View source for RS-21-056, Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Weld

{{Adams
| number = ML21133A297
| issue date = 05/12/2021
| title = Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Weld
| author name = Gudger D
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000456, 05000457, 05000454, 05000455, 05000317, 05000318
| license number = DPR-053, DPR-069, NPF-037, NPF-066, NPF-072, NPF-077
| contact person = 
| case reference number = RS-21-056
| document type = Letter type:RS, Report, Technical
| page count = 71
}}

=Text=
{{#Wiki_filter:200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-21-056 May 12, 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

==Subject:==
Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds In accordance with 10 CFR 50.55a(z)(1), Exelon Generation Company, LLC (Exelon) hereby requests NRC approval of a proposed alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," on the basis that the proposed alternative provides an acceptable level of quality and safety. Specifically, Exelon is requesting an alternative to volumetric examination of pressurizer circumferential and longitudinal shell-to-head welds and nozzle-to-shell welds to extend the inspection frequency from 10 years to the remainder of the currently licensed operating periods for Braidwood Generating Station (Braidwood), Units 1 and 2, Byron Generating Station (Byron), Units 1 and 2, and Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), Units 1 and 2.
Proposed Alternative I4R-15 for Braidwood, I4R-21 for Byron, and ISI-05-016 for Calvert Cliffs is provided in Attachment 1. Exelon requests approval of the proposed alternative by March 1, 2022 to support the Spring 2022 outage season when some of the subject examinations are currently scheduled.
There are no regulatory commitments contained in this letter.

Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds May 12, 2021 Page 2 Should you have any questions concerning this matter, please contact Tom Loomis (610) 765-5510.
Respectfully, David T. Gudger Senior Manager - Licensing Exelon Generation Company, LLC : 10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 cc:    Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant Illinois Emergency Management Agency - Division of Nuclear Safety S. Seaman, State of Maryland

Attachment 1 10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 1 of 68)
Proposed Alternative for Examination of Pressurizer Shell-to-Head and Nozzle-to-Shell Welds (Examination Categories B-B and B-D)
In Accordance with 10 CFR 50.55a(z)(1) 1    ASME Code Component(s) Affected Code Class:              Class 1

== Description:==
Pressurizer Shell-to-Head and Nozzle-to-Vessel Welds Examination Categories:  Category B-B, Pressure-Retaining Welds in Vessels Other Than Reactor Vessels Category B-D, Full Penetration Welded Nozzles in Vessels Item Numbers:            B2.11 - Pressurizer, Shell-to-Head Welds, Circumferential B2.12 - Pressurizer, Shell-to-Head Welds, Longitudinal B3.110 - Pressurizer, Nozzle-to-Vessel Welds Braidwood Component IDs:
ASME       ASME Unit                           Component ID             Component Description Category     Item 1      B-B      B2.11         1PZR-01-08A                Shell - Lower Head 1      B-B      B2.11         1PZR-01-08E                Shell - Upper Head 2      B-B      B2.11         2PZR-01-08A                Shell - Lower Head 2      B-B      B2.11         2PZR-01-08E                Shell - Upper Head 1      B-B      B2.12         1PZR-01-09A               Shell Longitudinal Weld 1      B-B      B2.12         1PZR-01-09D               Shell Longitudinal Weld 2      B-B      B2.12         2PZR-01-09A               Shell Longitudinal Weld 2      B-B      B2.12         2PZR-01-09D               Shell Longitudinal Weld 1      B-D      B3.110         1PZR-01-N1                    Surge Nozzle 1      B-D      B3.110         1PZR-01-N2                    Spray Nozzle 1      B-D      B3.110         1PZR-01-N3                    Relief Nozzle 1      B-D      B3.110        1PZR-01-N4A                    Safety Nozzle 1      B-D      B3.110        1PZR-01-N4B                    Safety Nozzle 1      B-D      B3.110        1PZR-01-N4C                    Safety Nozzle 2      B-D      B3.110         2PZR-01-N1                    Surge Nozzle 2      B-D      B3.110         2PZR-01-N2                    Spray Nozzle 2      B-D      B3.110         2PZR-01-N3                    Relief Nozzle 2      B-D      B3.110        2PZR-01-N4A                    Safety Nozzle 2      B-D      B3.110        2PZR-01-N4B                    Safety Nozzle 2      B-D      B3.110        2PZR-01-N4C                    Safety Nozzle

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 2 of 68)
Byron Component IDs:
ASME      ASME Unit                           Component ID             Component Description Category    Item 1     B-B      B2.11          1RY-01-S/PC-01              Shell - Bottom Head 1     B-B      B2.11          1RY-01-S/PC-05              Shell - Upper Head 2     B-B      B2.11          2RY-01-S/PC-01              Shell - Bottom Head 2     B-B      B2.11          2RY-01-S/PC-05              Shell - Upper Head 1     B-B      B2.12          1RY-01-S/PL-01            Lower Longitudinal Weld 1     B-B      B2.12          1RY-01-S/PL-04            Upper Longitudinal Weld 2     B-B      B2.12          2RY-01-S/PL-01            Lower Longitudinal Weld 2     B-B      B2.12          2RY-01-S/PL-04            Upper Longitudinal Weld 1     B-D      B3.110         1RY-01-S/PN-01                 Surge Nozzle 1     B-D      B3.110         1RY-01-S/PN-02                 Spray Nozzle 1     B-D      B3.110         1RY-01-S/PN-03                 Relief Nozzle 1     B-D      B3.110         1RY-01-S/PN-04                Safety Nozzle 1     B-D      B3.110         1RY-01-S/PN-05                Safety Nozzle 1     B-D      B3.110         1RY-01-S/PN-06                Safety Nozzle 2     B-D      B3.110         2RY-01-S/PN-01                 Surge Nozzle 2     B-D      B3.110         2RY-01-S/PN-02                 Spray Nozzle 2     B-D      B3.110         2RY-01-S/PN-03                 Relief Nozzle 2     B-D      B3.110         2RY-01-S/PN-04                Safety Nozzle 2     B-D      B3.110         2RY-01-S/PN-05                Safety Nozzle 2     B-D      B3.110         2RY-01-S/PN-06                Safety Nozzle

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 3 of 68)
Calvert Cliffs Component IDs:
ASME         ASME Unit                                     Component ID                   Component Description Category         Item 1         B-B         B2.11                   3-401                        Shell - Lower Head 1         B-B         B2.11                   8-411                        Shell - Upper Head 2         B-B         B2.11                   3-401                        Shell - Lower Head 2         B-B         B2.11                   8-411                        Shell - Upper Head 1         B-B         B2.12                  2-401A                     Upper Shell At 270 Deg.
1         B-B         B2.12                  2-401B                      Upper Shell At 90 Deg.
1         B-B         B2.12                 2-401C                      Lower Shell At 180 Deg.
1         B-B         B2.12                 2-401D                        Lower Shell At 0 Deg.
2         B-B         B2.12                  2-401A                     Upper Shell At 270 Deg.
2         B-B         B2.12                  2-401B                      Upper Shell At 90 Deg.
2         B-B         B2.12                 2-401C                      Lower Shell At 180 Deg.
2         B-B         B2.12                 2-401D                        Lower Shell At 0 Deg.
1         B-D        B3.110                   4-404                           Surge Nozzle 1         B-D        B3.110                   4-405                           Spray Nozzle 1         B-D        B3.110                 16-405A                       Safety & Relief Nozzle 1         B-D        B3.110                 16-405B                       Safety & Relief Nozzle 2         B-D        B3.110                   4-404                           Surge Nozzle 2         B-D        B3.110                   4-405                           Spray Nozzle 2         B-D        B3.110                 16-405A                       Safety & Relief Nozzle 2         B-D        B3.110                 16-405B                       Safety & Relief Nozzle 2     Applicable Code Edition and Addenda The following table identifies the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel (B&PV) Section XI Code of Record for performing Inservice Inspection (ISI) activities at Braidwood, Byron, and Calvert Cliffs:
PLANT          INTERVAL          EDITION                     START                         END Braidwood Station,                                          August 29, 2018 (Unit 1)     July 28, 2028 (Unit 1)
Fourth         2013 Edition Units 1 and 2                                           November 5, 2018 (Unit 2) October 16, 2028 (Unit 2)
Byron Station,                  2007 Edition, through Fourth                                  July 16, 2016                July 15, 2025 Units 1 and 2                      2008 Addenda Calvert Cliffs Nuclear Power          Fifth         2013 Edition              July 1, 2019                June 30, 2029 Plant, Units 1 and 2 The 2019 Edition of ASME Section XI, Table G-2110-1 will be utilized to extend the use of Figure G-2110-1, Reference Critical Stress Intensity Factor for Material, to material SA-533 Grade A, Class 2. (Note: The 2019 Edition of ASME Section XI is published in the proposed rules of the Federal Register, Vol. 86, No. 57. Currently there are conditions in the proposed NRC Rulemaking (86 FR 16087) regarding Table G-2110-1, but these conditions do not pertain to the use of Table G-2110-1 for material SA-533 Grade A, Class 2 as used in this proposed alternative).

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 4 of 68) 3   Applicable Code Requirement ASME Code, Section XI, IWB-2500(a), Table IWB-2500-1, Examination Category B-B, requires examination of the applicable Item Numbers as follows:
Item No. B2.11 - Volumetric examination of both Circumferential Shell-to-Head welds during each inspection interval. The examination volume is shown in Figure IWB-2500-1.
Item No. B2.12 - Volumetric examination of one foot of one Longitudinal Shell-to-Head weld intersecting the circumferential weld per head each inspection interval. The examination volume is shown in Figure IWB-2500-2.
ASME Code, Section XI, IWB-2500(a), Table IWB-2500-1, Examination Category B-D, requires examination of the applicable Item Number as follows:
Item No. B3.110 - Volumetric examination of all Full Penetration Nozzle-to-Vessel welds during each inspection interval. The examination volume is shown in Figures IWB-2500-7(a), (b), (c), and (d).
4   Reason for Request The Electric Power Research Institute (EPRI) performed assessments in Reference
[1] of the basis for the ASME Section XI examination requirements specified for the above-listed ASME Code, Section XI, Division 1 (ASME Section XI) Examination Categories and Item Numbers for pressurizer welds. The assessments include a survey of inspection results from 74 units as well as flaw tolerance evaluations using probabilistic fracture mechanics (PFM) and deterministic fracture mechanics (DFM). The Reference [1] report results indicate that the current ASME Section XI inspection interval of ten years for these welds can be increased with no impact to plant safety. It is upon the basis of those results that an alternate inspection interval is requested.
5   Proposed Alternative and Basis for Use Exelon requests an inspection alternative to the examination requirements of ASME Section XI, Table IWB-2500-1, for Examination Categories B-B and B-D, Item Numbers B2.11, B2.12, and B3.110. The proposed alternative is to defer inspection of these Item Numbers from the current ASME Section XI 10-year requirement to the end of the currently approved Period of Extended Operation (PEO) for Braidwood Station (Braidwood), Units 1 and 2, Byron Station (Byron), Units 1 and 2, and Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), Units 1 and 2, as summarized in the following table.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 5 of 68)
Table 1. Summary of Inspection Deferrals in this Proposed Alternative End of        Length of Current       Time Until ASME        Item                                Date of Last  Licensed          Next Station     Unit                               Description Category      No.                                Inspection   Operating     Inspection for Period       This Request (60 Years)        (Years)
Braidwood     1       B-B       B2.11    Pressurizer, Shell-to-Head  10/12/2019   10/17/2046          27.0 Welds, Circumferential B-B       B2.12     Pressurizer, shell-to-Head 10/12/2019                       27.0 Welds, Longitudinal B-D       B3.110     Pressurizer, Nozzle-to-     4/8/2021                       25.0 Vessel Welds Braidwood     2       B-B       B2.11    Pressurizer, Shell-to-Head  10/11/2018   12/18/2047          29.2 Welds, Circumferential B-B       B2.12     Pressurizer, shell-to-Head 10/11/2018                       29.2 Welds, Longitudinal B-D       B3.110     Pressurizer, Nozzle-to-   10/11/2018                       29.2 Vessel Welds Byron       1       B-B       B2.11    Pressurizer, Shell-to-Head   9/18/2015   10/31/2044          29.1 Welds, Circumferential B-B       B2.12     Pressurizer, shell-to-Head  9/18/2015                       29.1 Welds, Longitudinal B-D       B3.110     Pressurizer, Nozzle-to-    9/14/2018                       26.1 Vessel Welds Byron       2       B-B       B2.11    Pressurizer, Shell-to-Head   10/6/2014    11/6/2046          32.1 Welds, Circumferential B-B       B2.12     Pressurizer, shell-to-Head  10/6/2014                       32.1 Welds, Longitudinal B-D       B3.110     Pressurizer, Nozzle-to-    4/13/2019                       27.6 Vessel Welds Calvert      1       B-B       B2.11    Pressurizer, Shell-to-Head   2/25/2020    7/31/2034          14.4 Cliffs                                   Welds, Circumferential B-B       B2.12     Pressurizer, shell-to-Head  2/25/2020                       14.4 Welds, Longitudinal B-D       B3.110     Pressurizer, Nozzle-to-    2/21/2016                       18.5 Vessel Welds Calvert      2       B-B       B2.11    Pressurizer, Shell-to-Head   3/13/2021    8/13/2036          15.4 Cliffs                                   Welds, Circumferential B-B       B2.12     Pressurizer, shell-to-Head  3/12/2021                       15.4 Welds, Longitudinal B-D       B3.110     Pressurizer, Nozzle-to-    3/10/2021                       15.4 Vessel Welds As indicated in Table 1, the proposed alternative results in a maximum effective operating period of 32.1 years from the last inspection for Item Numbers B2.11 and B2.12 for Byron Unit 2 included in this proposed alternative. As summarized in Reference [1], the EPRI report demonstrates that for time intervals longer than 30 years (up to 80 years) no other inspections

