RS-21-061, Supplemental Information Concerning Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure.

Supplemental Information Concerning Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure.

ML21138A839
Person / Time
Site:	Dresden, Quad Cities
Issue date:	05/18/2021
From:	David Gudger Exelon Generation Co
To:	Document Control Desk
References
RS-21-061
Download: ML21138A839 (7)

Text

10 CFR 50.55a RS-21-061 May 18, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Supplemental Information Concerning Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting

1) Letter from D. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting," dated December 1, 2020 (ML20336A008)

2) Email from B. Purnell (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), "Exelon Generation Company, LLC -

Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting," dated March 1, 2021 (ML21062A065)

3) Letter from D. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information

- Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting," dated April 20, 2021 (ML21110A092)

In the Reference 1 letter, in accordance with 10 CFR 50.55a(z)(1), Exelon Generation Company, LLC (Exelon) requested a proposed alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," on the basis that the alternative provides an acceptable level of quality and safety. This proposed alternative concerns completion of Form NIS-2, "Owners Repair/Replacement Certification Record" (2017

Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation May 18, 2021 Page 2 Edition) or the NRC approved alternative Form NIS-2A, "Repair/Replacement Certification Record," contained in Code Case N-532-5. Specifically, Exelon proposes to forego preparation and completion of a Repair/Replacement Plan and Form NIS-2 (or NIS-2A) for pressure retaining bolting that is not classified as Examination Category B-G-1, B-G-2, or C-D.

In the Reference 3 letter, Exelon provided a response to the Staffs request for additional information contained in Reference 2. In the Reference 3 letter, Exelon requested that the relief request apply to Dresden Nuclear Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2 for the next Inservice Inspection Interval which will be in accordance with the 2017 Edition of the ASME Code,Section XI. This letter supplements the Reference 3 letter by updating the relief request to contain references to the 2017 Edition. To aid in review of the relief request, the attached copy contains revision bars.

Exelon requests your review and approval of this request by January 20, 2022.

If you have any questions, please contact Tom Loomis at (610) 765-5510.

Respectfully, David T. Gudger Senior Manager - Licensing Exelon Generation Company, LLC

Attachment:

Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting cc: Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

Attachment Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting

10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 1 of 4)

Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting in Accordance with 10 CFR 50.55a(z)(1)

- Alternative Provides Acceptable Level of Quality and Safety -

1. ASME Code Component(s) Affected:

All ASME pressure retaining bolting that is not classified as Examination Category B-G-1 (Class 1 pressure retaining bolting, greater than 2 in. in diameter), B-G-2 (Class 1 pressure retaining bolting, 2 in. and less in diameter), or C-D (Class 2 pressure retaining bolting greater than 2 in. in diameter).

2. Applicable Code Edition and Addenda

PLANT INTERVAL EDITION START END Dresden Nuclear Power Sixth 2017 Edition January 20, 2023 January 19, 2033 Station, Units 2 and 3 Quad Cities Nuclear Sixth 2017 Edition April 2, 2023 April 1, 2033 Power Station, Units 1 and 2

3. Applicable Code Requirements

IWA-4141 [2017 Edition] requires the Owner to provide or cause to be provided a Repair Replacement Program, a Repair Replacement Plan, and specification requirements for repair/replacement activities.

IWA-4142 [2017 Edition] requires the organization that performs repair/replacement activities shall establish a Quality Assurance Program for control of their activities in accordance with the Repair/Replacement Program and Plans.

IWA-4150(c) [2017 Edition] requires that a Repair/Replacement Plan be prepared in accordance with the Repair/Replacement Program whenever a repair/replacement activity is to be performed.

IWA-4511 [2017 Edition] requires that personnel performing nondestructive examination required by the Construction Code shall be qualified and certified in accordance with the Construction Code identified in the Repair/Replacement Plan.

IWA-6211(d) [2017 Edition] requires the Owner to prepare the Owners Repair/Replacement Certification Record, Form NIS-2 (Form NIS-2) upon completion of all required activities associated with the Repair/Replacement Plan to place the item in service.

IWA-6220 [2017 Edition] provides the requirements for tracking and approval of Repair/Replacement plans and Form NIS-2.

10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 2 of 4)

IWA-6350 [2017 Edition] requires that Repair/Replacement Plans and Form NIS-2 be retained.

Code Case N-532-5, "Repair/Replacement Activity Documentation Requirements and Inservice Inspection Summary Report Preparation and Submission,Section XI, Division 1,"

(unconditionally approved for use under Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," Revision 19) provides alternatives to the ASME Section XI requirements stated above and substitutes the Form NIS-2 with Form NIS-2A.

4. Reason for Request

In accordance with 10 CFR 50.55a(z)(1), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.

Exelon Generation Company, LLC (Exelon) is requesting relief from the current ASME Section XI requirements to initiate a Repair/Replacement Plan and complete a Form NIS-2 (or NIS-2A) for certain routine pressure retaining bolting replacement activities. Compliance with this ASME Code administrative requirement results in expending personnel resources that are better used on more safety significant activities. Eliminating this administrative burden will also streamline the planning and post maintenance review processes by involving fewer plant organizations (Engineering, Planning, Work Control, Maintenance, etc.) in the overall required maintenance activities. This proposed relief request is strictly limited to the administrative requirements of ASME Section XI and does not eliminate any ASME Section XI or Construction Code technical requirements associated with bolting materials or installation and maintenance requirements.

