ML21228A235

Notification of NRC Baseline Inspection and Request for Information Inspection Report 05000457/2021004

ML21228A235
Person / Time
Site:	Braidwood
Issue date:	08/17/2021
From:	John Bozga NRC/RGN-III/DRS/EB1
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
References
IR 2021004
Download: ML21228A235 (9)

See also: IR 05000457/2021004

Text

August 17, 2021

Mr. David Rhoades

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: BRAIDWOOD GENERATING STATION, UNIT 2NOTIFICATION OF NRC

BASELINE INSPECTION AND REQUEST FOR INFORMATION; INSPECTION

REPORT 05000457/2021004

Dear Mr. Rhoades:

On October 18, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin the Baseline

Inservice Inspection Procedure 71111.08. This onsite inspection is scheduled to be performed

October 18, 2021, through October 28, 2021.

Experience has shown that this inspection is resource intensive both for the NRC inspector and

your staff. In order to minimize the impact to your onsite resources, and to ensure a productive

inspection for both sides, we have enclosed a request for documents needed for this inspection.

These documents have been divided into two groups.

The first group identifies information necessary to ensure that the inspector is adequately

prepared. The second group identifies the information the inspector will need upon arrival at the

site. It is important that all of these documents are up-to-date, and complete, in order to

minimize the number of additional documents requested during the preparation and/or the

onsite portions of the inspection.

We have discussed the schedule for inspection activities with your staff and understand that

our regulatory contact for this inspection will be Mr. R. Schliessmann of your organization. If

there are any questions about this inspection or the material requested, please contact the

lead inspector John V. Bozga at 630-829-9613.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget Control

Number.

D. Rhoades -2-

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,

Exemptions, Requests for Withholding.

Sincerely,

Signed by Bozga, John

on 08/17/21

John V. Bozga, Senior Reactor Inspector

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-457

License No. NPF-77

Enclosure:

Document Request for Inservice

Inspection

cc: Distribution via LISTSERV

D. Rhoades -3-

Letter to David Rhoades from John V. Bozga dated August 17, 2021.

SUBJECT: BRAIDWOOD GENERATING STATION, UNIT 2NOTIFICATION OF NRC

BASELINE INSPECTION AND REQUEST FOR INFORMATION; INSPECTION

REPORT 05000457/2021004

DISTRIBUTION:

Jessie Quichocho

Aaron McCraw

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John Giessner

Mohammed Shuaibi

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML21228A235

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME JBozga:mb

DATE 08/17/2021

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR INSERVICE INSPECTION

Inspection Dates: October 18, 2021 - October 28, 2021

Inspection Procedures: Inspection Procedure 71111-08, Inservice Inspection

Lead Inspector: John V Bozga, DRS

630-829-9613

A. Information for the In-Office Preparation Week

The following information (electronic copy) is requested by October 4, 2021, to facilitate

the selection of specific items that will be reviewed during the onsite inspection week.

The inspector will select specific items from the information requested below and request

a list of additional documents needed onsite to your staff. We request that the specific

items selected from the lists be available and ready for review on the first day of

inspection. The following information is applicable to the outage Unit unless otherwise

indicated. If you have any questions regarding this information, please call the inspector

as soon as possible.

1. For the upcoming outage, a detailed schedule and description of:

a. Non-Destructive Examinations (NDEs) planned for Class 1 and 2 Systems and

containment, performed as part of your American Society of Mechanical

Engineers (ASME) Code Inservice Inspection (ISI) Program (include edition and

addenda of Code committed to), and NDEs planned for other systems performed

as part of a Risk-Informed ISI Program, or other augmented inspection programs

(e.g., ASME Code Case N-770 examination of dissimilar metal welds and

examinations to meet an industry initiative);

b. Reactor vessel upper head examinations required by Title 10 of the Code of

Federal Regulations (CFR), Part 50.55a(g)(6)(ii)(D) and Code Case N-729;

c. Steam generator (SG) tube inspection and repair activities for the upcoming

outage or SG secondary side examinations1; and

d. Welding on Code Class 1, 2, or 3 components. For each weld examination,

include the weld identification number, description of weld (component name),

category, class, type of exam and procedure number, and date of examination.

2. A copy of the NDE procedures, SG eddy current examination (ET) acquisition and

analysis procedures, and welding procedures used to perform the activities identified

in Item A.1 (including NDE calibration and flaw characterization/sizing procedures

and Welding Procedure Qualification Records). For ultrasonic examination

1 Note 1 - If no SG examinations are planned for this outage, please confirm when the next SG examination will

occur and no further information is required for the items identified above requesting SG related information.