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 6 of 68) are required to maintain plant safety and relevant acceptance criteria.
The key aspects of the technical basis for this request are summarized below. The applicability of the technical basis to Braidwood, Byron, and Calvert Cliffs is shown in Appendix A.
Degradation Mechanism Evaluation An evaluation of degradation mechanisms that could potentially impact the reliability of the pressurizer welds was performed in Reference [1]. Evaluated mechanisms included stress corrosion cracking (SCC), environmental assisted fatigue (EAF),
microbiologically influenced corrosion (MIC), pitting, crevice corrosion, erosion-cavitation, erosion, flow accelerated corrosion (FAC), general corrosion, galvanic corrosion, and mechanical/ thermal fatigue. Other than the potential for EAF and mechanical/thermal fatigue, there are no active degradation mechanisms identified that significantly affect the long-term structural integrity of the pressurizer welds.
Stress Analysis Finite element analyses (FEA) were performed in Reference [1] to determine the stresses in the subject pressurizer welds. The analyses were performed using representative pressurized water reactor (PWR) geometries, representative transients, and typical material properties. The results of the stress analyses were used to produce flaw tolerance evaluations. The applicability of the FEA to Braidwood, Byron, and Calvert Cliffs in accordance with Section 9 of Reference [1]
is shown in Appendix A and confirms that all plant-specific applicability requirements are satisfied. Therefore, the evaluation results and conclusions of Reference [1] are applicable to Braidwood, Byron, and Calvert Cliffs.
Flaw Tolerance Evaluation Flaw tolerance evaluations were performed in Reference [1] consisting of PFM and DFM evaluations. The results of the PFM analyses indicate that, after a preservice inspection (PSI), no other inspections are required for up to 60 years of plant operation to meet the U.S. Nuclear Regulatory Commissions (NRCs) safety goal of 10-6 failures per year. For the case of Braidwood and Byron, PSI was followed by three full 10-year interval inspections, which have been performed on the subject pressurizer welds. For Calvert Cliffs, PSI was followed by four full 10-year interval inspections, which have been performed on the subject pressurizer welds. Table 8-12 of Reference [1] indicates that if PSI are followed by at least three full 10-year interval inspections subsequent examinations do not need to be performed for up to 80 years of plant operation, and they will still meet the NRC safety goal (with considerable margin). The DFM evaluations confirm the PFM results by demonstrating that it takes approximately 400 years for a postulated flaw with an initial depth equal to the ASME Section XI acceptance standards to grow to 80% of the wall thickness without exceeding the ASME Section XI allowable fracture toughness.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-16 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Revision 0 (Page 7 of 68)
Inspection History Plant operating experience (including examinations performed to-date, examination findings, inspection coverage, and previously submitted Proposed Alternatives) is summarized in Tables 2 through 4. As shown in these tables, some previous examinations for the subject welds had limited coverage because of limited volumetric examination scan access due to existing plant obstructions.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 8 of 68)
Table 2. Braidwood Station, Units 1 and 2, Pressurizer Welds Inspection History Weld ID                            PSI1                          Interval 1               Interval 2            Interval 3         Interval 4 Unit   Summary Number                 Ultrasonic Test (UT)                (Date/Outage,           (Date/Outage,          (Date/Outage,      (Date/Outage, Exam Cat, Item Number         (Date, Coverage/Results)            Coverage/Results)        Coverage/Results)      Coverage/Results) Coverage/Results) 1PZR-01-08E                          8-1985                                                                                    Examination currently 10-1995/A1R05              4-2006/A1R12          9-2016/A1R19 1      BRW-1-B02.11.0005     Coverage was not documented; but 100%/NRI                  100%/NRI              98.5%/NRI scheduled for A2R25 B-B/B2.11                 obstructions noted/NRI                                                                                      (2025) 1PZR-01-08A 8-1985                     10-1989/A1R01             9-1998/A1R07          4-2009/A1R14      10-2019/A1R21 1      BRW-1-B02.11.0006 100%/Laminar type flaws noted               100%/NRI                95.3%/NRI              95.3%/NRI         95.3%/NRI B-B/B2.11 1PZR-01-09A 8-1985                     10-1989/A1R01           10-1998/A1R07           4-2009/A1R14      10-2019/A1R21 1      BRW-1-B02.12.0005 100%/Laminations/slag                  100%/NRI                 100%/NRI              100%/NRI           100%/NRI B-B/B2.12 1PZR-01-09D                                                                                                                         Examination 8-1985                     10-1995/A1R05             4-2006/A1R12          9-2016/A1R19 1      BRW-1-B02.12.0006 100%/NRI                        100%/NRI                 100%/NRI              100%/NRI currently scheduled B-B/B2.12                                                                                                                      for A2R25 (2025) 1PZR-01-N4A                          8-1985                    10-1995/A1R053             4-2006/A1R12                              Examination 9-2016/A1R19 1     BRW-1-B03.110.0013        Coverage was not documented;           Coverage was not      100% Shell Side only due 68.7%/NRI currently scheduled B-D/B3.110           limitations due to Geometry/NRI         documented/NRI             to config/NRI                          for A2R25 (2025) 8-1985 1PZR-01-N4B                                                                                                                         Examination Coverage was not documented;             10-1995/A1R05           10-2004/A1R11           4-2015/A1R18 1     BRW-1-B03.110.0014 limitations due to Geometry/Laminar             100%/NRI               92.66%/NRI              90.9%/NRI currently scheduled B-D/B3.110                                                                                                                     for A2R24 (2024) flaw 1PZR-01-N1                          8-1985                          A1R06                                                          Examination 10-2007/A1R132          9-2016/A1R192 1     BRW-1-B03.110.0015        Coverage was not documented;        (VT-2 per Relief Request 59.2%/NRI              74.7%/NRI currently scheduled B-D/B3.110           limitations due to Geometry/NRI             per NR-24)                                                    for A2R25 (2025) 9-1998/A1R073 1PZR-01-N2                          8-1985                    10-1989/A1R013 Coverage was not        10-2010/A1R15       4-2021/A1R22 1     BRW-1-B03.110.0016        Coverage was not documented;           Coverage was not documented; geometry         56.56%/NRI        56.43%/NRI B-D/B3.110           limitations due to Geometry/NRI         documented/NRI limitations/NRI 9-1998/A1R073 1PZR-01-N3                          8-1985                    10-1989/A1R01  3 Coverage was not        10-2010/A1R15       4-2021/A1R22 1     BRW-1-B03.110.0017        Coverage was not documented;           Coverage was not documented; geometry         60.92%/NRI           60%/NRI B-D/B3.110           limitations due to Geometry/NRI         documented/NRI limitations/NRI 10-1995/A1R053 1PZR-01-N4C                          8-1985                                                                                         Examination Coverage was not          10-2004/A1R11           4-2015/A1R18 1     BRW-1-B03.110.0018        Coverage was not documented; documented; geometry           92.66%/NRI              90.9%/NRI currently scheduled B-D/B3.110           limitations due to Geometry/NRI                                                                           for A2R24 (2024) limitations/NRI 1-1987 2PZR-01-08A                                                      4-1990/A2R013            5-1999/A2R07                              Examination Coverage was not documented;                                                            10-2009/A2R14 2      BRW-2-B02.11.0005 limitations due to obstructions/
Coverage was not        99.85%/Laminations 95.57%/NRI currently scheduled B-B/B2.11                                                    documented/NRI                  noted                             for A2R23 (2023)
Laminar and Planar flaws noted

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 9 of 68)
Table 2. Braidwood Station, Units 1 and 2, Pressurizer Welds Inspection History Weld ID                              PSI1                        Interval 1              Interval 2               Interval 3            Interval 4 Unit       Summary Number                   Ultrasonic Test (UT)              (Date/Outage,           (Date/Outage,           (Date/Outage,          (Date/Outage, Exam Cat, Item Number            (Date, Coverage/Results)            Coverage/Results)       Coverage/Results)       Coverage/Results)     Coverage/Results) 12-1986 2PZR-01-08E                                                                                                                              Examination Coverage was not documented;            4-1996/A2R05           10-2006/A2R12            10-2018/A2R20 2        BRW-2-B02.11.0006                                                                                                                       currently scheduled obstructions noted/Laminar and             100%/NRI                100%/NRI                 100%/NRI B-B/B2.11                                                                                                                           for A2R26 (2027)
Planar flaws noted 2PZR-01-09A                                                                                                                              Examination 1-1987                    4-1990/A2R01            5-1999/A2R07            10-2009/A2R14 2         BRW-2-B02.12.0005 100%/NRI                       100%/NRI                100%/NRI                 100%/NRI currently scheduled B-B/B2.12                                                                                                                           for A2R22 (2021) 2PZR-01-09D                                                                                                                              Examination 12-1986                    4-1996/A2R05           10-2006/A2R12            10-2018/A2R20 2          BRW-2-B02.12.0006                                                                                                                      currently scheduled 100%/Laminar type flaws noted              100%/NRI                100%/NRI                 100%/NRI B-B/B2.12                                                                                                                           for A2R26 (2027) 2PZR-01-N1                                                          A2R06                                                               Examination 1-1987                                            5-2008/A2R13            4-2017/A2R192 2         BRW-2-B03.110.0013                                             (VT-2 per Relief Request                                                 currently scheduled 100%/NRI                                              59.2%/NRI                59.2%/NRI B-D/B3.110                                                         NR-24)                                                           for A2R25 (2026) 2PZR-01-N2                                                                                                                              Examination 12-1986                    4-1996/A2R05            4-1999/A2R07             4-2011/A2R15 2         BRW-2-B03.110.0014                                                                                                                      currently scheduled 100%/NRI                       100%/NRI               88.5%/NRI                88.5%/NRI B-D/B3.110                                                                                                                          for A2R23 (2023) 4-1990/A2R013 2PZR-01-N3                           12-1986                                                                                            Examination Coverage was not          4-1999/A2R07             4-2011/A2R15 2         BRW-2-B03.110.0015          Coverage was not documented;                                                                                currently scheduled documented; geometry          88.5%/NRI                88.5%/NRI B-D/B3.110                 geometry limitations/NRI                                                                                 for A2R22 (2021) limitations /NRI 4-1990/A2R013 2PZR-01-N4A                           12-1986                                                                                            Examination Coverage was not         10-2006/A2R12            10-2018/A2R20 2         BRW-2-B03.110.0016          Coverage was not documented;                                                                                currently scheduled documented; geometry          91.5%/NRI                91.5%/NRI B-D/B3.110             nozzle geometry limitations/NRI                                                                              for A2R26 (2027) limitations /NRI 12-1986                    3-1996/A2R053 2PZR-01-N4B                                                                                                                              Examination Coverage was not documented;          Coverage was not         11-2003/A2R10             5-2014/A2R17 2         BRW-2-B03.110.0017                                                                                                                      currently scheduled nozzle geometry limitations /Laminar documented; geometry           88.5%/NRI                88.5%/NRI B-D/B3.110                                                                                                                          for A2R24 (2024) type flaw                  limitations /NRI 3-1996/A2R053          11-2003/A2R103 2PZR-01-N4C                           12-1986                                                                                            Examination Coverage was not        Coverage was not           5-2014/A2R17 2         BRW-2-B03.110.0018          Coverage was not documented;                                                                                currently scheduled documented; geometry    documented; geometry           88.5%/NRI B-D/B3.110             nozzle geometry limitations /NRI                                                                             for A2R24 (2024) limitations /NRI        limitations/NRI Notes:
: 1. PSI included radiographic (RT) examinations per Section III and ultrasonic (UT) examinations per Section XI. Together, these examinations constituted PSI examination in Reference [1], and 100% coverage was assumed because such coverage was required by Section III for the RT exams, and the RT exams were successfully completed for the subject pressurizer welds for both Braidwood, Units 1 and 2.
: 2. The increase in examination coverage from the Second Interval to the Third Interval for weld 1PZR-01-N1 was not a result of a change in physical limitations, but was due to a change in the methods of calculating coverage. For Unit 1 the actual coverage reported in 2007 (A1R13) utilized the most conservative angle for the total coverage (60&deg; axial = 59.2%). In 2016 (A1R19) the coverage utilized an aggregate of all angles 0&deg;, 45&deg; axial and circumferential and 60&deg; axial and circumferential to achieve 74.7% coverage. For Unit 2 during the exam in 2017 (A2R19) for the similar weld, 2PZR-01-N1, coverage was not

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 10 of 68) recalculated, and the same coverage was recorded as the prior interval examination. The limitations are the same between Unit 1 and Unit 2 and the reported Third Interval coverage for weld 2PZR-01-N1 should be similar to the Unit 1 Third Interval coverage at 74.7%.
: 3. Exelon has reviewed the missing coverages for the examinations in the First and Second Intervals and has concluded that the NDE code requirements and equipment for early interval examinations would not have resulted in an examination coverage lower than the minimum achieved coverage of 56.43%. In addition, there have been no design configuration changes that would alter examination access for any of the welds.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 11 of 68)
During the Fourth Interval, the Braidwood, Unit 1, pressurizer spray nozzle weld 1PZR-01-N2 had the minimum coverage of 56.43%. Section 8.3.5 and Table 8-33 of Reference [1] discuss the limited coverage and show that the conclusions of the report are applicable to components with limited coverage as low as 50%. The minimum coverage of 56.43% for this weld is higher than the 50% minimum coverage assumed in the sensitivity study of the base case in the EPRI report; therefore, the sensitivity results from the EPRI report are bounding for application to Braidwood, Units 1 and 2.
No flaws that exceeded the ASME Section XI acceptance standards were identified during any prior examinations for Braidwood.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 12 of 68)
Table 3. Byron Station, Units 1 and 2, Pressurizer Welds Inspection History Weld ID PSI1                          Interval 1                   Interval 2              Interval 3              Interval 4 Summary Number Unit Exam Cat, Item             Ultrasonic Test (UT)                 (Date/Outage,                (Date/Outage,            (Date/Outage,          (Date/Outage, (Date, Coverage/Results)              Coverage/Results)            Coverage/Results)        Coverage/Results)       Coverage/Results)
Number 4-1987 & 4-1987/B1R014 Coverage was not documented; scan limitations 8-1983               due to sampling nozzles and 3-2002/B1R11 Coverage was not documented;                X axis plates/
92%/5 embedded scan limitations (welded pads)         Resizing of 5 subsurface indications identified (1 1RY-01-S/PC-012               were identified/           indications identified in PSI                                                         Examination with 45&deg; and 4 with 60&deg;)       3-2011/B1R17 1    BYR-1-B2.11.0001    2 rejectable 45&deg; indications and                                                                                       currently scheduled 92%/NRI B-B/B2.11           3 rejectable 60&deg; indications              1-1990/B1R03                                                               for B1R25 (2023)
Fourth exam showed (total of 5 indications that did      Resizing of 5 subsurface no change in indication not meet the requirements of      indications identified in B1R01 sizes.
ASME Section XI, IWB-3511 4-1996/B1R07 Resizing of 5 subsurface indications identified in B1R03 8-1982 1RY-01-S/PC-05                                                                                                                                Examination Coverage was not documented;                 4-1996/B1R07                3-2005/B1R13             9-2015/B1R20 1    BYR-1-B2.11.0002                                                                                                                           currently scheduled scan limitations (welded pads)                  96%/NRI                     96%/NRI                 95.47%/NRI B-B/B2.11                                                                                                                                for B1R25 (2023) were identified/NRI 8-1982 1RY-01-S/PL-01                                                  4-1987/B1R01                                                                  Examination Coverage was not documented;                                             3-2002/B1R11             3-2011/B1R17 1    BYR-1-B2.12.0001                                           90% - limited by sample                                                         currently scheduled no scan limitations were                                               100%/NRI                  100%/NRI B-B/B2.12                                             nozzles and axis plates/NRI                                                        for B1R25 (2023) identified/NRI 8-1982 1RY-01-S/PL-04                                                                                                                                Examination Coverage was not documented;                 4-1996/B1R07                3-2005/B1R13             9-2015/B1R20 1    BYR-1-B2.12.0002                                                                                                                           currently scheduled no scan limitations were                   100%/NRI                    100%/NRI                  100%/NRI B-B/B2.12                                                                                                                                for B1R25 (2023) identified/NRI 9-2018/B1R223 7-1982                                                                             9-2006/B1R143 1RY-01-S/PN-01                                                                                                                             72.03% - limited by Coverage was not documented;      B1R07 (VT-2 per Relief Request B1R11 (VT-2 per Relief       40% - limited by nozzle 1   BYR-1-B3.110.0001 NR-19)                  Request I2R-03) nozzle configuration no scan limitations were                                                                 configuration and heater B-D/B3.110                                                                                                                                   and heater identified/NRI                                                                       penetrations/NRI penetrations/NRI

