ML19275H136
| ML19275H136 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Nine Mile Point, Byron, Braidwood, Limerick, Clinton, LaSalle  |
| Issue date: | 10/02/2019 |
| From: | Blake Purnell Plant Licensing Branch III |
| To: | Tom Loomis Exelon Generation Co |
| References | |
| L-2019-LLR-0037 | |
| Download: ML19275H136 (4) | |
Text
1 NRR-DRMAPEm Resource From:
Purnell, Blake Sent:
Wednesday, October 2, 2019 1:06 PM To:
Loomis, Thomas R:(GenCo-Nuc) (thomas.loomis@exeloncorp.com)
Cc:
Regner, Lisa; Barstow, James:(GenCo-Nuc)
Subject:
Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Use ASME Code Case N-879 (EPID L-2019-LLR-0037)
Attachments:
Exelon Code Case N-879 - RAI.pdf Mr. Loomis:
By application dated April 30, 2019 (Agencywide Documents Access and Management System (ADAMS)
Package Accession No. ML19122A014), as supplemented by letter dated August 15, 2019 (ADAMS Accession No. ML19228A023), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request for a proposed alternative to the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, Codes and standards, and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code for Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; and Nine Mile Point Nuclear Station, Unit 2. The proposed alternative would allow the licensee to use ASME Code Case N-879, Use of Micro-Alloyed Carbon Steel Bar in Patented Mechanical Joints and Fittings, Classes 1, 2, and 3,Section III, Division 1.
The NRC staff has reviewed the application and determined that it needs additional information to complete its review. A response to the attached request for additional information is requested to be provided within 30 days from the date of this email. The NRC staff discussed this request with you on October 2, 2019. If you have any questions, please contact me at (301) 415-1380.
Sincerely, Blake Purnell, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-373, 50-374, 50-352, 50-353, 50-220, and 50-410 OFFICE NRR/DORL/LPL3/PM NRR/DMLR/MPHB/BC(A) NRR/DORL/LPL3/BC(A)
NAME BPurnell ABuford LRegner DATE 10/2/19 9/19/19 10/1/19
Hearing Identifier:
NRR_DRMA Email Number:
234 Mail Envelope Properties (BL0PR0901MB229136D8F73226C425120A73E69C0)
Subject:
Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Use ASME Code Case N-879 (EPID L-2019-LLR-0037)
Sent Date:
10/2/2019 1:06:14 PM Received Date:
10/2/2019 1:06:00 PM From:
Purnell, Blake Created By:
Blake.Purnell@nrc.gov Recipients:
"Regner, Lisa" <Lisa.Regner@nrc.gov>
Tracking Status: None "Barstow, James:(GenCo-Nuc)" <James.Barstow@exeloncorp.com>
Tracking Status: None "Loomis, Thomas R:(GenCo-Nuc) (thomas.loomis@exeloncorp.com)" <thomas.loomis@exeloncorp.com>
Tracking Status: None Post Office:
BL0PR0901MB2291.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1925 10/2/2019 1:06:00 PM Exelon Code Case N-879 - RAI.pdf 182509 Options Priority:
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Recipients Received:
REQUEST FOR ADDITIONAL INFORMATION EXELON GENERATION COMPANY, LLC ALTERNATIVE REQUEST TO USE ASME CODE CASE N-879 DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-373, 50-374, 50-352, 50-353, 50-410, AND 50-289 By application dated April 30, 2019 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML19122A014), as supplemented by letter dated August 15, 2019 (ADAMS Accession No. ML19228A023), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request for a proposed alternative to the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, Codes and standards, and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code for Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; and Nine Mile Point Nuclear Station, Unit 2.1 The proposed alternative would allow the licensee to use ASME Code Case N-879, Use of Micro-Alloyed Carbon Steel Bar in Patented Mechanical Joints and Fittings, Classes 1, 2, and 3,Section III, Division 1.
The U.S. Nuclear Regulatory Commission (NRC) has reviewed the application and determined that the information below is needed to complete its review.
RAI 1
Background The regulations in 10 CFR 50.55a(z) allow the NRC staff to authorize alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a, but do not allow the staff to approve alternatives to requirements not currently in these paragraphs. The staff does not generally approve alternatives to 10 CFR 50.55a and the ASME BPV Code beyond the current inservice inspection or test intervals, unless specific circumstances would justify a longer interval. The staff can approve alternatives for the next inservice inspection or test interval when it is near the end of the current interval and the applicable requirements for the next interval are known (e.g., see 10 CFR 50.55a(g)(4)(ii)).
The licensee requested use of the proposed alternative for the remainder of each plants 10-year inservice inspection interval and for the remainder of each plants life. Section 2 of the
application identifies the ASME BPV Code edition and addenda applicable to the current 10-year inservice inspection interval for each plant. However, the application does not identify
the ASME BPV Code edition and addenda applicable to future 10-year inservice inspection
intervals. Thus, the licensee has not demonstrated that the proposed alternative is limited to the
current requirements in paragraphs (b) through (h) of 10 CFR 50.55a.
1 The original request also included Three Mile Island Nuclear Station, Unit 1, but this request was withdrawn by letter dated June 17, 2019 (ADAMS Accession No. ML19169A031).
Request For each plant, either (1) limit the scope of the request to the current 10-year inservice inspection interval or (2) identify the specific ASME Code edition and addenda applicable to future 10-year inservice inspection intervals in which the proposed alternative will be used. In addition, provide a basis for each plant where use of the alternative is requested beyond the current interval.
RAI 2
Background
Section 5 of the application states:
The proprietary fittings that Exelon desires to use are typically designed in accordance with ASME Section Ill, NB-3671.7, Sleeve Coupled and Other Patented Joints, using the option of prototype testing. Alternatively, NC/ND-3671.7 may be used for Class 2 or 3 fittings, as applicable. The fittings will also comply with similar requirements in ASME B31.1, paragraph 123.1.2.
While the application states that prototype testing is normally performed, it also states that paragraph NC/ND-3671.7 of ASME BPV Code,Section III, may be used. Paragraph NC/ND-3671.7 does not require prototype testing and the requirements are not as prescriptive as paragraph NB-3671.7. The application also indicates that tensile testing, pressurization testing to burst, fatigue testing, and torsion testing have been performed, and this testing is provided as a basis for the acceptability of fabricating fittings from the material listed in Code Case N-879. However, the application does not clearly describe the testing that has been, or will be, performed to qualify non-standard fittings fabricated from the material specified in Code Case N-879 using NC/ND-3671.7. In addition, the range of fitting sizes that have been, or will be, tested is not provided.
Request Provide a summary of the qualification testing (with applicable testing specifications) that has been or will be performed for all Class 2 and 3 Lokring fittings made using Code Case N-879.
Clarify if the specific sizes of fittings used for repairs will be tested or will credit be taken for the testing of fitting of other sizes (e.g., specify whether NPS 2 fitting will be specifically tested or will NPS 2 fittings credit the testing of smaller fittings). If credit will be taken for fitting sizes other than those that were or will be specifically tested, provide a justification.