Enclosure

DOCUMENT REQUEST FOR INSERVICE INSPECTION

procedures qualified in accordance with Appendix VIII, of Section XI of the ASME

Code, provide documentation supporting the procedure qualification (e.g., the

Electric Power Research Institute performance demonstration qualification summary

sheets). For SG tube ET this includes the acquisition and analysis procedures.

3. A copy of ASME Section XI, Code Relief Requests applicable to the examinations

identified in Item A.1.

4. A copy of the 10-year ISI Program showing those required exams scheduled to be

performed this outage, and those which have been completed.

5. A list identifying NDE reports (ultrasonic, radiography, magnetic particle, or dye

penetrant), which have identified relevant indications on Code Class 1 and 2

Systems since the beginning of the last refueling outage.

6. List of repair/replacement welds in Code Class 1, 2 and 3 Systems, which have been

fabricated since the beginning of the last refueling outage and identify the system,

weld number, and reference applicable documentation (e.g., NIS-2 forms with

definitions of system and component acronyms).

7. List of reactor vessel weld examinations required by the ASME Code that are

scheduled to occur during the upcoming refueling outage, and please provide a

detailed description of the welds and the extent of the planned examination.

8. Corrective action list of ISI and SG-related issues such as piping or SG tube

degradation or damage (e.g., cracks, wall thinning, wear, microbiologically induced

corrosion) or errors identified during piping/SG tube examinations since the

beginning of the last refueling outage. Also, include a list of corrective actions

associated with foreign material in the reactor vessel, primary coolant system, SG or

feed systems since the beginning of the last refueling outage.

9. 10 CFR Part 21 reports applicable to your structures, systems, or components within

the scope of ASME Code Section XI that have been identified since the beginning of

the last refueling outage.

10. Copy of SG history documentation given to vendors performing ET of the SGs during

the upcoming outage1.

11. Copy of procedure containing screening criteria used for selecting tubes for in-situ

pressure testing and the procedure to be used for in-situ pressure testing1.

12. Copy of previous outage SG tube operational assessment completed following ET of

the SGs (provide this document even if no SG ET is planned for current outage).

13. Copy of most recent SG Degradation Assessment (provide this document even if no

SG ET is planned for current outage).

14. Copy of most recent SG Condition Monitoring Assessments1.

1 Note 1 - If no SG examinations are planned for this outage, please confirm when the next SG examination will

occur and no further information is required for the items identified above requesting SG-related information.

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DOCUMENT REQUEST FOR INSERVICE INSPECTION

15. Copy of the document defining the planned SG ET scope (e.g., 100 percent of

unrepaired tubes with bobbin probe and 20 percent sample of hot leg expansion

transition regions with rotating probe) and identify the scope expansion criteria,

which will be applied. Also identify and describe any deviations in this scope or

expansion criteria from the Electric Power Research Institute Guidelines1.

16. Copy of the document describing the ET acquisition equipment to be applied

including ET probe types. Also identify the extent of planned tube examination

coverage with each probe type (e.g., rotating probe - 0.080 inches, 0.115 inches

pancake coils and mid-range + point coil applied at the top-of-tube-sheet plus

3 inches to minus 12 inches)1.

17. Provide procedures with guidance/instructions for identifying (e.g., physically locating

the tubes that require repair) and plugging SG tubes1.

18. Identify and quantify any SG tube leakage experienced during the previous operating

cycle. Also provide documentation identifying which SG was leaking and corrective

actions completed or planned for this condition.

19. Point of contact information (name and site number) for the following activities:

a. ISISite and vendor leads;

b. Boric Acid Inspections and Evaluations;

c. Reactor Vessel Head InspectionSite and vendor leads;

d. SG InspectionSite and vendor leads;

e. Aging Management Programs; and

f. Site Welding Engineer.

B. Onsite Information to Be Provided to the Inspector on the First Day of the

Inspection (e.g., Following the Entrance Meeting). Please Provide Hard Copies

(e.g., Paper Records) of the Following Documents.

1. For welds selected by the inspector from Item A.1.d and A.6 above, provide copies of

the following documents:

a. Document of the weld number and location (e.g., system, train, branch);

b. Document with a detail of the weld construction (e.g., drawing);

c. Applicable portions of the Design Specification and applicable Code of

construction for the weldment (e.g., B31.1 or ASME Section III);

d. Applicable Code Edition and Addenda for weld procedure qualification;

1 Note 1 - If no SG examinations are planned for this outage, please confirm when the next SG examination will

occur and no further information is required for the items identified above requesting SG related information.