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 13 of 68)
Table 3. Byron Station, Units 1 and 2, Pressurizer Welds Inspection History Weld ID PSI1                        Interval 1               Interval 2               Interval 3               Interval 4 Summary Number Unit Exam Cat, Item            Ultrasonic Test (UT)              (Date/Outage,             (Date/Outage,             (Date/Outage,           (Date/Outage, (Date, Coverage/Results)          Coverage/Results)          Coverage/Results)        Coverage/Results)        Coverage/Results)
Number 7-1982 Coverage was not documented;             1-1990/B1R03 1RY-01-S/PN-02                                                                      11-1997/B1R08              9-2006/B1R14              Examination no scan limitations were        75% - limited by nozzle 1   BYR-1-B3.110.0002                                                                  73% - limited by nozzle  77% - limited by nozzle    currently scheduled identified/         configuration/NRI with 0&deg; and B-D/B3.110                                                                       configuration/NRI         configuration/NRI        for B1R26 (2024)
Indications - appears to be ID   45&deg;. ID Geometry with 60&deg; geometry 7-1982 1RY-01-S/PN-03                                                                      11-1997/B1R08              9-2006/B1R14              Examination Coverage was not documented;             3-1987/B1R01 1   BYR-1-B3.110.0003                                                                  69% - limited by nozzle  77% - limited by nozzle    currently scheduled no scan limitations were                100%/NRI B-D/B3.110                                                                       configuration/NRI         configuration/NRI        for B1R26 (2024) identified/NRI 7-1982 Coverage was not documented;             1-1990/B1R03 1RY-01-S/PN-04                                                                       3-2002/B1R11              9-2015/B1R20              Examination no scan limitations were        75% - limited by nozzle 1   BYR-1-B3.110.0004                                                                  66% - limited by nozzle 64.93% - limited by nozzle currently scheduled identified          configuration/NRI with 0&deg; and B-D/B3.110                                                                       configuration/NRI         configuration/NRI        for B1R25 (2023)
Indications - appears to be ID   45&deg;. ID Geometry with 60&deg; geometry 9-2006/B1R14 68% - limited by nozzle 7-1982 1RY-01-S/PN-05                                                                      11-1997/B1R08            configuration/NRI           Examination Coverage was not documented;             4-1996/B1R07 1   BYR-1-B3.110.0005                                                                  73% - limited by nozzle                             currently scheduled no scan limitations were                100%/NRI B-D/B3.110                                                                       configuration/NRI           9-2015/B1R20           for B1R25 (2023) identified/NRI 64.93% - limited by nozzle configuration/NRI 7-1982 Coverage was not documented;             9-1988/B1R02 1RY-01-S/PN-06         no scan limitations were    76% (0&deg;) 75% (45&deg;), 75% (60&deg;)    11-1997/B1R08              9-2006/B1R14              Examination 1   BYR-1-B3.110.0006                identified/                  limited due to       73% - limited by nozzle  77% - limited by nozzle    currently scheduled B-D/B3.110        Indications - appears to be ID configuration/Spot indication   configuration/NRI         configuration/NRI        for B1R26 (2024) geometry and one spot indication          similar to PSI (seen with 45&deg;)
1-1989/B2R014 10-1985                                              3-2004/B2R11 Coverage was not 2RY-01-S/PC-01     Coverage was not documented;                                  92% - scan limitations                                  Examination documented; scan limitations                                10-2014/B2R18 2    BYR-2-B2.11.0001     scan limitations (welded pads,                                   (welded pads,                                   currently scheduled (welded pads, sampling                                      94%/NRI B-B/B2.11        sampling nozzle and skirt) were                                sampling nozzle and                                 for B2R23 (2022) nozzle and skirt) were identified/NRI                                             skirt)/NRI identified/NRI

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 14 of 68)
Table 3. Byron Station, Units 1 and 2, Pressurizer Welds Inspection History Weld ID PSI1                           Interval 1                Interval 2              Interval 3               Interval 4 Summary Number Unit Exam Cat, Item               Ultrasonic Test (UT)                   (Date/Outage,             (Date/Outage,            (Date/Outage,           (Date/Outage, (Date, Coverage/Results)               Coverage/Results)           Coverage/Results)       Coverage/Results)        Coverage/Results)
Number 3-1995/B2R054 10-1985 2RY-01-S/PC-05                                                  Coverage was not                                                                Examination Coverage was not documented;                                             9-2005/B2R12             4-2010/B2R15 2    BYR-2-B2.11.0002                                          documented; scan limitations                                                       currently scheduled scan limitations (welded pads)                                              96%/NRI                  96%/NRI B-B/B2.11                                                    (welded pads) were                                                            for B2R24 (2023) were identified/NRI identified/NRI 10-1985 Coverage was not documented; no scan limitations were                 1-1989/B2R014 2RY-01-S/PL-01                                                                                                                                  Examination identified/                  Coverage was not             3-2004/B2R11             10-2014/B2R18 2    BYR-2-B2.12.0001                                                                                                                             currently scheduled Indications - 0&deg; identified 4         documented; no scan               100%/NRI                 100%/NRI B-B/B2.12                                                                                                                                  for B2R23 (2022) embedded indications, 45&deg; was NRI, limitations were identified/NRI 60&deg; identified 2 embedded indications.
10-1985                       3-1995/B2R054 2RY-01-S/PL-04                                                                                                                                  Examination Coverage was not documented; no              Coverage was not             9-2005/B2R12             4-2010/B2R15 2    BYR-2-B2.12.0002                                                                                                                             currently scheduled scan limitations were             documented; no scan               100%/NRI                 100%/NRI B-B/B2.12                                                                                                                                  for B2R24 (2023) identified/NRI           limitations were identified/NRI 10-1985 Coverage was not documented; no                                                                                              4-2019/B2R213 4-2007/B2R133 2RY-01-S/PN-01      scan limitations were identified/                                       11-1999/B2R08                                     40% - limited by 2-1989/B2R01                                   40% - limited by nozzle 2   BYR-2-B3.110.0001       Indications - 0&deg; was NRI, 45&deg; (VT-2 per Relief Request NR-19)
(VT-2 per Relief                                nozzle configuration B-D/B3.110                                                                                Request I2R-03)      configuration and heater identified 1 embedded indication,                                                                                             and heater 60&deg; identified 1 embedded                                                                   penetrations/NRI penetrations/NRI indication.
9-1993/B2R044             3-2004/B2R11 2RY-01-S/PN-02                      10-1985                                                                           4-2010/B2R15              Examination Coverage was not           62.3% - limited by 2   BYR-2-B3.110.0002   Coverage was not documented; no                                                                62.3% - limited by nozzle  currently scheduled documented; no scan                 nozzle B-D/B3.110      scan limitations were identified/NRI                                                              configuration/NRI        for B2R24 (2023) limitations were identified/NRI   configuration/NRI 2RY-01-S/PN-03                      10-1985                        10-1990/B2R02             4-2001/B2R09             4-2010/B2R15              Examination 2   BYR-2-B3.110.0003   Coverage was not documented; no            75% - limited by nozzle     66% - limited by nozzle 66.3% - limited by nozzle  currently scheduled B-D/B3.110      scan limitations were identified/NRI           configuration/NRI         configuration/NRI        configuration/NRI        for B2R24 (2023) 9-1993/B2R044 2RY-01-S/PN-04                      10-1985                                                  3-2004/B2R11             10-2014/B2R18             Examination Coverage was not 2   BYR-2-B3.110.0004   Coverage was not documented; no                                        62% - limited by nozzle 62.5% - limited by nozzle  currently scheduled documented; no scan B-D/B3.110      scan limitations were identified/NRI                                     configuration/NRI        configuration/NRI        for B2R24 (2023) limitations were identified/NRI

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 15 of 68)
Table 3. Byron Station, Units 1 and 2, Pressurizer Welds Inspection History Weld ID PSI1                           Interval 1                    Interval 2              Interval 3              Interval 4 Summary Number Unit Exam Cat, Item                Ultrasonic Test (UT)                  (Date/Outage,                (Date/Outage,            (Date/Outage,           (Date/Outage, (Date, Coverage/Results)              Coverage/Results)            Coverage/Results)        Coverage/Results)        Coverage/Results)
Number 3-1995/B2R054                                                                  4-2019/B2R21 2RY-01-S/PN-05                   10-1985                                                      4-2001/B2R09             10-2014/B2R18 Coverage was not                                                                66% - limited by 2     BYR-2-B3.110.0005   Coverage was not documented; no                                      66.3% - limited by nozzle 62.5% - limited by nozzle documented; no scan                                                                    nozzle B-D/B3.110      scan limitations were identified/NRI                                    configuration/NRI         configuration/NRI limitations were identified/NRI                                                       configuration/NRI 3-1995/B2R05 4 4-2019/B2R21 2RY-01-S/PN-06                   10-1985                                                      4-2001/B2R09             4-2010/B2R15 Coverage was not                                                                62% - limited by 2     BYR-2-B3.110.0006   Coverage was not documented; no                                       66% - limited by nozzle  66.3% - limited by nozzle documented; no scan                                                                    nozzle B-D/B3.110      scan limitations were identified/NRI                                     configuration/NRI        configuration/NRI limitations were identified/NRI                                                       configuration/NRI Notes:
: 1. PSI included radiographic (RT) examinations per Section III and ultrasonic (UT) examinations per Section XI. Together, these examinations constituted PSI examination in Reference [1], and 100% coverage was assumed because such coverage was required by Section III for the RT exams, and the RT exams were successfully completed for the subject pressurizer welds for both Byron units.
: 2. Indications were found in weld 1RY-01-S/PC-01 that did not meet the acceptance standards of IWB-3511 during the initial PSI examination, but were accepted by engineering evaluation per IWB-3600 and three successive examinations were performed in B1R01, B1R03, and B1R07, which showed no changes in the flaw sizes.
: 3. The increase in examination coverage from the Third Interval to the Fourth Interval for weld 1RY-01-S/PN-01 was not a result of a change in physical limitations, but was due to a change in the methods of calculating coverage. For Unit 1 in 2018 (B1R22) the coverage calculated included the axial coverage of the examination which increased the coverage to 72.03%. For Unit 2 the exam in 2019 (B2R21) did not recalculate the coverage and conservatively assumed the same coverages as the 2007 (B2R13) exam, which did not include the axial coverage. The limitations are the same between Unit 1 and Unit 2 and the reported Fourth Interval coverage for weld 2RY-01-S/PN-01 should be similar to the Unit 1 Fourth Interval coverage at 72.03%.
: 4. Exelon has reviewed the missing coverages for the examinations in the First Interval and has concluded that the Code NDE requirements and equipment for early interval examinations would not have resulted in an examination coverage lower than the minimum documented coverage of 40%. In addition, there have been no design configuration changes that would alter examination access for any of the welds.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 16 of 68)
During Interval 3, the Byron, Units 1 and 2 pressurizer surge nozzle welds 1RY    S/PN-01 and 2RY-01-S/PN-01 had the minimum documented coverage of 40%.
During Interval 4, the Byron, Unit 2 pressurizer surge nozzle weld 2RY-01-S/PN-01 again had a minimum documented coverage of 40%. (Note: The subsequent B1R22 examination for Weld ID 1RY-01-S/PN-01 recorded significantly more coverage at 72.03%, which was calculated by including the axial examination. The change in coverage was not a result of changes to physical limitations. The limitations are the same between Unit 1 and Unit 2 and the reported Fourth Interval coverage for weld 2RY-01-S/PN-01 should be similar to the Unit 1 Fourth Interval coverage at 72.03%). During the First and Second Intervals Relief Requests NR-19 and I2R-03 were approved by the NRC to perform VT-2 examination in lieu of UT for welds 1RY-01-S/PN-01 (Outage B1R07 and B1R11) and 2RY-01-S/PN-01 (Outages B2R01 and B2R08). Since the minimum coverage was identified for the surge line nozzle welds, a review of the probability of leakage and rupture for various sensitivity studies from Reference [1] was done for leak path PRNV-BW-1C, which is applicable to welds 1RY-01-S/PN-01 and 2RY-01-S/PN-01 as follows:
* Section 8.3.4.1.1 and Table 8-11 of Reference [1] discuss the probability of rupture and leakage for the case study if only PSI exams are performed.
The most limiting crack path for the surge line nozzle welds (PRNV-BW-1C),
yielded a probability of leakage of 6.25x10-9 after 80 years and a probability of rupture of 1.25x10-9 after 80 years. The probability of leakage and the probability of rupture for this Case ID listed in Table 8-11 are approximately three orders of magnitude below the acceptance criteria utilized in Reference [1], Section 8.3.2.9, of 10-6 failures per year. Additionally, the impact of performing more examinations than the PSI-only case study, even with limited coverage, which was the case for welds 1RY-01-S/PN-01 and 2RY-01-S/PN-01, would reduce the probability of rupture and leakage.
Furthermore, as discussed in Section 8.3.4.1.1 of Reference [1], leakage of the pressure boundary is detectable by plant operators and plant procedures allow for safe plant shutdown under leaking conditions. Probabilities of rupture values are maintained well below the acceptance criterion for 80 years of operation even considering only PSI inspection. The examination results with coverage as low as 40% for welds 1RY-01-S/PN-01 and 2RY-01-S/PN-01 at Byron are bounded by the PSI-only case study in Reference
[1] and the failure frequency for these welds would be below the NRC acceptance criteria of 10-6 failures per year.
* Section 8.3.5 and Table 8-33 of Reference [1] discuss the probability of leakage for the case study where only 50% coverage was achieved. For the leak path most applicable to welds 1RY-01-S/PN-01 and 2RY-01-S/PN-01, PRNV-BW-1C was evaluated to have a probability of leakage of 3.75x10 -9 after 80 years. This was an increase of 2.5x10-9 compared to the base case where 100% coverage was achieved. This increase in the probability of leakage is small in comparison to the acceptance criteria of 10-6 failures per year. The sensitivity studies performed in Reference [1], including the Inspection Coverage case study, show that probabilities of rupture and leakage are not significantly affected by using a range of values for most of the input variables.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 17 of 68)
Considering all of the findings from Reference [1] it can be concluded that the probability of failure is below 10-6 failures per year for welds 1RY-01-S/PN-01 and 2RY-01-S/PN-01.
At Byron, weld 1RY-01-S/PC-01 had five indications that did not meet acceptance standards of IWB-3511 during the PSI examination, but all five indications were accepted through engineering evaluation in accordance with IWB-3600 of Section XI. Successive examinations were performed in B1R01 (1987), B1R03 (1990), and B1R07 (1996) which showed no change in the five indications. The most recent examination performed on weld 1RY-01-S/PC-01 during B1R17 (2011) did not identify any recordable indications. The absence of indications in this latest examination is due to improved NDE techniques and changes to sizing requirements. Therefore, the B1R17 examination determined that the previously reported indications meet the acceptance standards of ASME Section XI.
Based on the discussions above, the results of the EPRI report are applicable to Byron, Units 1 and 2.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 18 of 68)
Table 4. Calvert Cliffs, Units 1 and 2, Pressurizer Welds Inspection History PSI1 Weld ID Ultrasonic Test       Interval 1         Interval 2        Interval 3        Interval 4         Interval 5 Summary Number Unit                          (UT)         (Date/Outage,      (Date/Outage,     (Date/Outage,     (Date/Outage,      (Date/Outage, Exam Cat, Item (Date,     Coverage/Results)  Coverage/Results) Coverage/Results) Coverage/Results) Coverage/Results)
Number Coverage/Results) 1          8-411            8-1974 DATA RECORD NOT    DATA RECORD NOT     3-2000/1RFO14     2-2010/1RFO19       2-2020/CC1R25 CCNP-1-003900   Coverage was not FOUND5             FOUND5          100%/NRI          100%/NRI            99.7%/NRI B-B/B2.11      documented/NRI 1          3-401                           2-1978/1RFO26 8-1974                                                                               Examination currently CCNP-1-004000                      Coverage was not     3-1994 /1RFO11   4-2004/1RFO16     2-2018/1RFO23 Coverage was not                                                                           scheduled for CC1R29 B-B/B2.11                           documented           99.8%/NRI        90.7%/NRI         99.1%/NRI documented/ NRI                                                                                    (2028)
                                                  /NRI 1         2-401A            8-1974         2-1978/1RFO26 DATA RECORD NOT     3-2000/1RFO14     2-2010/1RFO19       2-2020/CC1R25 CCNP-1-003700   Coverage was not   Coverage was not FOUND5           96%/NRI          100%/NRI            97.5%/NRI B-B/B2.12      documented/ NRI   documented /NRI 1         2-401B            8-1974        11-1980/1RFO46 CCNP-1-003750   Coverage was not   Coverage was not           NA4              NA4               NA4                 NA4 B-B/B2.12      documented/ NRI   documented /NRI 1         2-401C            71974 DATA RECORD NOT CCNP-1-003800   Coverage was not                              NA4              NA4               NA4                 NA4 FOUND5 B-B/B2.12      documented/ NRI 1         2-401D            9-1974                                                                               Examination currently DATA RECORD NOT       3-1994/1RFO11    4-2004/1RFO16     2-2018/1RFO23 CCNP-1-003850   Coverage was not                                                                           scheduled for CC1R29 FOUND5            100%/NRI         100%/NRI           94%/NRI B-B/B2.12      documented/ NRI                                                                                    (2028) 1          4-404            7-1974        11-1980/1RFO46                                                         Examination currently 2-1994/1RFO11    4-2004/1RFO163    2-2014/1RFO213 CCNP-1-004050   Coverage was not   Coverage was not                                                        scheduled for CC1R28 71%/NRI         65.9%/NRI         31.8%/NRI B-D/B3.110     documented/ NRI   documented /NRI                                                                  (2026) 1          4-405            8-1974         2-1978/1RFO26                                                         Examination currently DATA RECORD NOT     3-2000/1RFO14     2-2010/1RFO19 CCNP-1-004100   Coverage was not   Coverage was not                                                        scheduled for CC1R28 FOUND5          66.4%/NRI         66.4%/NRI B-D/B3.110     documented/ NRI   documented /NRI                                                                  (2026) 1        16-405A            7-1974                                                                               Examination currently DATA RECORD NOT    DATA RECORD NOT     2-2006/1RFO172    2-2016/1RFO222 CCNP-1-004150   Coverage was not                                                                           scheduled for CC1R28 FOUND5             FOUND5           36%/NRI          60.5%/NRI B-D/B3.110     documented/ NRI                                                                                    (2026) 1        16-405B            7-1974                                                                               Examination currently DATA RECORD NOT      3-1994/1RFO112    2-2006/1RFO172    2-2016/1RFO222 CCNP-1-004200   Coverage was not                                                                           scheduled for CC1R28 FOUND5            79.7%/NRI         36%/NRI          60.5%/NRI B-D/B3.110     documented/ NRI                                                                                    (2026) 2          8-411            9-1972                                                 2RFO13 DATA RECORD NOT    DATA RECORD NOT                       2-2011 /2RFO18      3-2021/CC2R24 CCNP-2-103050   Coverage was not                                       DATA RECORD NOT FOUND5             FOUND5                            100%/NRI            99.7%/NRI B-B/B2.11      documented/ NRI                                             FOUND5 2          3-401            9-1972         6-1984/2RFO66                                                         Examination currently 4-1993/2RFO9    3-2003/2RFO14     2-2017/2RFO21 CCNP-2-103070   Coverage was not   Coverage was not                                                        scheduled for CC2R27 100%/NRI         100%/NRI          100%/NRI B-B/B2.11      documented/ NRI   documented /NRI                                                                  (2027)