Based on the above discussion, reasonable assurance is still achieved by performing the remaining technical requirements when bolting is replaced.

5. Proposed Alternative and Basis for Use

This relief request proposes to forego preparation and completion of a Repair/Replacement Plan and associated Form NIS-2 (or NIS-2A) for replacement of pressure retaining bolting that is not classified as Examination Category B-G-1, B-G-2, or C-D. This relief request will not be applied to activities that involve replacement of bolting that has experienced unacceptable service-induced degradation or when involving a design change. Bolting replacement during normal maintenance work activities due to damage or loss will apply this relief request unless involving Examination Category B-G-1, B-G-2, or C-D components. Unacceptable service-induced degradation that cannot apply this relief request is defined as follows:

• Fractures and crack like flaws not caused by maintenance activities.

• More than one deformed or sheared thread in the zone of thread engagement that is due to a service-induced condition. Threads can often get deformed or sheared during the removal process and may not be considered service-induced degradation.

• Corrosion (e.g., boric acid, raw water) that reduces the bolt cross sectional area by more than 5%.

• Bending, twisting, or deformation of bolts determined to be from a service-induced condition.

• Degradation of protective coatings on bolting surfaces.

10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 3 of 4)

Quality Assurance Program and system/component specification requirements remain in place during application of this relief request; therefore, these technical requirements remain unchanged. The specific requirements will not be documented in a Repair/Replacement Plan but are currently implemented through the normal planning, procurement, and maintenance processes.

IWA-4150 Repair/Replacement Program and Plan administrative requirements applicable to this relief request are addressed as follows:

1. The Section XI Repair/Replacement Program remains applicable with editions and addenda(s) defined through application of the Repair/Replacement Program and ISI Plan and are therefore defined. NRC enforcement of Section XI and Construction Code requirements remain applicable because this relief request maintains Code requirements other than a documented Repair/Replacement Plan and NIS-2 (or NIS-2A).

2. The applicable Construction Code Edition, Addenda, Cases, and Owners Requirements are included in plant records that may be retrieved when appropriate.

Routine replacement of bolting is achieved through review of current component and procurement records with replacement material being of equal or more stringent requirements (e.g., replacing a Class 3 stud with a Class 1 stud).

3. This relief request will not be used for locations that have experienced unacceptable service-induced degradation or for a replacement involving a design change; therefore, there are no NDE detection methods, defect removal methods, welding requirements, acceptance NDE requirements, description of activity, life of component, or code stamping requirements involved.

4. Documentation of the work activity and replacement bolting is achieved through the normal processes of procurement, planning, and maintenance. Close-out reviews are completed through the normal post-work review process to assure appropriate documentation of work performed and traceability is satisfied. Authorized Inspection Agency Review will remain in place but will not be documented on the Form NIS-2 (or NIS-2A).

5. Availability of records for regulatory review of the Repair/Replacement Program and associated repair/replacement evaluations remain in place and available for review.

There will be no Repair/Replacement Plan, but the associated work order and procurement documentation will be available for review by the Authorized Inspection Agency and regulatory authority when requested.

Replacement bolting will receive Construction Code and Owners Requirements NDE as part of the normal procurement and receipt inspection processes which identify applicable Construction Code and Owners Requirements. The Construction Code and Owners Requirements for NDE will be documented in the procurement and receipt records.

The current Form NIS-2 (or NIS-2A) provides documented evidence of compliance with Section XI for repair/replacement activities by obtaining Owner and Authorized Inspection Agency signatures. The proposed alternative would use current work control, procurement, and records retention processes to assure that the Authorized Inspection Agency has access to records of

10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 4 of 4) bolting replacement in order to maintain Code oversight; however, there will be no Repair/Replacement Plan or Form NIS-2 (or NIS-2A) presented to the agency in order to complete the Form approval. Owner and Authorized Inspection Agency reviews of completed work orders applying this relief request will be documented in records associated with the work management process (e.g., hard copy signature in work order documentation and electronic work order review records (commonly referred to as "Post Work Review")).

As stated above, a replacement bolting Repair/Replacement Plan and associated Form NIS-2 (or NIS-2A) will not be completed for bolting replacement activities described above; therefore, these documents cannot be submitted as plant records. The procurement and work activity records will document technical requirements and work activities to allow subsequent review for adequacy and traceability, thereby meeting the intent of Code requirements and maintaining an acceptable level of quality and safety.

6. Duration of Proposed Alternative

The proposed alternative to forego preparation and completion of a Repair/Replacement Plan and associated Form NIS-2 (or NIS-2A) will be applicable as specified in Section 2 above or until such time as the NRC approves a similar administrative requirement relaxation in an NRC-approved applicable Code Edition in 10 CFR 50.55a or a Code Case in Regulatory Guide 1.147.

7. Precedent:

None