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DOCUMENT REQUEST FOR INSERVICE INSPECTION

e. Applicable weld procedure specifications and weld data sheets used to fabricate

the welds;

f. Copies of procedure qualification records supporting the weld procedure

specifications;

g. Copies of welders performance qualification records;

h. Copies of mechanical test reports identified in the weld procedure qualification

records above;

i. Copies of the nonconformance reports for the selected welds;

j. Access to radiographs and equipment to view radiographs of the selected welds;

k. ASME Code Section XI repair replacement plan and reconciliation for

replacement components/materials;

l. Certified Material Test Reports for replacement pressure boundary materials; and

m. Copies of the NDE required by the construction Code and the pre-service

examination records required by the ASME Code Section XI for the selected

welds.

2. For the ISI-related corrective action issues selected by the inspector from Item A.8

above, provide a copy of the corrective actions and supporting documentation.

3. For the NDE reports with relevant indications on Code Class 1 and 2 Systems

selected by the inspector from Item A.5 above, provide a copy of the examination

records and associated corrective action documents.

4. Updated schedules for Item A.1 (including schedule showing contingency repair

plans if available).

5. Fabrication Drawings (D size) of the reactor vessel welds (including vessel head

J-groove welds) if any are to be examined during the outage. Also provide any

drawings used by NDE vendors to locate these welds.

6. Copy of the procedures which govern the scope, equipment used, and

implementation of the inspections required to identify boric acid leakage fromsystems

and components above the vessel head.

7. Copy of:

a. Engineering evaluations/assessments of boric acid related deposits and

associated wastage or corrosion for safety-related components; and

b. Corrective action records for coolant leakage including boric acid deposits on

safety-related components identified since the beginning of the last refueling

outage.

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DOCUMENT REQUEST FOR INSERVICE INSPECTION

8. Copy of the plant procedures used to perform inspections to identify reactor coolant

system leaks or boric acid deposits and the procedures for resolution of leaks or

boric acid deposits.

9. Copy of the documents which demonstrate that the procedures to be used for

volumetric examination of the reactor vessel head penetration J-groove welds were

qualified by a blind demonstration test in accordance with 10 CFR

Part 50.55a(g)(6)(ii)(D).

10. Copy of volumetric, surface and visual examination records for the prior inspection of

the reactor vessel head and head penetration J-groove welds.

11. Provide a copy of the Electric Power Research Institute Examination Technique

Specification Sheets and vendor related documents, which support qualification of

the ET probes to be used during the upcoming SG tube inspections1.

12. Provide a copy of the guidance to be followed if a loose part or foreign material is

identified in the SGs1.

13. Identify the types of SG tube repair processes which will be implemented for

defective SG tubes (including any U.S. Nuclear Regulatory Commission

reviews/evaluation/approval of this repair process). Provide the flaw depth sizing

criteria to be applied for ET indications identified in the SG tubes1.

14. Copy of document describing actions to be taken if a new SG tube degradation

mechanism is identified1.

15. Provide document which defines the scope of SG secondary side examinations (if

any are planned) and identify site specific operational history related to degradation

of SG secondary side components (if any).

16. Provide procedures with guidance/instructions for identifying (e.g., physically locating

the tubes that require repair) and plugging SG tubes1.

17. Provide copies of the following standards at the onsite U.S. Nuclear Regulatory

Commission inspection location for the duration of the inspection:

a. Sections V, IX, and XI of the ASME Code with Editions applicable to the

ISIProgram and the Repair/Replacement Program;

b. Copy of the performance demonstration initiative (PDI) generic procedures with

the latest applicable revisions that support site qualified ultrasonic examination of

piping welds and components (e.g., PDI-UT-1, PDI-UT-2, PDI-UT-3, PDI-UT-10

etc.);

c. Electric Power Research Institute and industry standards referenced in the site

procedures used to perform the SG tube ET, which includes Electric Power

Research Institute documents: SG Examination Guidelines, SG Integrity

1 Note 1 - If no SG examinations are planned for this outage, please confirm when the next SG examination will

occur and no further information is required for the items identified above requesting SG related information.

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DOCUMENT REQUEST FOR INSERVICE INSPECTION

Assessment Guidelines, SG In-Situ Pressure Test Guidelines1; and

d. Boric Acid Corrosion Guidebook Revision 1Electric Power Research Institute

Technical Report 1000975.

If you have questions regarding the information requested, please contact the lead inspector.

1 Note 1 - If no SG examinations are planned for this outage, please confirm when the next SG examination will

occur and no further information is required for the items identified above requesting SG related information.

6