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 19 of 68)
Table 4. Calvert Cliffs, Units 1 and 2, Pressurizer Welds Inspection History PSI1 Weld ID Ultrasonic Test             Interval 1           Interval 2            Interval 3               Interval 4                 Interval 5 Summary Number Unit                               (UT)               (Date/Outage,        (Date/Outage,         (Date/Outage,            (Date/Outage,              (Date/Outage, Exam Cat, Item (Date,          Coverage/Results)    Coverage/Results)      Coverage/Results)        Coverage/Results)         Coverage/Results)
Number Coverage/Results) 2          2-401A               9-1972                                                             2RFO13 DATA RECORD NOT      DATA RECORD NOT                                   2-2011/2RFO18               3-2021/CC2R24 CCNP-2-103010        Coverage was not                                                  DATA RECORD NOT FOUND5               FOUND5                                        96%/NRI                    96.4%/NRI B-B/B2.12         documented/ NRI                                                         FOUND5 2          2-401B               9-1972 DATA RECORD NOT CCNP-2-103020        Coverage was not                                     NA4                  NA4                       NA4                        NA4 FOUND5 B-B/B2.12         documented/ NRI 2          2-401C               9-1972               6-1984/2RFO66 CCNP-2-103030        Coverage was not       Coverage was not              NA4                  NA4                       NA4                        NA4 B-B/B2.12         documented/ NRI         documented /NRI 2          2-401D               9-1972               6-1984/2RFO66                                                                              Examination currently DATA RECORD NOT          3-2003/2RFO14            2-2017/2RFO21 CCNP-2-103040        Coverage was not       Coverage was not                                                                             scheduled for CC2R27 FOUND5              100%/NRI                 95.3%/NRI B-B/B2.12         documented/ NRI         documented /NRI                                                                                       (2027) 2           4-404               9-1972 DATA RECORD NOT          4-1989/2RFO8         4-2001/2RFO13            2-2011/2RFO183             3-2021/CC2R243 CCNP-2-103080        Coverage was not FOUND5               63%/NRI             69.5%/NRI                 56%/NRI                    28.2%/NRI B-D/B3.110         documented/ NRI 2           4-405               9-1972               6-1984/2RFO66                                 2RFO13 4-1989/2RFO8                                  2-2011/2RFO18               3-2021/CC2R24 CCNP-2-103090        Coverage was not       Coverage was not                           DATA RECORD NOT 53%/NRI                                       65%/NRI                    62.1%/NRI B-D/B3.110         documented/ NRI         documented /NRI                                 FOUND5 2         16-405A               9-1972               6-1984/2RFO66 4-1993/2RFO92        3-2003/2RFO142           2-2013/2RFO192             3-2021/CC2R242 CCNP-2-103100        Coverage was not       Coverage was not 98%/NRI              41%/NRI                  58%/NRI                    55.3%/NRI B-D/B3.110         documented/ NRI         documented /NRI 2         16-405B               9-1972               6-1984/2RFO66 DATA RECORD NOT          3-2007/2RFO162           2-2017/2RFO212             3-2021/CC2R242 CCNP-2-103110        Coverage was not       Coverage was not FOUND5              41.9%/NRI                60.5%/NRI                   55.3%/NRI B-D/B3.110         documented/ NRI         documented /NRI Notes
: 1. PSI included radiographic (RT) examinations per Section III and ultrasonic (UT) examinations per Section XI. Together, these examinations constituted PSI examination in Reference [1], and 100% coverage was assumed because such coverage was required by Section III for the RT exams, and the RT exams were successfully completed for the subject pressurizer welds for both Calvert Cliffs units.
: 2. The variations in examination coverage over the Intervals for welds 16-405A and 16-405B (Units 1 and 2) was not a result of a change in physical limitations, but was due to a change in the methods of calculating coverage.
: 3. The decrease in examination coverage from the Third Interval to the Fourth Interval (Unit 1) and Fourth Interval to the Fifth Interval (Unit 2) for weld 4-404 was not a result of a change in physical limitations, but was due to a change in the examination boundaries. The weld locations utilized in 2004 (1RFO16) and 2011 (2RFO18) were adjusted in 2014 (1RFO21) and 2021 (2RFO24) to be closer to the nozzle, based on the nozzle design drawing, which increased the limitation.
The adjustment resulted in a drop in coverage.
: 4. The pressurizers at Calvert Cliffs have two longitudinal welds per shell. For Successive Inspection Intervals, ASME Section XI requires only 1ft of one weld per head to be volumetrically examined.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 20 of 68)
: 5. Examination records for earlier Intervals could not be located in plant records during the preparation of this proposed alternative; however, recent examination data shows these welds have had acceptable results in accordance with Section XI.
: 6. Exelon has reviewed the missing coverages for the examinations in the First Interval and has concluded that the NDE code requirements and equipment for early interval examinations would not have resulted in an examination coverage lower than the minimum achieved coverage of 28.2%. In addition, there have been no design configuration changes that would alter examination access for any of the welds.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 21 of 68)
During Interval 3, the Calvert Cliffs, Units 1 and 2, pressurizer safety/relief nozzle welds 16-405A and 16-405B (for each unit) had a coverage of 36% (Unit 1) and 41% (Unit 2) (Note: The examinations performed during other Intervals for these welds have resulted in a coverage greater than 60%). Since the limited coverage was identified for the safety/relief nozzle welds, a review of the probability of leakage and rupture for various sensitivity studies from Reference [1] was done for leak paths PRNV-CE-4A/C, which is applicable to welds 16-405A and 16-405B as follows:
* Section 8.3.4.1.1 and Table 8-11 of Reference [1] discuss the probability of rupture and leakage for the case study where PSI-only was performed. The most limiting crack path for safety/relief nozzle welds (PRNV-CE-4A &
PRNV-CE-4C), yielded a probability of leakage of 1.25x10-9 after 80 years and a probability of rupture of 1.25x10-9 after 80 years. The probability of leakage and the probability of rupture for this Case ID listed in Table 8-11 are approximately three orders of magnitude below the acceptance criteria utilized in Reference [1], Section 8.3.2.9, of 10-6 failures per year.
Additionally, the impact of performing more examinations than the PSI-only case study, even with limited coverage, which was the case for welds 16-405A and 16-405B, would reduce the probability of rupture and leakage.
Furthermore, as discussed in Section 8.3.4.1.1 of Reference [1], leakage of the pressure boundary is detectable by plant operators and plant procedures allow for safe plant shutdown under leaking conditions.
Probabilities of rupture values are maintained well below the acceptance criterion for 80 years of operation even considering only PSI inspection. The examination results with coverage as low as 36% for welds 16-405A and 16-405B at Calvert Cliffs are bounded by the PSI-only sensitivity study in Reference [1] and the failure frequency for these welds would be below the NRC acceptance criteria of 10-6 failures per year.
* Section 8.3.5 and Table 8-33 of Reference [1] discuss the probability of leakage for the case study where only 50% coverage was achieved. For the leak path most applicable to welds 16-405A and 16-405B, PRNV-CE-4A/C were evaluated to have a probability of leakage of 1.25x10-9 after 80 years.
There is a negligible change in the probability of leakage compared to the base case where 100% coverage was achieved. The sensitivity studies performed in Reference [1], including the Inspection Coverage case study, show that probabilities of rupture and leakage are not significantly affected by using a range of values for most of the input variables.
Also, during Interval 4 for Calvert Cliffs, Unit 1, and Interval 5 for Calvert Cliffs, Unit 2, pressurizer surge nozzle weld 4-404 had the minimum coverage of 31.8% and 28.2%, respectively. It should be noted that the prior examinations performed for these welds reported a coverage greater than 55%. Since the minimum coverage was identified for the surge line nozzle welds, a review of the probability of leakage and rupture for various sensitivity studies from Reference [1] was done for leak path PRNV-BW-1C, which is applicable to weld 4-404.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 22 of 68)
* Section 8.3.4.1.1 and Table 8-11 of Reference [1] discuss the probability of rupture and leakage for the case study where PSI-only was performed. The most limiting crack path for the surge line nozzle welds (PRNV-BW-1C),
yielded a probability of leakage of 6.25x10-9 after 80 years and a probability of rupture of 1.25x10-9 after 80 years. The probability of leakage and the probability of rupture for this Case ID listed in Table 8-11 are approximately three orders of magnitude below the acceptance criteria utilized in Reference [1], Section 8.3.2.9, of 10-6 failures per year. Additionally, the impact of performing more examinations than the PSI-only case study, even with limited coverage, which was the case for weld 4-404, would reduce the probability of rupture and leakage; therefore, the examination results with coverage as low as 31.8% for weld 4-404 at Calvert Cliffs are bounded by the PSI-only case study in Reference [1] and the failure frequency for these welds would be below the NRC acceptance criteria of 10 -6 failures per year.
* Section 8.3.5 and Table 8-33 of Reference [1] discuss the probability of leakage for the case study where only 50% coverage was achieved. For the leak path most applicable to weld 4-404, PRNV-BW-1C was evaluated to have a probability of leakage of 3.75x10-9 after 80 years. This was an increase of 2.5x10-9 compared to the base case where 100% coverage was achieved. This increase in the probability of leakage is small in comparison to the acceptance criteria of 10-6 failures per year. The sensitivity studies performed in Reference [1], including the Inspection Coverage case study, show that probabilities of rupture and leakage are not significantly affected by using a range of values for most of the input variables.
Considering all the findings from Reference [1] it can be concluded that the probability of failure is below 10-6 failures per year for welds 4-404, 16-405A, and 16-405B.
No flaws exceeding the ASME Section XI acceptance standards were identified during any prior examinations for Calvert Cliffs.
Conclusion Based on the results of Reference [1] and its demonstrated applicability to Braidwood, Byron, and Calvert Cliffs, the subject pressurizer welds contained in this proposed alternative are very flaw tolerant. PFM and DFM evaluations performed as part of the technical basis in Reference [1] demonstrate that, after PSI, no other inspections are required for up to 60 years of operation to meet the NRC safety goal of 10-6 failures per reactor year. Plant-specific applicability of the technical basis to Braidwood, Byron, and Calvert Cliffs is demonstrated in Appendix A. While the technical bases demonstrate longer inspection intervals are possible, Exelon considers that deferral of these inspections until the end of the currently approved Period of Extended Operation (PEO), as shown in Table 1, is justified and provides an acceptable level of quality and safety in lieu of the current ASME Section XI 10-year inspection frequency.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 23 of 68)
The PWR fleet inspection history for the applicable components (obtained from an EPRI industry survey) is presented in Appendix B. The results of the survey indicate that these components are very flaw tolerant and prior instances of flaw detection are minimal.
Exelon operating and examination experience demonstrates that these welds have performed with very high reliability, mainly due to their robust designs and structural margins. As shown in the Tables 2 through 4, to-date, Exelon has performed nearly 200 inspections of the subject pressurizer welds at Braidwood, Byron, and Calvert Cliffs, with only one of these welds found to have recordable indications. The sizes of these indications have not increased since PSI. As indicated in the inspection history Tables 2 through 4, some of the examinations involved limited coverage of as low as 28.2%. However, due to the robust fabrication of these components and the intensive pre-service examinations performed, Reference [1] was able to conclude that performing only the PSI examination without any other follow-on ISI examinations is acceptable for up to 80 years of operation while still maintaining plant safety. In addition, it is important to note that all other inspection activities, including the ASME Section XI, Examination Category B-P system leakage test conducted during each refueling outage, will continue to be performed, providing further assurance of safety.
Finally, as discussed in Reference [2], for situations where no active degradation mechanism is present, it was concluded that subsequent inservice inspections do not provide additional value after the PSI has been performed. Braidwood, Byron, and Calvert Cliffs pressurizer welds have received the required PSI examinations along with nearly 200 subsequent inservice inspections with no service-induced indications documented.
Therefore, Exelon requests that the NRC authorize this proposed alternative in accordance with 10 CFR 50.55a(z)(1).
6    Duration of Proposed Alternative The proposed alternative is requested for Braidwood, Byron, and Calvert Cliffs for the remainder of their currently approved operating license, currently scheduled to end on October 17, 2046 (Braidwood, Unit 1), December 18, 2047 (Braidwood, Unit 2), October 31, 2044 (Byron, Unit 1), November 6, 2046 (Byron, Unit 2), July 31, 2034 (Calvert Cliffs, Unit 1), and August 13, 2036 (Calvert Cliffs, Unit 2), as summarized in Table 1.
7    Precedent To-date, one previous submittal has been made requesting relief from the ASME Code, Section XI, Examination Category B-B (Item Numbers B2.11 and B2.12) volumetric examinations on the basis of the Reference [1] Technical Report, as follows:

