5 15 6 14 50 SBle SBLC 13 35 11 49 SOC SDC 47 47 24 71 TOTAL 48 254 82 426 47 853 1710 NOTES:
1.
- 1. Includes scram discharge volume volume (CROSO).
(CRDSD).
3.
- 3. Includes isolation isolation condenser (ISCOCR, ISCOSS).
- 4. Includes Includes reactor recirculation recirculation (RR), head vent (RR), reactor head vent (RHV), jet pump (JPIA, JPIB), and RPV RPV level level instrument instrument nozzles (lVLA, (LVLA, lVlB, UVlB).
LVLB, UVLA, UVLB).
ATTACHMENT 2 ATIACHMENT2 Dresden Nuclear Dresden Nuclear Power Power Station Station Fifth Fifth Interval Interval Risk-Informed Risk-Informed Inservice Inspection (RISI) Summary Tables Page 30f5 Page 3 of 5 RISI Final RISI Final Report Report Table Table 4:4: Number Number of of Elements Elements (Welds)
(Welds) by by Risk Risk Category Category forfor Unit 3 High Risk High Risk Medium Risk Medium Risk low Low Risk Risk TOTAL TOTAL i
System Category Category 66 or or All All System Category 1 Category Category 22 Category Category 33 Category Category 44 Category Category Category 55 77 Categories Categories CRD'1 CR0 51 51 51 51 ECCS22 ECCS 27 27 147 147 22 484 484 660 660 FW FW 46 46 11 11 57 57 HPCI HPCI 22 99 29 29 147 147 187 187 3
MS3 MS 55 10 10 74 74 112 112 95 95 296 296 RCS44 RCS 125 125 99 101 101 235 235 RWCU RWCU 44 15 15 66 17 17 42 SBLC SBlC 17 17 57 57 11 75 SDC SOC 44 44 19 19 63 TOTAL TOTAL 51 51 100 100 89 89 465 465 46 46 915 915 1666 NOTES:
NOTES:
- 1. Includes
- 1. Includes scram discharge volume (CRDSD).
(CROSO).
- 2. Includes CS,
- 3. Includes
- 3. Includes isolation isolation condenser (ISCOCR, ISCOSS).
- 4. Includes
- 4. Includes reactor recirculation (RR), reactor head vent (RHV), jet jet pump pump (JPIA, (JPIA, JPIB),
JPIB), and and RPV RPVlevel level instrument instrument nozzles (lVLA, nozzles (LVLA, LVLB, UVLA, UVLB).
ATTACHMENT 2 Dresden Nuclear Power Station Fifth Interval Risk Dresden -Informed Inservice Inspection (RISI) Summary Tables Risk-Informed Page 4 of 5 Page4of5 RISI Final RISI Final Report Table 5: Number of Inspections by Risk Category CategoryforforUnit 25 ,6 Unit25,6 High Risk Medium Risk Low Low Risk All Risk Categories Category Category 11 Category 2 Category 3 Category 4 Category 5 Category 6 or 7 Pre -
Pre- Pre -
Pre- Pre -
Pre- Pre -
Pre- Pre -
Pre- Pre -
Pre-System RISI RISI RISI RISI Pre-RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI CRD11 CR0 5 0 5 0 2
ECCS2 ECCS 19 19 14 12 16 39 0 70 30 FW 7 6 11 2 8 8 HPCI 4 2 2 4 13 0 19 6 3
MS3 MS 11 11 3 3 4 14 33 13 19 0 60 31 RCS44 RCS 2 2 21 13 4 11 21 0 48 16 RWCU 4 2 3 0 7 2 SBlC SBLC 5 4 8 4 13 8 SOC SDC 12 12 5 0 17 12 TOTAL 8 7 41 -
35 5 16 82 82 50 50 66 55 105 0 247 247 113 NOTES:
- 1. Includes scram discharge
- 1. discharge volume volume (CRDSD).
(CRDSO).
- 2. Includes CS,
- 3. Includes isolation condenser (ISCOCR, ISCOSS).
3.
- 4. Includes reactor recirculation (RR), reactor head vent
- 4. vent (RHV),
(RHV), jet jet pump pump (JPIA, (JPIA, JPIB),
JPIB). and and RPV RPVlevel levelinstrument instrument nozzles (LVLA, (lVLA, LVLB, lVlB, UVLA, UVLA, UVLB).
UVlB).
- 5. This table provides a comparison of the RISI
- 5. RISI element selection selection to the the previous previous Third Third Interval's Interval's 1989 1989 ASME ASME Section Section XIXI program (Pre-RISI).
- 6. This table includes the number of welds previously selected for ASME Section XI (Pre-RISI),
- 6. (Pre-RISI), but excludes the number number of welds previously selected selected for ASME Section XI (Pre-RISI) that now default to the the augmented augmented programs programs for for IGSCC IGSCC and FAC.
ATTACHMENT ATTACHMENT 2 Dresden Nuclear Dresden Nuclear Power StationStation Fifth Fifth Interval Risk-Informed Inservice Inspection (RISI) Summary Tables Page 55 of 55 Page RISI Final RISI Final Report Table Table 6: 6: Number NumberofofInspections Inspections by by Risk Risk Category Category for forUnit Unit35,6 35.6 High Risk High Risk I Medium Risk Medium Low Low Risk Risk All All Risk Categories Categories Category Category 1 Category Category 2 2 Category Category 3 3 1 Category Category 4 4 ( Category 5 Category Category Category 6 6 or 7 Pre -
Pre- Pre-Pre - Pre -
Pre- Pre-Pre - Pre -
Pre- Pre-Pre -
System System RISI RISI RISI RISI RISI RISI RISI I Pre-RISI RISI Pre-RISI I RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI RISI CRD' CR0 1 44 0 4 o0 '
2 ECCS2 ECCS 11 11 77 19 19 16 16 40 0 70 23 23 FW FW 8 66 11 22 9 88 HPCIHPCI 2 22 2 3 14 14 00 18 18 5 I 3
MS3 MS 11 22 11 11 88 16 30 12 12 15 15 00 55 55 31 31
- RCS44 RCS 44 14 14 33 11 25 25 00 72 72 15 15 RWCU RWCU 33 2 5 0 8 2 SBLC SBLC 55 5 14 14 6 19 19 11 11 SDC SOC 10 10 11 11 6 00 16 16 11 11 TOTAL 1 TOTAL 99 1 88 27 1 24 24 1 9 1 18 18 1 112 112 1 52 52 1 5 1 4 1 109 109 1 0 271 1 106 NOTES:
NOTES:
- 1. Includes
- 1. Includes scram discharge volume volume (CRDSD).
(CROSO).
- 2. Includes
- 3. Includes
- 3. Includes isolation condenser (ISCOCR, ISCOSS).
- 4. Includes
- 4. Includes reactor recirculation (RR), reactor head vent (RHV), (RHV), jet jet pump pump (JPIA, (JPIA, JPIB),
JPIB), and and RPVRPVlevel levelinstrument instrument nozzles (LVLA, LVLB, UVLA, UVLB).
nozzles UVLB).
- 5. This
- 5. This table provides provides a comparison of the RISI element selection to the previous previous Third Interval' Interval'ss 1989 ASME Section XI program (Pre-RISI).
program
- 6. This
- 6. This table includes the number of welds previously selected for ASME Section XI (Pre-RISI), but excludes the number welds previously of welds previously selected selected for ASME Section XI (Pre-RISI) that now default to the the augmented augmented programs programs for IGSCC IGSCC and FAC.