ML17317A900

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Summary of Teleconference on November 9, 2017, Regarding Verbal Authorization of Relief Request to Use Alternative for Dresden Nuclear Power Station, Units 2 and 3
ML17317A900
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 11/13/2017
From: Haskell R
Plant Licensing Branch III
To: Bryan Hanson
Exelon Generation Co
Haskell R, NRR/DORL/LPLIII
References
EPID L-LLR-2017-0018
Download: ML17317A900 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 13, 2017 LICENSEE: Exelon Generation Company, LLC.

FACILITY: Dresden Nuclear Power Station, Units 2 and 3

SUBJECT:

SUMMARY

OF TELECONFERENCE ON NOVEMBER 9, 2017, REGARDING VERBAL AUTHORIZATION OF RELIEF REQUEST TO USE ALTERNATIVE FOR DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 (EPID: L-2017-LLR-0136)

On November 9, 2017, a teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC. (the licensee).

The purpose of the call was to discuss the licensee's emergent request, submitted by letter dated November 7, 2017 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17312A293), to use an alternative to the American Society of Mechanical Engineers (ASME) Code,Section XI. The licensee proposed to implement an alternative inspection program developed by the Performance Demonstration Initiative (POI) and described in ASME Code Case N-653-1, "Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds." The licensee's proposed alternative includes the use of the POI program for the inspection of the weld overlay for weld JP1A/N20A-6 at a Dresden, Unit 2 reducer-to-pipe butt-weld in the "A" jet pump instrumentation loop header. The proposed alternative is also applicable for other weld overlaid class 1 piping at Dresden, Units 2 and 3, for the duration of the fifth ten-year inservice inspection interval (ISi), currently scheduled to end for both units on January 19, 2023.

The NRC staff reviewed the licensee's submittal and determined that the proposed alternative provides reasonable assurance of structural integrity of the subject piping. During the teleconference, at approximately 10:30 a.m., Eastern Time, November 9, 2017, the NRC staff granted verbal authorization to the licensee to use the proposed alternative in accordance with Title 10 of the Code of Federal Regulations Section 50.55a(z)(1 ). A copy of the NRC staffs verbal authorization is enclosed.

Teleconference attendees included the following:

David Wrona, Chief, Plant Licensing Branch Ill, Division of Operating Reactor Licensing (DORL)

Russell Haskell, Project Manager, DORL David Alley, Chief, Piping and Head Penetration Branch (MPHB)

John Tsao, Senior Materials Engineer, MPHB Stephen Cumblidge, Materials Engineer, MPHB John Rutkowski, Project Engineer, Region Ill Mel Hornberg, Senior Reactor Inspector, Region Ill Vijay Meghani, Resident Inspector, Region Ill

Gregory Roach, Senior Resident Inspector, Dresden Elba Sanchez Santiago, Resident Inspector, Region Ill Lionel Rodriguez, Resident Inspector, Region Ill EXELON Glen Kaegi, Director Corporate Licensing and Regulatory Affairs, Midwest Patrick Simpson, Manager, Corporate Licensing, Midwest Ken Nicely, Corporate Licensing, Midwest Mitchel Mathews, Corporate Licensing, Midwest Bruce Franzen, Dresden Regulatory Assurance Manager John Kish, Dresden lnservice Inspection Program Manager Brendan Casey, Braidwood lnservice Inspection Program Jay Miller, Exelon Non-Destructive Examination Programs David Anthony, Exelon Non-Destructive Examination Programs Kevin Hall, LaSalle Non-Destructive Examination Programs David Waskey, AREVA ASME Section XI Programs If you have any questions, please contact me at (301) 415-1129 or via e-mail at Russell.Haskell@nrc.gov.