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 24 of 68)
: 1. Letter from Paul R. Duke, Jr., Manager - Licensing, PSEG Nuclear LLC, to U.S. Nuclear Regulatory Commission Document Control Desk, Proposed Alternative for Examination of ASME Section XI, Examination Category B-B, Item Number B2.11 and B2.12, August 5, 2020, ADAMS Accession No. ML20218A587.
: 2. Letter from Paul R. Duke, Jr., Manager - Licensing, PSEG Nuclear LLC, to U.S. Nuclear Regulatory Commission Document Control Desk, Response to Request for Additional Information for Proposed Alternative for Examination of ASME Section XI, Examination Category B-B, Item Number B2.11 and B2.12, April 12, 2021, ADAMS Accession No. ML21102A024.
In addition, the following is a list of Proposed Alternatives and other precedents related to inspections of pressurizer welds and components:
* Letter from M. Lesniak (ComEd) to NRC, Relief from Inservice Inspection Program Requirements for Pressurizer Surge Nozzle-to-Vessel Weld and Pressurizer Surge Nozzle Inner Radius Section, March 28, 1996, ADAMS Accession No. ML20101L096.
* Letter from R. Capra (NRC) to D. Farrar (Commonwealth Edison Company),
Safety Evaluation of Inservice Inspection Program Relief Request for Inspection of the Pressure Surge Nozzle-to-Vessel Weld; Byron and Braidwood Stations (TAC Nos. M95088, M95089, M95172, and M95173),
May 3, 1996, ADAMS Accession Nos. ML20108D006 and ML20108D016.
* Letter from M. G. Kowal (NRC) to M. A. Balduzi (Entergy Nuclear Operations, Inc.),
Indian Point Nuclear Generating Unit No. 2 - Relief Request No. RR-01 (TAC No.
MD4695), September 5, 2007, ADAMS Accession No. ML072130487.
* Letter from T. L. Tate (NRC) to Vice President, Operations (Entergy Nuclear Operations, Inc.), Indian Point Nuclear Generating Unit No. 2 - Safety Evaluation for Relief Request No. IP2-ISI-RR-01, Examination of Upper Pressurizer Welds (CAC No. MF7082), September 14, 2016, ADAMS Accession No. ML16179A178.
* Letter from N. DiFrancesco (NRC) to M. J. Pacilio (Exelon Generation Company, LLC), Braidwood Station, Units 1 and 2 - Relief from the Requirements of the ASME Code for the Third 10-Year Interval of Inservice Inspection (TAC NOS. ME9748 AND ME9749), January 30, 2013, ADAMS Accession No. ML13016A515.
* Letter from N. L. Salgado (NRC) to B. C. Hanson (Exelon Generation Company, LLC), Braidwood Station, Units 1 and 2 - Relief from the Requirements of the ASME Code (EPID L-2019-LLR-0081), May 14, 2020, ADAMS Accession No. ML20133K093.
* Letter from D. J. Wrona (NRC) to B. C. Hanson (Exelon Generation Company, LLC), Byron Station, Units 1 and 2 - Request for Relief Nos.
13R-12 and 13R-15 from the Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (CAC NOS.
MF9884, MF9885, and MF9886; EPID NOS. 000976/05000454/L-2017-LLR-0055, 000976/05000455/L-2017-LLR-0055, AND 000976/05000455/L-2017-LLR-0056), January 25, 2018, ADAMS Accession No. ML17349A960.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 25 of 68)
* Letter from J. G. Danna (NRC) to D. P. Rhoades (Exelon Generation Company, LLC), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Relief from the Requirements of the ASME Code Concerning Volumetric or Surface Examination Coverage for the Subject Welds (EPID L-2020-LLR-0089), January 15, 2021, ADAMS Accession No. ML20356A121.
In addition, other studies have been performed by the industry to extend the inspection interval for various components and have been accepted by the NRC.
* Based on studies presented in Reference [11], the NRC approved extending the SG vessel and nozzle welds from 10 to 30 years for Vogtle in Reference
[12].
* Based on studies presented in Reference [3], the NRC approved extending PWR reactor vessel nozzle-to-shell welds from 10 to 20 years in Reference
[4].
* Based on work performed in BWRVIP-108, Reference [5], and BWRVIP-241, Reference [7], the NRC approved the reduction of BWR vessel nozzle-to-shell weld examinations (Item No. B3.90 for BWRs from 100% to a 25%
sample of each nozzle type every 10 years) in References [6] and [8]. The work performed in BWRVIP-108 and BWRVIP-241 provided the technical basis for ASME Code Case N-702, Reference [9], which has been conditionally approved by the NRC in Revision 18 of Regulatory Guide 1.147, Reference [10].
8 Acronyms ASME          American Society of Mechanical Engineers B&W           Babcock and Wilcox BWR           Boiling Water Reactor BWRVIP        Boiling Water Reactor Vessel and Internals Program CE            Combustion Engineering CFR           Code of Federal Regulations DFM           Deterministic fracture mechanics EAF           Environmentally assisted fatigue EPRI          Electric Power Research Institute FAC           Flow accelerated corrosion FEA           Finite element analysis ISI           Inservice Inspection MIC           Microbiologically influenced corrosion NPS           Nominal pipe size NRC           Nuclear Regulatory Commission NSSS          Nuclear steam supply system PFM           Probabilistic fracture mechanics PWR           Pressurized Water Reactor SCC           Stress corrosion cracking

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 26 of 68) 9    

==REFERENCES:==
: 1. Technical Bases for Inspection Requirements for PWR Pressurizer Head, Shell-to- Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
: 2. American Society of Mechanical Engineers, Risk-Based Inspection: Development of Guidelines, Volume 2-Part 1 and Volume 2-Part 2, Light Water Reactor (LWR) Nuclear Power Plant Components. CRTD-Vols. 20-2 and 20-4, ASME Research Task Force on Risk-Based Inspection Guidelines, Washington, D.C., 1992 and 1998.
: 3. B. A. Bishop, C. Boggess, N. Palm, Risk-Informed extension of the Reactor Vessel In-Service Inspection Interval, WCAP-16168-NP-A, Rev. 3, October 2011.
: 4. U.S. NRC, Revised Final Safety Evaluation by the Office of Nuclear Reactor Regulation; Topical Report WCAP-16168-NP-A, Revision 2, Risk-Informed Extension of the Reactor Vessel In-service Inspection Interval, Pressurized Water Reactor Owners Group, Project No. 694, July 26, 2011, ADAMS Accession No. ML111600303.
: 5. BWRVIP-108: BWR Vessels and Internals Project, Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzle-to-Shell Welds and Nozzle Blend Radii, EPRI, Palo Alto, CA 2002. 1003557.
: 6. U.S. NRC, Safety Evaluation of Proprietary EPRI Report, BWR Vessel and Internals Project, Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius (BWRVIP-108),
December 19, 2007, ADAMS Accession No. ML073600374.
: 7. BWRVIP-241: BWR Vessels and Internals Project, Probabilistic Fracture Mechanics Evaluation for the Boiling Water Reactor Nozzle-to-Shell Welds and Nozzle Blend Radii, EPRI, Palo Alto, CA 2010. 1021005.
: 8. U.S. NRC, Safety Evaluation of Proprietary EPRI Report, BWR Vessel and Internals Project, Probabilistic Fracture Mechanics Evaluation for the Boiling Water Reactor Nozzle-to-Shell Welds and Nozzle Blend Radii (BWRVIP-241), April 19, 2013, ADAMS Accession Nos. ML13071A240 and ML13071A233.
: 9. Code Case N-702, Alternate Requirements for Boiling Water Reactor (BWR) Nozzle Inner Radius and Nozzle-to-Shell Welds, ASME Code Section XI, Division 1, Approval Date: February 20, 2004.
: 10. U.S. NRC Regulatory Guide 1.147, Revision 19, Inservice Inspection Code Case Acceptability, ASME Code Section XI, Division 1, October 2019.
: 11. Technical Bases for Inspection Requirements for PWR Steam Generator Class 1 Nozzle-to-Vessel Welds and Class 1 and Class 2 Vessel Head, Shell, Tubesheet-to-Head and Tubesheet-to-Shell Welds. EPRI, Palo Alto, CA: 2019. 3002015906.
: 12. U.S. NRC, Vogtle Electric Generating Plant, Units 1 and 2 - Relief Request for Proposed Inservice Inspection Alternative VEGP-ISI-ALT-04-04 to the Requirements of the ASME Code (EPID L-2020-LLR-0109), January 11, 2021, ADAMS Accession No. ML20352A155.
: 13. American Society of Mechanical Engineers, Section XI Rules for Inservice Inspection of Nuclear Power Plant Components, 2007 Edition with 2008 Addenda, 2013 Edition, and 2019 Edition.
: 14. U.S. NRC, Vogtle Electric Generating Plant, Units 1 and 2 - Audit Report for the Promise Version 1.0 Probabilistic Fracture Mechanics Software Used in Relief Request VEGP-ISI-ALT-04-04 (EPID L-2019-LLR-0109), December 10, 2020, ADAMS Accession No. ML20258A002.
: 15. U.S. NRC Regulatory Federal Register Volume 86, Issue 57, March 26, 2021.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 27 of 68)
APPENDIX A Plant-Specific Applicability

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 28 of 68)
Plant-Specific Applicability for Braidwood Station Section 9 of Reference [A1] provides applicability requirements that must be demonstrated in order to apply the representative stress and flaw tolerance analyses to a specific plant. Plant-specific evaluation of these requirements for Braidwood is provided in Table A-1.
Table A-1 indicates that all plant-specific requirements are met for Braidwood. Therefore, the results and conclusions of the EPRI report are applicable to Braidwood.
Table A-1 Plant-Specific Applicability of Reference [A1] Representative Analyses to Braidwood Station, Units 1 and 2 Pressurizer Shell-to-Head Welds (Circumferential and Longitudinal) and Nozzle-to-Shell Welds (Item Numbers B2.11, B2.12, and B3.110)
Requirement from Category                                     Applicability to Braidwood Station, Units 1 and 2 Reference [A1]
General      The plant-specific          In Appendix C of this proposed alternative, the number Requirements    pressurizer general         and type of the Braidwood, Units 1 and 2 general transients and cycles       transients are compared to the transients listed in must be bounded by          Table 5-6 of Reference [A1]. As shown in Table C-2, the those shown in Table 5-     Braidwood, Units 1 and 2 transients are bounded by the 6 for a 60- year            transients listed in Table 5-6 of Reference [A1].
operating life. It should be noted that the number of cycles were extrapolated to 80 years in the evaluations.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 29 of 68)
Requirement from Category                                   Applicability to Braidwood Station, Units 1 and 2 Reference [A1]
The materials of the        The Braidwood, Units 1 and 2, pressurizer upper and pressurizer shell and       lower heads are fabricated of SA-533 Grade A, Class 2, nozzles must be low         to meet ASME Nuclear Vessels Code Section III.
alloy ferritic steels which SA-533 Grade A, Class 2 material is not specifically conform to the listed in ASME Code, Section XI, Appendix G. However, requirements of ASME SA-533 Grade A, Class 2 material has similar toughness Code, Section XI, and chemical composition to SA-533, Grade B, Class 1, Appendix G, Paragraph SA-508-1, SA-508-2, and SA-508-3. SA-533 Grade A, G-2110.
Class 2 has a specified minimum yield strength at room temperature of 70 ksi (which is greater than 50 ksi), and the maximum RTNDT values for the Braidwood pressurizer bottom head materials are 60&deg;F or less (so the RTNDT of 60&deg;F used in the EPRI report is bounding).
Appendix G, Table G-2110-1, of the 2019 Edition of ASME Section XI acknowledges that Figure G-2210-1 is applicable to material SA-533 Grade A, Class 2.
Therefore, it can be concluded that the EPRI report is applicable to material SA-533 Grade A, Class 2.
Also, material properties in SA-533 Grade A, Class 2 material are identical compared to the SA-533 Grade B Class 1 material used in the FEA in the EPRI report as is shown Table 5-2 of Reference [A1]. Therefore, by comparison, SA-533 Grade A, Class 2 material is consistent with the requirements of ASME Code, Section XI, Appendix G and satisfies the requirements for application of the EPRI report.
The Braidwood, Units 1 and 2, pressurizer shells are fabricated from SA-533 Grade A, Class 2, material. The Braidwood, Units 1 and 2, pressurizer Surge, Spray, and Safety-Relief valve nozzles are all fabricated from SA-508, Class 2, material.
The materials for the pressurizer shells conform to the requirements of ASME Code, Section XI, Appendix G, Paragraph G-2110.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 30 of 68)
Requirement from Category                                   Applicability to Braidwood Station, Units 1 and 2 Reference [A1]
Specific    The plant-specific         The Braidwood, Units 1 and 2, pressurizer shell-to-head Requirements  pressurizer surge nozzle   and nozzle-to-vessel weld configurations included in this and bottom head weld       request are shown in Figures A-1, A-2, A-3, and A-4 and configurations must        show conformance with the figures shown in Reference conform to those shown     [A1].
in Figure 1-1 (Item No.
B2.11), Figure 1-2 (Item No. B2.12) and Figures 1-4 and 1-5 (Item No.
B3.110) of Reference
[A1].
The plant-specific         The comparison of the Braidwood, Units 1 and 2, dimensions of the          pressurizer shell dimensions with those in Table 9-1 of pressurizer shell and the  Reference [A1] is provided in Table A-2. The surge nozzle must be       comparison shows that the Braidwood, Units 1 and 2 within the range of        configurations are within the range of values shown in values listed in Table 9-1 Table 9-1 of Reference [A1].
of Reference [A1].
The plant-specific         In Appendix D of this proposed alternative, the Insurge/Outsurge           Braidwood, Units 1 and 2, Insurge/Outsurge transients transient definitions      are compared to the number and type of transients (temperature difference    listed in Table 5-10 of Reference [A1]. As can be seen between the pressurizer    from Table D-2, the Braidwood, Units 1 and 2, transients shell and the pressurizer  are bounded by those transients listed in Table 5-10 of surge nozzle fluid         Reference [A1].
temperature and associated number of cycles) must be bounded by those shown in Table 5-10 for a Westinghouse/CE plant of Reference [A1].

