Text

Proposed Alternative to Utilize Code Case N-893
	ML21182A100
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Byron, Braidwood, Limerick, Clinton, LaSalle
Issue date:	06/30/2021
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21182A099	List: ML21182A100; NMP2L2773, Company - Response to Request for Additional Information; RS-21-070, Proposed Alternative to Utilize Code Case N-893;
References
	NMP2L2773, RS-21-070
	Download: ML21182A100 (6)
	v • d • e

CONFIDENTIAL INFORMATION - WITHHOLD UNDER 10 CFR 2.390 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-21-070 NMP2L2773 June 30, 2021 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410

Subject:

Proposed Alternative to Utilize Code Case N-893

References:

1) Letter from D. Gudger (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, Proposed Alternative to Utilize Code Case N-893, dated November 16, 2020 (ML20321A234)

Attachments 4 and 5 transmitted herewith contains Confidential Information. When separated from attachments, this document is decontrolled.

CONFIDENTIAL INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Proposed Alternative to Utilize Code Case N-893 June 30, 2021 Page 2

2) Letter from B. Purnell (U.S. Nuclear Regulatory Commission) to D.

Rhoades (Exelon Generation Company, LLC), 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 - Request for Additional Information Regarding Proposed Alternative to Use ASME Code Case N-893 (EPIDS L-2020-LLR-0147 and L-2020-LLR-0148), dated May 5, 2021 (ML21117A034)

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 proposed alternative provides an acceptable level of quality and safety, equivalent to compliance with ASME Section III and XI requirements. Specifically, this proposed alternative concerns the use of Code Case N-893, Use of Alloy Steel Bar and Mechanical Tubing in Class 2 and 3 Patented Mechanical Joints and Fittings,Section III, Division 1. This Code Case allows the use of a material that does not comply with the limitations on material specifications and grades mandated by ASME Section Ill.

In the Reference 2 letter, the U.S. Nuclear Regulatory Commission requested additional information. Attached is our response.

Attachments 4 and 5 contain information proprietary to Lokring Technology, LLC (Lokring).

Lokring requests that these documents be withheld from public disclosure in accordance with 10 CFR 2.390(b)(4). An Affidavit supporting this request is contained in Attachment 3.

There are no regulatory commitments contained in this letter.

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

Respectfully, David T. Gudger - Senior Manager Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Response to Request for Additional Information (Non-Confidential Information)

2) Executive Summary - Crevice Corrosion Test of Lokring LTSC-333 and Socket weld Fittings (Non-Confidential Information)

3) Affidavit

4) Exhibit A - Response to Request for Additional Information (Confidential Information)

5) Exhibit B - Executive Summary - Crevice Corrosion Test of Lokring LTSC-333 and Socket weld Fittings (Confidential Information)

Attachments 4 and 5 transmitted herewith contains Confidential Information. When separated from attachments, this document is decontrolled.

CONFIDENTIAL INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Proposed Alternative to Utilize Code Case N-893 June 30, 2021 Page 3 cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC NRC Project Manager - Nine Mile Point Nuclear Station Illinois Emergency Management Agency - Division of Nuclear Safety W. DeHaas, Commonwealth of Pennsylvania S. Seaman, State of Maryland A. L. Peterson, NYSERDA Attachments 4 and 5 transmitted herewith contains Confidential Information. When separated from attachments, this document is decontrolled.

Affidavit

ATIACHMENT 3 AFFIDAVIT I, William H. Lennon, the sole member and President of Lokring Technology, LLC do hereby affirm and state:

1. I am the sole member and President of lokring Technology, LLC, and I am authorized to execute this Affidavit on behalf of Lokring Technology, LLC. I am further authorized to review information submitted to the Nuclear Regulatory Commission (NRC) and apply for the withholding of information from disclosure.

2. Lokring Technology, LLC is providing information pursuant to 10 CFR 50.SSa, of and concerning its proprietary LTCS-333 product. The information being provided constitutes proprietary trade secret information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390(a)(4), because:

i. The contents of Attachment 4 (Response to Request for Additional Information) and in Attachment 5 (Executive Summary- Crevice Corrosion Test of Lokring LTSC-333 and Socket Weld Fittings) each contain 11 information ( lnformation") that is and has been held in confidence by Lokring Technology, LLC. The referenced Attachment 4 and Attachment 5 are attached hereto as Exhibits A and~, respectively;

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ii. This Information is of a type that is held in confidence by Lokring Technology, LLC and there is a rational basis for doing so because the Information contains sensitive trade secret information concerning Lokring Technology, LLC's product design and testing details; iii. This Information is being transmitted to the NRC in confidence; iv. This Information is not available in public sources and could not be gathered readily from other publicly available information; and

v. Public disclosure of this Information would create substantial harm to the competitive position of Lokring Technology, LLC by disclosing Lokring Technology, LLC's product design and testing details to other parties whose commercial interests may be adverse to those of Lokring Technology, LLC.

3. Accordingly, Lokring Technology, LLC requests that the designated documents be withheld from public disclosure pursuant to the policy reflected in 10 CFR 2.390(a)(4)

and that prompt written notice be provided to Lokring Technology, LLC of any request for disclosure of LokringTechnology, LLC's trade secret or confidential information, as well as the maximum amount of time available under the applicable statute to object in writing to any disclosure of such Information.

Lokring Technology, LLC

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William H. Lennon, sole member and President of Lokring Technology, LLC STATE OF OHIO SS .

COUNTY OF LAKE Before me, a Notary Public, in and for said County and State, personally appeared Mr.

William H. Lennon, the sole member and President of Lokring Technology, LLC, who acknowledged that he did execute the foregoing Affidavit in his capacity as the duly authorized officer of Lokring Technology, LLC, and such execution is his free act and deed .

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