Russell S. Haskell II, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosure:

Verbal Authorization cc w/encl: Distribution via Listserv

VERBAL AUTHORIZATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR RELIEF REQUEST 15R-16 ALTERNATIVES TO THE REQUIREMENTS OF APPENDIX VIII, SUPPLEMENT 11 OF ASME SECTION XI, 2007 EDITION 2008 ADDENDA FOR CLASS 1 PIPING DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 EXELON GENERATION COMPANY, LLC.

DOCKET NOS. 50-237 AND 50-249 NOVEMBER 9, 2017 Technical Evaluation read by David Alley, Chief of the Piping and Head Penetration Branch, NRR By letter dated November 7, 2017, Exelon Generation Company (the licensee) requested relief from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2007 Edition and 2008 Addenda, Appendix VIII, Supplement 11, for ASME Code, weld overlaid Class 1 piping at the Dresden Nuclear Power Station, Units 2 and 3.

Pursuant to Title 1O of the Code of Federal Regulations (1 O CFR) 50.55a(z)(1 ), the licensee submitted Relief Request 15R-16 to propose an alternative to ASME Code,Section XI, Appendix VIII, Supplement 11 requirements for weld overlaid Class 1 piping on the basis that the proposed alternative provides an acceptable level of quality and safety.

On November 6, 2017, the licensee identified two circumferential and one axial flaw on weld JP1A/N20A-6 which is a reducer-to-pipe weld in the "A" jet pump instrumentation loop header.

The licensee proposed to install a full structural weld overlay on the existing piping weld using the ASME Code,Section XI.

In assessing this repair, the licensee determined that it could not comply with the requirements of the ASME Code,Section XI, 2007 Edition and 2008 Addenda, Appendix VIII, Supplement 11, "Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds." As an alternative to the ASME Code requirements the licensee proposed to implement an alternative inspection program developed by the Performance Demonstration Initiative (POI) and described in ASME Code Case N-653-1, "Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds." The licensee proposed the use of the POI program for the inspection of the weld overlay for Weld JP1A/N20A-6 as well as other weld overlaid class 1 piping at Dresden, Units 2 and 3 for the duration of the fifth ten-year inspection intervals at each plant.

Enclosure

The NRC staff finds that the licensee provided sufficient basis to demonstrate that the use of the proposed POI program as proposed by the licensee and as described in ASME Code Case N-653-1 is acceptable for the inspection of weld overlaid Class 1 piping at Dresden, Units 2 and 3 including weld JP1A/N20A-6 following the weld overlay that is currently planned. Additionally, the NRC staff notes that ASME Code Case N-653-1 is included in the draft revision 18 of Regulatory Guide 1.147 without conditions. Therefore, the NRC finds that Relief Request 15R-16 will provide reasonable assurance that the structural integrity of the weld overlaid Class 1 piping including the subject butt-weld is acceptable during the time period for which the alternative has been proposed.

Authorization read by David Wrona, Branch Chief of the Plant Licensing Branch Ill, NRR As Branch Chief of the Plant Licensing Branch Ill, Office of Nuclear Reactor Regulation, I agree with the conclusions of the Piping and Head Penetration Branch.

The NRC staff concludes that the proposed alternative provides reasonable assurance of structural integrity. As such, the NRC staff finds that the alternate repair provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a (z)(1 ). Therefore, as of November 9, 2017, the NRC authorizes the use of Relief Request 15 R-16 at Dresden Nuclear Power Station, Units 2 and 3 for the fifth 10-Year ISi interval.

The authorization of this relief request does not imply or infer the NRC approval of ASME Code Case N-653-1 for generic use.

All other requirements in ASME Code,Section XI, for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.

This verbal authorization does not preclude the NRC staff from asking additional clarification questions regarding the Relief Request while preparing the subsequent written safety evaluation.

ML17317A900 *by email OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DMLR/MPHB/BC* NRR/DORL/LPL3/BC NAME RHaskell SRohrer DAllev DWrona DATE 11 /13/17 11/13/17 11/13/17 11 /13/17 OFFICE NRR/DORL/LPL3/PM NAME RHaskell DATE 11 /13/17