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 31 of 68)
Table A-2 Range of Geometric Parameters for which the Evaluation is Applicable in Comparison with Braidwood Station, Units 1 and 2 Braidwood Station, Component        Geometric Parameter       For a Westinghouse Plant     Units 1 and 2 Dimensions Pressurizer Inside Diameter (in)    Must be between 80 and 88       84 [A3]
Shell NPS of piping or component (e.g., reducer)
Surge Nozzle                               Must be between 12 and 18       14 [A2]
attached to nozzle safe-end (in)
NPS of piping or Safety/Relief  component (e.g., reducer)
Must be between 4 and 8         6 [A2]
Nozzle        attached to nozzle safe-end (in)
NPS of piping or component (e.g., reducer)
Spray Nozzle                                Must be between 4 and 6         4 [A2]
attached to nozzle safe-end (in)
REFERENCES A1. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to- Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
A2. Westinghouse Electric Corporation Drawing No. 1100J48, Outline: Pressurizer 1800 Cu.
Ft. [50.96].
A3. Westinghouse Electric Corporation Drawing No. 1101J22, General Arrangement:
Pressurizer 1800 Cu. Ft. [50.96].
A4. Braidwood Station, Drawings 1PZR-01 and 2PZR-01, Inspection Identification Drawing Inservice Inspection for Pressurizer NC. 1RY01S and 2RY01S.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 32 of 68)
Figure A-1: Braidwood Station, Unit 1 Pressurizer Vessel Weld Locations [A4]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 33 of 68)
Figure A-2: Braidwood Station, Unit 2 Pressurizer Vessel Weld Locations [A4]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 34 of 68)
Figure A-3: Braidwood Station, Units 1 and 2 Typical Pressurizer Nozzle-to-Shell Weld Details

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 35 of 68)
Figure A-4: Braidwood Station, Units 1 and 2 Typical Shell and Head Weld Details [A3]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 36 of 68)
Plant-Specific Applicability for Byron Station Section 9 of Reference [A5] provides applicability requirements that must be demonstrated in order to apply the representative stress and flaw tolerance analyses to a specific plant. Plant-specific evaluation of these requirements for Byron is provided in Table A-3.
Table A-3 indicates that all plant-specific requirements are met for Byron. Therefore, the results and conclusions of the EPRI report are applicable Byron.
Table A-3 Plant-Specific Applicability of Reference [A5] Representative Analyses to Byron Station, Units 1 and 2 Pressurizer Shell-to-Head Welds (Circumferential and Longitudinal) and Nozzle-to-Shell Welds (Item Numbers B2.11, B2.12, and B3.110)
Requirement from Category                                        Applicability to Byron Station, Units 1 and 2 Reference [A5]
General      The plant-specific           In Appendix C of this proposed alternative, the number Requirements    pressurizer general          and type of the Byron, Units 1 and 2 general transients transients and cycles        are compared to the transients listed in Table 5-6 of must be bounded by           Reference [A5]. As shown in Table C-4, the Byron, Units those shown in Table 5-      1 and 2 transients are bounded by the transients listed 6 for a 60- year             in Table 5-6 of Reference [A5].
operating life. It should be noted that the number of cycles were extrapolated to 80 years in the evaluations.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 37 of 68)
Requirement from Category                                      Applicability to Byron Station, Units 1 and 2 Reference [A5]
The materials of the        The Byron, Units 1 and 2, pressurizer upper and lower pressurizer shell and       heads are fabricated of carbon steel casting SA-533 nozzles must be low         Grade A, Class 2, to meet ASME Nuclear Vessels Code alloy ferritic steels which Section III.
conform to the SA-533 Grade A, Class 2 material is not specifically requirements of ASME listed in ASME Code, Section XI, Appendix G. However, Code, Section XI, SA-533 Grade A, Class 2 material has similar toughness Appendix G, Paragraph and chemical composition to SA-533, Grade B, Class 1, G-2110.
SA-508-1, SA-508-2, and SA-508-3. SA-533 Grade A, Class 2 has a specified minimum yield strength at room temperature of 70 ksi (which is greater than 50 ksi), and the maximum RTNDT values for the Byron pressurizer bottom head materials are 60&deg;F or less (so the RTNDT of 60&deg;F used in the EPRI report is bounding). Appendix G, Table G-2110-1, of the 2019 Edition of ASME Section XI acknowledges that Figure G-2210-1 is applicable to material SA-533 Grade A, Class 2. Therefore, it can be concluded that the EPRI report is applicable to material SA-533 Grade A, Class 2.
Also, material properties in SA-533 Grade A, Class 2 material is identical compared to the SA-533 Grade B Class 1 material used in the FEA in the EPRI report as is shown Table 5-2 of Reference [A5]. Therefore, by comparison, SA-533 Grade A, Class 2 material is consistent with the requirements of ASME Code, Section XI, Appendix G and satisfies the requirements for application of the EPRI report.
The Byron, Units 1 and 2, pressurizer shells are fabricated from SA-533 Grade A, Class 2, material. The Byron, Units 1 and 2 pressurizer Surge, Spray, and Safety-Relief valve nozzles are all fabricated from SA-508, Class 2, material.
The materials for the pressurizer shells conform to the requirements of ASME Code, Section XI, Appendix G, Paragraph G-2110.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 38 of 68)
Requirement from Category                                      Applicability to Byron Station, Units 1 and 2 Reference [A5]
Specific    The plant-specific         The Byron, Units 1 and 2, pressurizer shell-to-head and Requirements  pressurizer surge nozzle   nozzle-to-vessel weld configurations included in this and bottom head weld       request are shown in Figures A-5, A-6, A-7, and A-8 and configurations must        show conformance with the figures shown in Reference conform to those shown     [A5].
in Figure 1-1 (Item No.
B2.11), Figure 1-2 (Item No. B2.12) and Figures 1-4 and 1-5 (Item No.
B3.110) of Reference
[A5].
The plant-specific         The comparison of the Byron, Units 1 and 2, pressurizer dimensions of the          shell dimensions with those in Table 9-1 of Reference pressurizer shell and the  [A5] is provided in Table A-4. The comparison shows surge nozzle must be       that the Byron, Units 1 and 2, configurations are within within the range of        the range of values shown in Table 9-1 of Reference values listed in Table 9-1 [A5].
of Reference [A5].
The plant-specific         In Appendix D of this proposed alternative, the Byron, Insurge/Outsurge           Units 1 and 2, Insurge/Outsurge transients are transient definitions      compared to the number and type of transients listed in (temperature difference    Table 5-10 of Reference [A5]. As can be seen from between the pressurizer    Table D-4, the Byron, Units 1 and 2, transients are shell and the pressurizer  bounded by those transients listed in Table 5-10 of surge nozzle fluid         Reference [A5].
temperature and associated number of cycles) must be bounded by those shown in Table 5-10 for a Westinghouse/CE plant of Reference [A5].

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 39 of 68)
Table A-4 Range of Geometric Parameters for which the Evaluation is Applicable in Comparison with Byron Station, Units 1 and 2 Byron Station, Units 1 Component        Geometric Parameter       For a Westinghouse Plant and 2 Dimensions Pressurizer Inside Diameter (in)    Must be between 80 and 88        84 [A7]
Shell NPS of piping or component (e.g., reducer)
Surge Nozzle                               Must be between 12 and 18        14 [A6]
attached to nozzle safe-end (in)
NPS of piping or Safety/Relief  component (e.g., reducer)
Must be between 4 and 8          6 [A6]
Nozzle        attached to nozzle safe-end (in)
NPS of piping or component (e.g., reducer)
Spray Nozzle                                Must be between 4 and 6          4 [A6]
attached to nozzle safe-end (in)
REFERENCES A5. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to- Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
A6. Westinghouse Electric Corporation Drawing No. 1100J48, Outline: Pressurizer 1800 Cu.
Ft. [50.96].
A7. Westinghouse Electric Corporation Drawing No. 1101J22, General Arrangement:
Pressurizer 1800 Cu. Ft. [50.96].
A8. Byron Station, Drawings 1PZR-1-ISI and 2PZR-1-ISI, Inspection Identification Drawing Inservice Inspection for Pressurizer No. 1RY01S and 2RY01S.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 40 of 68)
Figure A-5: Byron Station, Unit 1 Pressurizer Vessel Weld Locations [A8]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 41 of 68)
Figure A-6: Byron Station, Unit 2 Pressurizer Vessel Weld Locations [A8]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 42 of 68)
Figure A-7: Byron Station, Units 1 and 2 Typical Pressurizer Nozzle-to-Shell Weld Details

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 43 of 68)
Figure A-8: Byron Station, Units 1 and 2 Typical Shell and Head Weld Details [A5]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 44 of 68)
Plant-Specific Applicability for Calvert Cliffs Section 9 of Reference [A9] provides applicability requirements that must be demonstrated in order to apply the representative stress and flaw tolerance analyses to a specific plant. Plant-specific evaluation of these requirements for Calvert Cliffs, Units 1 and 2 is provided in Table A-5.
Table A-5 indicates that all plant-specific requirements are met for Calvert Cliffs, Units 1 and 2.
Therefore, the results and conclusions of the EPRI report are applicable to Calvert Cliffs, Units 1 and 2.
Table A-5 Plant-Specific Applicability of Reference [A9] Representative Analyses to Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Pressurizer Shell-to-Head Welds (Circumferential and Longitudinal) and Nozzle-to-Shell Welds (Item Numbers B2.11, B2.12, and B3.110)
Requirement from Category                                        Applicability to Calvert Cliffs, Units 1 and 2 Reference [A9]
General     The plant-specific           In Appendix C of this proposed alternative, the number Requirements   pressurizer general          and type of the Calvert Cliffs, Units 1 and 2, general transients and cycles        transients are compared to the transients listed in must be bounded by           Table 5-6 of Reference [A9]. As shown in Table C-6, the those shown in Table 5-      Calvert Cliffs, Units 1 and 2, transients are bounded by 6 for a 60- year             the transients listed in Table 5-6 of Reference [A9].
operating life. It should be noted that the number of cycles were extrapolated to 80 years in the evaluations.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 45 of 68)
Requirement from Category                                       Applicability to Calvert Cliffs, Units 1 and 2 Reference [A9]
The materials of the        The Calvert Cliffs, Units 1 and 2, pressurizer upper and pressurizer shell and       lower heads are fabricated of SA-533, Grade B, Class 1, nozzles must be low         to meet ASME Nuclear Vessels Code Section III.
alloy ferritic steels which SA-533, Grade B, Class 1 material is specifically listed conform to the in ASME Code, Section XI, Appendix G. SA-533, Grade requirements of ASME B, Class 1 has a specified minimum yield strength at Code, Section XI, room temperature of 50 ksi, and the RTNDT values for Appendix G, Paragraph the Calvert Cliffs, Units 1 and 2, pressurizer top head G-2110.
materials are not greater than 60&deg;F (so the RTNDT of 60&deg;F used in the EPRI report is bounding).
Also, material properties in SA-533, Grade B, Class 1 material are identical to the material used in the FEA in the EPRI report. Therefore, by comparison, SA-533, Grade B, Class 1 material is consistent with the requirements of ASME Code, Section XI, Appendix G and satisfies the requirements for application of the EPRI report.
The Calvert Cliffs, Units 1 and 2, pressurizer shells are fabricated from SA-533, Grade B, Class 1, material. The Calvert Cliffs, Units 1 and 2, pressurizer Surge, Spray, and Safety-Relief valve nozzles are all fabricated from A-508, Class 2, material.
The materials for the pressurizer shells conform to the requirements of ASME Code, Section XI, Appendix G, Paragraph G-2110.
Specific    The plant-specific          The Calvert Cliffs Units 1 and 2 pressurizer shell-to-Requirements  pressurizer surge nozzle    head and nozzle-to-vessel weld configurations included and bottom head weld        in this request are shown in Figures A-9, A-10, A-11, configurations must         and A-12 and show conformance with the figures shown conform to those shown      in Reference [A9].
in Figure 1-1 (Item No.
B2.11), Figure 1-2 (Item No. B2.12) and Figures 1-4 and 1-5 (Item No.
B3.110) of Reference
[A9].
The plant-specific          The comparison of the Calvert Cliffs Units 1 and 2 dimensions of the           pressurizer shell dimensions with those in Table 9-1 of pressurizer shell and the   Reference [A9] is provided in Table A-6. The surge nozzle must be        comparison shows that the Calvert Cliffs Units 1 and 2 within the range of         configurations are within the range of values shown in values listed in Table 9-1  Table 9-1 of Reference [A9].
of Reference [A9].

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 46 of 68)
Requirement from Category                                     Applicability to Calvert Cliffs, Units 1 and 2 Reference [A9]
The plant-specific        Calvert Cliffs does not track individual thermal transients Insurge/Outsurge          as it is presented in the EPRI Report. Therefore, in transient definitions     Appendix D of this proposed alternative, the Calvert (temperature difference   Cliffs Units 1 and 2 stress-based fatigue monitoring between the pressurizer   values (U and UEN) were projected out to the current shell and the pressurizer end-of-license operating period (60 years) and are surge nozzle fluid        compared to the design limit value of 1.0 as shown in temperature and           Tables D-5 and D-6. As can be seen from Table D-6, associated number of      the Calvert Cliffs Units 1 and 2 fatigue values are well cycles) must be           below the design limits and are satisfactory through 60 bounded by those          years of operation.
shown in Table 5-10 for a Westinghouse/CE plant of Reference [A9].

