ML21139A172

Acceptance Review Memo Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Pressure Retaining Bolting Requirements

ML21139A172
Person / Time
Site:	Dresden
Issue date:	05/19/2021
From:	Haskell R Plant Licensing Branch III
To:	Tom Loomis Exelon Generation Co
Haskell R-NRR/DORL 301-415-1129
References
Download: ML21139A172 (2)

Text

From: Haskell, Russell To: thomas.loomis@exeloncorp.com Cc: Steinman, Rebecca L:(Exelon Nuclear)

Subject:

(Dresden) Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting Date: Wednesday, May 19, 2021 8:26:48 AM Mr. Loomis:

By application dated December 1, 2020 (ADAMS Accession No. ML20336A008), Exelon Generation Company, LLC (the licensee) submitted a request in accordance with Paragraph 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to certain requirements of 10 CFR 50.55a, Codes and standards.

This was a fleet-based request which included the Dresden Nuclear Power Station, Units 2 and 3 (Dresden). The proposed alternative would allow the licensee to forgo preparation and completion of a repair and replacement plan and certain forms for pressure retaining bolting, that is not classified as Examination Categories B-G-1, B-G-2, or C-D, at this facility.

By supplemental letter dated April 20, 2021 (ADAMS Accession No. ML20336A008),

Exelon included responses to NRC staff questions regarding the initial application, as referenced above. As a result of the Exelon responses, the NRC staff identified issues that pertained to the Dresden proposed alternative on the aforementioned topic. The specific details of these issues were communicated to you via an NRC email message from the NRC Exelon Fleet Project Manager (B. Purnell) on April 26, 2021. In the message you were informed that the NRC staff has decided the supplemental letter included information for Dresden that is beyond the scope of the original application, which was accepted for review on December 14, 2020 (ADAMS Accession No. ML20350B558). You were informed the NRC staff will review the proposed alternative for Dresdens sixth 10-year ISI interval, separately, from the original application (which also included Dresdens 5th ISI interval).

The submittal date for this new task was determined to be April 20, 2021, which coincides with the supplemental information furnished by Exelon. This review will be performed by the NRC staff with the project code of EPID L-2021-LLR-0030. (The NRC staff will continue the Dresden review for the 5th ISI interval under the original application and EPID project code L-2020-LLR-0155). Additionally, on Tuesday May 18, 2021, the NRC staff held a public Observation Meeting with the Exelon staff to assess and clarify several remaining questions associated with these efforts. Shortly following this meeting, Exelon submitted a letter to the NRC dated May 18, 2021, Supplemental Information Concerning Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting (ADAMS Accession No. ML21138A839), which included clarifying information for the staff to consider for the Dresden 6th ISI interval review.

After a preliminary review of Exelons furnished information, the NRC staff has concluded that the request provides a sufficient level of technical information for the staff to commence with a detailed technical review and to make an independent assessment regarding the acceptability of the proposed request in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review process, as compared to a detailed technical review, there may be instances in which issues that impact the NRC staffs ability to complete its review are identified, despite completion of an adequate acceptance review. If additional information is needed, Exelon will be advised by separate correspondence.

Based on the information provided in the request, the NRC staff has estimated that this review will take approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> to complete by Exelons request date of January 22, 2022. These estimates are based on the NRC staffs initial review of the application and they could change due to several factors, including requests for additional information or an unanticipated addition of project scope identified during the review. Should the NRC staff identify any emergent complexities or challenges that would cause significant changes to these estimates, they will be promptly communicated during routine exchanges between the NRC Project Manager/Exelon staff.

Russell S. Haskell II United States Nuclear Regulatory Commission (NRC)

Licensing Project Manager - NRR/DORL/LPL 3 Dresden Nuclear Power Station, Units 2 and 3

+ Russell.Haskell@nrc.gov; ( (301) 415-1129 (forwarded); Office: O-8C01; Mail-Stop O-8B1A