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 47 of 68)
Table A-6 Range of Geometric Parameters for which the Evaluation is Applicable in Comparison with Calvert Cliffs, Units 1 and 2 Calvert Cliffs Units 1 Component        Geometric Parameter              For a CE Plant and 2 Dimensions Pressurizer Inside Diameter (in)      Must be between 90 and 102        96 [A10]
Shell NPS of piping or component (e.g., reducer)
Surge Nozzle                                Must be between 10 and 14         12 [A11]
attached to nozzle safe-end (in)
NPS of piping or Safety/Relief component (e.g., reducer)
Must be between 4 and 6           4 [A12]
Nozzle       attached to nozzle safe-end (in)
NPS of piping or component (e.g., reducer)
Spray Nozzle                                 Must be between 4 and 6           4 [A12]
attached to nozzle safe-end (in)
REFERENCES A9. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to- Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
A10. Calvert Cliffs, Units 1 and 2, Drawing 12019-0005, 96 I.D. Pressurizer.
A11. Calvert Cliffs, Units 1 and 2, Drawing 12019-0010, Nozzle Details 96 I.D. Pressurizer.
A12. Calvert Cliffs, Units 1 and 2, Drawing 12019-0012, Nozzle Details 96 I.D. Pressurizer.
A13. Calvert Cliffs, Units 1 and 2, ISI Figure A-3.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 48 of 68)
Figure A-9: Calvert Cliffs, Unit 1 Pressurizer Vessel Weld Locations [A13]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 49 of 68)
Figure A-10: Calvert Cliffs, Unit 2 Pressurizer Vessel Weld Locations [A13]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 50 of 68)
Figure A-11: Calvert Cliffs, Units 1 and 2 Typical Pressurizer Nozzle-to-Shell Weld Details [A11 & A12]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 51 of 68)
Figure A-12: Calvert Cliffs, Units 1 and 2 Typical Pressurizer Vessel Shell Weld Details [A10]

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 52 of 68)
APPENDIX B Results of Industry Survey

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 53 of 68)
Overall Industry Inspection Summary The results of an industry survey of past inspections of pressurizer welds are summarized in Reference
[B1]. Table B-1 provides a summary of the combined survey results for Item Numbers B2.11, B2.12, and B3.110. The results identify that pressurizer examination of the items adversely impact outage activities including worker exposure, personnel safety, and radwaste. A total of 47 domestic and international PWR units responded to the survey and provided information representing all PWR plant designs currently in operation in the U.S. This included 2-loop, 3-loop, and 4-loop PWR designs from each of the PWR nuclear steam supply system (NSSS) vendors (i.e., Babcock and Wilcox (B&W), Combustion Engineering (CE), and Westinghouse). A total of 1,128 examinations of components for the three affected Item Numbers included in this proposed alternative were conducted on PWR pressurizer components.
A small number of flaws were identified during these examinations which required flaw evaluation. None of these flaws were found to be service induced. Out of a total of 1,128 examinations identified by the plants that responded to the survey that have been performed on the above item numbers, only four examinations (for Item No. B2.11) at two units of a single plant site identified flaws exceeding the acceptance criteria of ASME Code, Section XI. Flaw evaluations were performed to show acceptability of these indications and follow on examinations showed no change in flaw sizes since the original inspections. No other indications were identified in any in-scope components.
Table B-1 Summary of Survey Results Item No.         No. of Examinations            No. of Reportable Indications B2.11                   269                                   4 (1)
B2.12                   269                                     0 B3.110                  590                                     0 Note:
: 1. Flaw evaluations were performed to show acceptability of these indications and follow on examinations showed no change in flaw sizes since the original inspections.
REFERENCE B1. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 54 of 68)
APPENDIX C Comparison of Braidwood Station, Byron Station, and Calvert Cliffs General Transients to the Transients Evaluated in EPRI Report

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 55 of 68)
Comparison of Braidwood Station, Units 1 and 2 General Transients to the Transients Evaluated in Reference [C1]
Braidwood general transients are tracked by Exelon and the number of cycles encountered as of 2020 for the transients relevant to this request are provided in Table C-1 [C2]. As indicated in Reference [C1], not all the transients tracked by Exelon for Braidwood are required for this request. Table 5-5 of Reference [C1] identified the significant cycles to be used in the evaluation based on expected cycles from a fleet fatigue monitoring review. The Reference
[C1] report considered the heatup/coodown and loss of load. Leakage tests are conducted as an integral part of the plant heatup process; therefore, no additional cycles were included solely for leakage testing. Braidwood would also expect to perform operating leakage testing, instead of hydrostatic testing, following any potential Braidwood Units 1 and 2 pressurizer repairs required by Paragraph IWA-4540(a) of ASME Section XI, in the future. The report considered 300 heatup and cooldown transients for 60 years of operation. The loss of load condition was the most limiting transient, but the cycles were increased to account for other similar events (reactor trip, loss of flow, and loss of power) and thus increased the number of cycles to 360.
For comparison with Table 5-6 of Reference [C1], the actual number of cycles in Table C-1 were projected to 60 years. The comparison of Braidwood general transients to the requirements in Reference [C1] is shown in Table C-2.
Table C-1 Braidwood Station, Units 1 and 2, General Transients Applicable to This Request [C2-C7]
Braidwood Station, Unit 1                Braidwood Station, Unit 2 Maximum                               Maximum Transient Name            Up to     60-Year         Cycles        Up to     60-Year       Cycles 2020     Projected     (Controlling     2020     Projected   (Controlling Limit)                                Limit) 1        RCS Heat Up            40         72             200           43         79           200 2      RCS Cool Down            39         70             200           51         94           200 3   Pressurizer Cooldown        40         72             200           41         75           200 4        Reactor Trips           6         11             230           38         69           230 Reactor Trips 5       w/Subsequent            11         20             160            3          5           160 Cooldown Reactor Trip w/
6                                3          5              10            0          0            10 Subsequent SI 50% Step Load           See                                     See     See Steps See Steps      See Steps                            See Steps 7a, 7   Decrease with Steam Steps 7a,                                   Steps 7a, 7a, 7b, 7c, 7a, 7b, 7c, 7d 7a, 7b, 7c, 7d                          7b, 7c, 7d Dump (See Below) 7b, 7c, 7d                                   7b, 7c, 7d     7d 7a     Unload @5%/min           104         187           12240          86        158          13200

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 56 of 68)
Braidwood Station, Unit 1              Braidwood Station, Unit 2 Maximum                                Maximum Transient Name            Up to      60-Year       Cycles       Up to    60-Year         Cycles 2020      Projected   (Controlling    2020    Projected     (Controlling Limit)                                 Limit)
Step Load 10%
7b                               3           5           2000          5           9            2000 Decrease Unloading, 15%-0%
7c                              17          31            500         15          28             500 Power Large Step Load 7d                               2           4            200          1           2             200 Decrease 8        Loss of Load           1           2            80           1           2             80 Loss of Offsite AC 9                               1           2            40           2           4             40 Power See                                   See Loss of Flow in One RC               See Steps    See Steps              See Steps    See Steps 10a, 10                             Steps                                 Steps Loop Only (BRW below)                 10a, 10b     10a, 10b               10a, 10b           10b 10a, 10b                              10a, 10b 10a    Partial Loss of Flow       1           2            80           1           2             80 10b Complete Loss of Flow         0           0             5           1           2              5 Note:
: 1. Allowable limits and totals are from the Braidwood, Unit 1 and 2, Fatigue Monitoring Reports (December 2020) Work Orders 05107062 and 05107063 (Procedure BwVP 850-7).
: 2. 60-year projection is based on Braidwood, Unit 1 and 2, Semi-Annual Fatigue Monitoring Report (January 2021) under Work Orders 05064062 and 05064063.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 57 of 68)
Table C-2 Comparison of Braidwood Station, Units 1 and 2, General Transients to the Transients Evaluated in Reference [C1]
Number of        Braidwood Station,  Braidwood Station, Cycles for 60        Unit 1 60-Year      Unit 2 60-Year Transient              Years from        Projections from    Projections from Reference [C1]          Table C-1           Table C-1 Heatup / Cooldown             300                    72                  94 Loss of Load (Sum of Reactor Trips, 50%
Step Load Decrease with Steam Dump, Loss of Load,          360                   269                 281 Loss of Flow in One RC Loop Only, and Loss of Offsite AC Power Events)
REFERENCES C1. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
C2. Braidwood Station, Unit 1, December Fatigue Monitoring Report (Monthly), Work Order 05107062.
C3. Braidwood Station, Unit 2, December Fatigue Monitoring Report (Monthly), Work Order 05107063.
C4. Braidwood Station, Unit 1, Semi-Annual Report (January), Work Order 05064063.
C5. Braidwood Station, Unit 2, Semi-Annual Report (January), Work Order 05064062.
C6. Procedure BwVP 850-7, Operational Transient Cycle Counting.
C7. WCAP-15966, Evaluation of Pressurizer Insurge / Outsurge Transients for Byron and Braidwood, 2002.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 58 of 68)
Comparison of Byron Station, Units 1 and 2, General Transients to the Transients Evaluated in Reference [C8]
Byron general transients are tracked by Exelon and the number of cycles encountered as of 2020 for the transients relevant to this request are provided in Table C-3 [C9]. As indicated in Reference [C8], not all the transients tracked by Exelon for Byron are required for this request.
Table 5-5 of Reference [C8] identified the significant cycles to be used in the evaluation based on expected cycles from a fleet fatigue monitoring review. The Reference [C8] report considered the heatup/coodown and loss of load. Leakage tests are conducted as an integral part of the plant heatup process; therefore, no additional cycles were included solely for leakage testing. Byron would also expect to perform operating leakage testing, instead of hydrostatic testing, following any potential Byron Units 1 and 2 pressurizer repairs, required by Paragraph IWA-4540(a) of ASME Section XI, in the future. The report considered 300 heatup and cooldown transients for 60 years of operation. The loss of load condition was the most limiting transient, but the cycles were increased to account for other similar events (reactor trip, loss of flow, and loss of power) and thus increased the number of cycles to 360.
For comparison with Table 5-6 of Reference [C8], the actual number of cycles in Table C-3 were projected to 60 years. The comparison of Byron general transients to the requirements in Reference [C8] is shown in Table C-4.
Table C-3 Byron Station, Units 1 and 2, General Transients Applicable to This Request [C9]
Byron Station, Unit 1                   Byron Station, Unit 2 Maximum                                Maximum Cycles                                 Cycles Transient Name             Up to      60-Year                      Up to      60-Year (Controlling                            (Controlling 2020      Projected                     2020      Projected Limit)                                  Limit)
Heat Up@ <100&deg;F/hr             38          66            200           34          62            200 Cooldown@ <100&deg;F/hr             38          66            200           34          62            200 Reactor Trips              5           9             230            7          13            230 50% Step Load Decrease 2           4             200            3           6            200 with Steam Dump Loss of Load              3           6              80            1           2             80 Loss of Flow in One RC 0           0              80            0           0             80 Loop Only Loss of Offsite AC Power          1           2              40            3           6             40 Note:
: 1. Allowable limits and totals are from the Byron, Unit 1 and 2, Annual Fatigue Monitoring Report (2020),
EC 633359, Revision 0.
: 2. 60-year projection is based on Byron, Unit 1 and 2, Annual Fatigue Monitoring Report (2020), EC 633359, Revision 0.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 59 of 68)
Table C-4 Comparison of Byron Station, Units 1 and 2, General Transients to the Transients Evaluated in Reference [C8]
Number of        Byron Station, Unit  Byron Station, Unit Cycles for 60          1 60-Year            2 60-Year Transient             Years from        Projections from      Projections from Reference [C8]          Table C-3            Table C-3 Heatup / Cooldown             300                   66                    62 Loss of Load (Sum of Reactor Trips, 50%
Step Load Decrease with Steam Dump, Loss of Load,         360                   21                    27 Loss of Flow in One RC Loop Only, and Loss of Offsite AC Power Events)
REFERENCES C8. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
C9. EC 633359, Revision 0, Annual Fatigue Monitoring Report 2020 Unit 1 & Unit 2.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 60 of 68)
Comparison of Calvert Cliffs, Units 1 and 2 General Transients to the Transients Evaluated in Reference [C10]
Calvert Cliffs general transients are tracked by Exelon and the number of cycles encountered as of 2018 for the transients relevant to this request are provided in Table C-5 [C11]. As indicated in Reference [C10], not all the transients tracked by Exelon for Calvert Cliffs are required for this request. Table 5-5 of Reference [C10] identified the significant cycles to be used in the evaluation based on expected cycles from a fleet fatigue monitoring review. The Reference [C10] report considered the heatup/coodown and loss of load. Leakage tests are conducted as an integral part of the plant heatup process; therefore, no additional cycles were included solely for leakage testing.
Calvert Cliffs would also expect to perform operating leakage testing, instead of hydrostatic testing, following any potential Calvert Cliffs Units 1 and 2 pressurizer repairs, required by Paragraph IWA-4540(a) of ASME Section XI, in the future. The report considered 300 heatup and cooldown transients for 60 years of operation. The loss of load condition was the most limiting transient, but the cycles were increased to account for other similar events (reactor trip, loss of flow, and loss of power) and thus increased the number of cycles to 360.
For comparison with Table 5-6 of Reference [C10], the actual number of cycles in Table C-5 were projected to 60 years. The comparison of Calvert Cliffs general transients to the requirements in Reference [C10] is shown in Table C-6.
Table C-5 Calvert Cliffs, Units 1 and 2, General Transients Applicable to This Request [C11]
Calvert Cliffs, Unit 1                         Calvert Cliffs, Unit 2 Maximum                                         Maximum Cycles                                          Cycles Transient Name              Up to        60-Year                            Up to        60-Year (Controlling                                   (Controlling 2018       Projected                            2018      Projected Limit)                                         Limit)
Pressurizer Heat Up            121           152                500             93          120                500 Pressurizer Cooldown            120           149                500             91          117                500 Reactor Trips               134          171(2)              164            112          147                164 Plant Loading 15-100%            107           146               6150             90          123                6150 Power Plant Unloading 100%-15%            101           137               6150             84          114                6150 Power Loss of Load                 2             6                  40              2            6                 40 Partial Loss of RCS Flow          10            12                  40              9           12                 40 Loss of Offsite AC Power(1)        NA            NA                  NA            NA            NA                 NA Step Load Decrease 10%            378           457                820            289          360                820 Step Load Increase 10%            382           468                820            279          344                820 Note:
: 1.       Loss of Offsite AC power is not a transient that is required to be analyzed as part of the Calvert Cliffs design basis transients.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 61 of 68)
: 2. The Reactor Trips Transient for Unit 1 is projected to exceed the design allowable number of cycles for 60-Years.
While the number of this one transient exceeds the allowable number of transient cycles, the 2018 fatigue analysis determined the fatigue usage still remains below the allowable value of 1.0. All locations monitored for fatigue are currently below the design allowable limit of 1.0 and are projected to remain below the design allowable limit of 1.0 through 60 years of operation.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 62 of 68)
Table C-6 Comparison of Calvert Cliffs, Units 1 and 2, General Transients to the Transients Evaluated in Reference [C10]
Number of Calvert Cliffs, Unit 1 Calvert Cliffs, Unit 2 Cycles for 60 60-Year Projections    60-Year Projections Transient             Years from from Table C-5        from Table C-5 Reference [C10]
Heatup / Cooldown              300                152/149                120/117 Loss of Load (Sum of Reactor Trips, 50%
Step Load Decrease with Steam Dump, Loss of Load,          360                   189                   165 Loss of Flow in One RC Loop Only, and Loss of Offsite AC Power Events)
REFERENCES C10. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
C11. ECP-18-000545, Fatigue Plant Transient Review.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 63 of 68)
APPENDIX D Comparison of Braidwood Station, Byron Station, and Calvert Cliffs Insurge/Outsurge Transients to the Insurge/Outsurge Transients Evaluated EPRI Report

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 64 of 68)
Comparison of Braidwood Station, Units 1 and 2, Insurge/Outsurge Transients to the Insurge/Outsurge Transients Evaluated in Reference [D1]
Braidwood Insurge/Outsurge transients are provided in Table D-1 [D2-D7]. The temperature differences (Ts) identified in Table D-1 are combined conservatively by summing all the events into the 320&deg;F T bin. It should be noted that the transients in Table D-1 reflect 40 years of operation, so for comparison with Table 5-10 of Reference [D1], they are extrapolated to 60 years by multiplying by 1.5. With this conservative treatment of the Insurge/Outsurge transients, the comparison of Braidwood Insurge/Outsurge transients to the requirements in Reference [D1] is shown in Table D-2. The results of Table D-2 indicate that the Braidwood Insurge/Outsurge transients are bounded by those in Reference
[D1].
Table D-1 40-Year Insurge/Outsurge Transients for Braidwood Station, Units 1 and 2 [D2-D7]
Unit 1                                Unit 2 No.          Transient Name (1,2,3)
Up to 60-Year           Allowable        Up to 60-Year Allowable 2020 Projected              Limit        2020 Projected        Limit
[D2]     [D4](5)           [D7](4)      [D3]     [D5](5)     [D7](4) 1       PZR I/O SURGE MOPHU320                  4          10              56           4         10          56 2       PZR I/O SURGE MOPHU300                  2           5              20           0          0          20 3       PZR I/O SURGE MOPHU280                  3           8              21           0          0          21 4       PZR I/O SURGE MOPHU270                  9          23              70           6         16          70 5       PZR I/O SURGE MOPCD320                  0           0              41           0          0          41 6       PZR I/O SURGE MOPCD310                  0           0              15           0          0          15 7       PZR I/O SURGE MOPCD300                  1           3              20           2          5          20 8       PZR I/O SURGE MOPCD270                  1           3              76           0          0          76 (6) 9       PZR I/O SURGE MOPCD250                  4          10              15           8        21           15 Notes:
: 1. The Transient Name is MOPXXnnn, where MOP = post Modified Operating Procedures, XX = HU for insurge/outsurge transients that occur during Heatup events, or CD for insurge/outsurge transients that occur during Cooldown events, and nnn = temperature difference, delta T, between the RCS piping at the beginning of the transient and pressurizer temperature at the end of the transient
: 2. Insurge/Outsurge determination is based on WCAP-15966
: 3. Braidwood does not explicitly monitor the breakdown of the transients shown in this table. Rather, the number of cycles shown in this table were used in the governing fatigue evaluations for the pressurizer surge nozzles.
Braidwood does NOT currently monitor the environmental fatigue usage factor for the surge nozzle but is expected to do so with implementation of WESTEMs as part of license renewal commitments for the station.
: 4. Per Note 2 (WCAP-15966) the allowable insurge/outsurge numbers were used to evaluate the stresses for Braidwood. As such, these numbers are the same for 40 years and 60 years.
: 5. 60-year projection is based on Braidwood, Unit 1 and 2, Semi-Annual Fatigue Monitoring Report (January 2021) under Work Orders 05064062 and 05064063.
: 6. In Reference [D5], PZR I/O SURGE MOPCD250 was identified as reaching 53.33% of the allowable limit for Unit 2, and was projected to exceed the allowable limit in 2033. This projection is skewed based on the occurrences in 2008 and 2009, when three of the events occurred during a refueling outage cool down. Except for one event in 2014 during the A2R17 refueling outage, there have been zero occurrences of the PZR I/O SURGE MOPCD250 events between 2010 and 2020. Based on the latest trend, the 60-Year Projected count should decrease as the plant reaches its PEO and the projected year to reach the limit will continue to increase beyond 2033.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 65 of 68)
Table D-2 Comparison of Braidwood Station, Units 1 and 2, Insurge/Outsurge Transient Temperature Differences and Numbers of Cycles with the Insurge/Outsurge Transient Date from Reference [D1]
60-Year No. of                                           Braidwood Station, Braidwood Station, Unit Cycles                                                    Unit 2 Cycles 1 Cycles Projected to 60 T (oF)(1)       From Reference                                            Projected to 60 Years Years of Operation
[D1]                                                    of Operation 330                 600                            0                                0 320                3,000                          62                               52 103                1,500                           0                                0 Notes:
: 1. T is the temperature difference between the pressurizer fluid temperature and the fluid temperature in the surge nozzle.
REFERENCES D1. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
D2. Braidwood Station, Unit 1, December Fatigue Monitoring Report (Monthly), Work Order 05107062.
D3. Braidwood Station, Unit 2, December Fatigue Monitoring Report (Monthly), Work Order 05107063.
D4. Braidwood Station, Unit 1, Semi-Annual Report (January), Work Order 05064063.
D5. Braidwood Station, Unit 2, Semi-Annual Report (January), Work Order 05064062.
D6. Procedure BwVP 850-7, Operational Transient Cycle Counting.
D7. WCAP-15966, Evaluation of Pressurizer Insurge / Outsurge Transients for Byron and Braidwood, 2002.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 66 of 68)
Comparison of Byron Station, Units 1 and 2, Insurge/Outsurge Transients to the Insurge/Outsurge Transients Evaluated in Reference [D8]
Byron Insurge/Outsurge transients are provided in Table D-3 [D9-D14]. The temperature differences (Ts) identified in Table D-3 are combined conservatively by summing all the events into the 320&deg;F T bin. It should be noted that the transients in Table D-3 reflect 40 years of operation, so for comparison with Table 5-10 of Reference [D8], they are extrapolated to 60 years by multiplying by 1.5. With this conservative treatment of the Insurge/Outsurge transients, the comparison of Byron Insurge/Outsurge transients to the requirements in Reference [D8] is shown in Table D-4. The results of Table D-4 indicate that the Byron Insurge/Outsurge transients are bounded by those in Reference [D8].
Table D-3 40-Year Insurge/Outsurge Transients for Byron Station, Units 1 and 2 [D9-D14]
WCAP-                       Unit 1                                  Unit 2 No.       Transient Name (1,2) 15966 Past       Up to                    Allowable       Up to                 Allowable 60-Year                                  60-Year Total        2020                        Limit       2020                     Limit Projected(3)                             Projected(3)
Count      [D11](2)                     [D10](4)    [D11](2)                 [D10](4)
[D10]
1    PZR I/O Surge-MOPHU320             10            3          20              35            3          20           35 2    PZR I/O Surge-MOPHU310              5            0           5              17            0           5           17 3    PZR I/O Surge-MOPHU300              5            1           9              17            1           9           17 4    PZR I/O Surge-MOPHU280             15            0          15              52            1          19           52 5    PZR I/O Surge-MOPHU270             12            2          19              42            0          12           42 6    PZR I/O Surge-MOPHU250             11            8          36              37           10          44           37 7    PZR I/O Surge-MOPCD320              7            0           7              24            1          11           24 8    PZR I/O Surge-MOPCD310              9            0           9              31            0           9           31 9    PZR I/O Surge-MOPCD300              9            0           9              31            0           9           31 10 PZR I/O Surge-MOPCD290                11            0          11              38            0          11           38 11 PZR I/O Surge-MOPCD280                 4            0           4              14            0           4           14 12 PZR I/O Surge-MOPCD270                11            0          11              38            1          15           38 13 PZR I/O Surge-MOPCD250                 7            3          17              24            6          27           24 Notes:
: 1. The Transient Name is PZR I/O Surge-MOP XX nnn, where XX = HU for insurge/outsurge transients that occur during Heatup events, or CD for insurge/outsurge transients that occur during Cooldown events, and nnn = the temperature difference, T, between the pressurizer fluid temperature and the fluid temperature in the surge nozzle.
: 2. Byron has explicitly monitored the breakdown of the transients shown in this table since May 2008, when BVP 900-3, Revision 6 [D11] was issued. This monitoring was implemented to confirm the MOP strategies recommended in WCAP-14950 [D14] are effective and to ensure that the projections in WCAP-15966 [D10] remain bounding.
: 3. The projection for the number of Insurge/Outsurge Transients over 60 years of operation is equal to the sum of the conservatively estimated past events as documented in WCAP-15966 [D10] and the number of events recorded between 2008 and 2020 [D9] increased to assume the same rate of occurrence until the end of the 60 year operating period.
: 4. The Allowable Limit is the sum of the conservatively estimated past events as documented in WCAP-15966 [D10] and the projected number of future MOP Heatup/Cooldown events assumed in WCAP-15966 [D10].

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 67 of 68)
Table D-4 Comparison of Byron Station, Units 1 and 2, Insurge/Outsurge Transient Temperature Differences and Numbers of Cycles with the Insurge/Outsurge Transient Date from Reference
[D8]
Byron Unit 1             Byron Unit 2 o   (1) 60-Year No. of         Cycles Projected         Cycles Projected T ( F)        Cycles from             to 60 Years of           to 60 Years of Reference [D8]             Operation                Operation (2)                       (2) 330                600                    27                        31 (3)                       (3) 320              3,000                    172                      195 (4)                       (4) 103              1,500                    53                        71 Notes:
: 1. T is the temperature difference between the pressurizer fluid temperature and the fluid temperature in the surge nozzle.
: 2. Byron has an administrative limit of 320&deg;F on system T. WCAP-15966 [D10] did identify a small number of events that exceeded 320&deg;F on system T and assumed those events to be 320&deg;F for the purposes of developing the system T distribution in the analysis. Based on this precedence, the number of cycles at T = 330&deg;F is conservatively considered to be equal to sum of all heatup and cooldown events in Table D-3 for T = 320&deg;F, since Byron does not specifically monitor for transients with a temperature difference of 330&deg;F.
: 3. The number of cycles at T = 320&deg;F is conservatively considered to be equal to sum of all events in Table D-3.
: 4. The number of cycles at T = 103&deg;F is conservatively considered to be equal to sum of the heatup and cooldown events in Table D-3 for T = 250&deg;F, since Byron does not specifically monitor for transients with a temperature difference of 103&deg;F. Byron does count any event with T >80&deg;F and 250&deg;F in as applicable 250&deg;F surge condition.
Therefore, the number of events in Table D-3 for T = 250&deg;F is conservatively bounding.
REFERENCES D8. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
D9. EC 633359, Revision 0, Annual Fatigue Monitoring Report 2020 Unit 1 & Unit 2.
D10. WCAP-15966, Evaluation of Pressurizer Insurge/Outsurge Transients for Byron and Braidwood, Rev. 0, dated December 2002.
D11. BVP 900-3, Documentation of Operating Plant/Component Cyclic or Transient Events, Rev.
6, issued May 9, 2008.
D12. BVP 900-3, Documentation of Operating Plant/Component Cyclic or Transient Events, Rev.
8 (current revision), issued February 27, 2012.
D13. Exelon Procedure ER-AA-470, Fatigue and Transient Monitoring Program, Rev. 8, issued January 30, 2019.
D14. WCAP-14950, Mitigation and Evaluation of Pressurizer Insurge/Outsurge Transients, February 1998.

10 CFR 50.55a Proposed Alternative I4R-15 for Braidwood Station, Units 1 and 2, Proposed Alternative I4R-21 for Byron Station, Units 1 and 2, and Proposed Alternative ISI-05-016 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Revision 0 (Page 68 of 68)
Comparison of Calvert Cliffs, Units 1 and 2 Insurge/Outsurge Transients to the Insurge/Outsurge Transients Evaluated in Reference [D15]
Calvert Cliffs does not track individual thermal transients as it is presented in the EPRI Report. Instead, the plant performs stress-based fatigue monitoring for the relevant surge nozzle locations that tracks Fatigue Usage (U) and Environmental Assisted Fatigue Usage (UEN) values to ensure they remain below the allowable value of 1.0 as shown in Tables D-5 and D-6 [D16]. As a result, instead of tabulated transients, the current U and UEN estimates are provided for the subject welds for Calvert Cliffs and their projections out to the current end-of-license operating period (60 years). The results of Table D-5 and D-6 indicate that the actual Calvert Cliffs fatigue values are well below the design limits and are satisfactory through 60 years of operation.
Table D-5 General Transients Fatigue Usage (U) Summary Report for Calvert Cliffs, Units 1 and 2 [D16]
Unit 1                                            Unit 2 U                 U                               U                   U Pressurizer         U                                                 U 60-Year          Maximum                          60-Year            Maximum Locations       Up to                                             Up to Projected           Cycles                        Projected            Cycles 12/2018                                           12/2018 (7/21/2034) (Design Limit)                        (7/21/2034)       (Design Limit)
Lower Head        0.1853         0.221               1.0            0.1168         0.151                 1.0 Surge Nozzle      0.0173         0.019               1.0            0.0746         0.093                 1.0 Notes:
: 1. The U values projected out to 60 years is calculated with the Fatigue Pro Software utilized by Calvert Cliffs.
Table D-6 General Transients Environmental Assisted Fatigue Usage (UEN) Summary Report for Calvert Cliffs, Units 1 and 2 [D15]
Unit 1                                            Unit 2 Pressurizer                     UEN                UEN                            UEN                 UEN UEN                                               UEN 60-Year          Maximum                          60-Year            Maximum Locations       Up to                                             Up to Projected           Cycles                        Projected            Cycles 12/2018                                           12/2018 (7/21/2034) (Design Limit)                        (7/21/2034)       (Design Limit)
Lower Head        0.4548         0.543               1.0            0.5287         0.685                 1.0 Surge Nozzle      0.0876         0.096               1.0            0.3806         0.495                 1.0 Notes:
: 1. The UEN values projected out to 60 years is calculated with the Fatigue Pro Software utilized by Calvert Cliffs.
REFERENCES D15. Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell-to-Head and Nozzle-to-Vessel Welds. EPRI, Palo Alto, CA: 2019. 3002015905, ADAMS Accession No. ML21021A271.
D16. ECP-18-000545, Fatigue Plant Transient Review.}}