ML14183B230

June 24, 2014, Summary of Telephone Conference Call Held Between the U.S. NRC and Exelon Generation Co., LLC, Concerning Draft Request for Additional Information, Set 36, Pertaining to the Byron Station and Braidwood Station, License Renewa

ML14183B230
Person / Time
Site:	Byron, Braidwood
Issue date:	07/07/2014
From:	Robinson L License Renewal Projects Branch 1
To:
Robinson L, 415-4115
References
TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882
Download: ML14183B230 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 7, 2014 LICENSEE: Exelon Generation Company, LLC FACILITY: Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JUNE 24, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 36, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION (TAC NOS. MF1879, MF1880, MF1881, MF1882)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC (Exelon or the applicant), held a telephone conference call on June 24, 2014, to discuss and clarify the staffs draft request for additional information (DRAI),

Set 36, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs DRAIs. provides a listing of the participants, and Enclosure 2 contains a listing of the DRAIs discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/RA/

Lindsay Robinson, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-454, 50-455, 50-456, and 50-457

Enclosures:

1. List of Participants

2. List of Draft Request for Additional Information cc w/encls: Listserv

ML14183B230 *concurred via email OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds LRobinson YDiazSanabria LRobinson DATE 07/2/14 07/7/14 07/7/14 07/7/14

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JUNE 24, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 36, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION (TAC NOS. MF1879, MF1880, MF1881, MF1882)

DISTRIBUTION EMAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsOgcMailCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource

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LRobinson DMcIntyre, OPA EDuncan, RIII JBenjamin, RIII AGarmoe, RIII JMcGhee, RIII JRobbins, RIII VMitlyng, RIII PChandrathil, RIII

TELEPHONE CONFERENCE CALL BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS June 24, 2014 PARTICIPANTS AFFILIATIONS Lindsay Robinson U.S. Nuclear Regulatory Commission (NRC)

Allen Hiser NRC Seung Min NRC Aloysius Obodoako NRC John Hufnagel Exelon Generating Company, LLC (Exelon)

Al Fulvio Exelon Don Warfel Exelon Pete Tamburro Exelon Gary Becknell Exelon Don Brindle Exelon Ralph Wolen Exelon ENCLOSURE 1

DRAFT REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION June 24, 2014 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC (Exelon or the applicant), held a telephone conference call on June 24, 2014, to discuss and clarify the following draft request for additional information (DRAI), Set 36, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application (LRA).

DRAI 3.1.2.3.4-1a Applicability:

Byron Station (Byron) and Braidwood Station (Braidwood), Unit 1

Background:

By letter date May 12, 2014, the applicant responded to request for additional information (RAI) 3.1.2.3.4-1 which addressed loss of fracture toughness in Byron and Braidwood, Unit 1 steam generator internal structural supports. In its response, the applicant revised license renewal application Table 3.1.2-4 by deleting the aging management review (AMR) line item which manages loss of fracture toughness for Byron and Braidwood, Unit 1 steam generator tube support lattice bar attachment components made of cast austenitic stainless steel (CASS). The deleted AMR line item indicated that these CASS components are exposed to treated water greater than 482 degrees Fahrenheit and may experience loss of fracture toughness due to thermal aging embrittlement. Byron and Braidwood manage both by the Steam Generators program.

The applicant further stated that loss of fracture toughness due to thermal aging embrittlement is not applicable to these steam generator CASS internal components (i.e., internal supports and structures and tube support plates and U-bend supports). The applicant reviewed the Grimes letter to Walters on License Renewal Issue No. 98-0030, Thermal Aging Embrittlement of Cast Stainless Steel Components, dated May 19, 2000, (ADAMS Accession Number ML003717179) and provided the following justification for excluding the steam generator tube support lattice bar attachment components, fabricated from SA-351 CF3M CASS, from being susceptible to thermal aging embrittlement.

The concern associated with thermal aging embrittlement is the reduction in fracture toughness of a component at low temperatures (i.e., room temperature) and the potential for non-ductile failure at low temperatures. The material properties at high temperature are not affected.

Therefore, fracture of a CASS component is not expected at low temperatures. Since the loading on the CASS components at low temperature is negligible, the possibility that loss of fracture toughness would render the component incapable of performing its function without showing any visual evidence of cracking, deformation, or damage is also negligible.

The staff reviewed the Grimes letter, dated May 19, 2000, and notes that it states that aging of CASS at reactor operating temperatures of 280-350 degrees Celsius (536-662 degrees ENCLOSURE 2

Fahrenheit) can lead to changes in the mechanical properties of these materials, depending on the characteristics of the material and the environment to which the component is exposed.

The effects of thermal aging on materials include increases in the tensile strength, hardness, and Charpy impact energy transition temperature, as well as decreases in ductility, fracture toughness, and impact strength.

Further, NUREG/CR-6923, Expert Panel Report on Proactive Materials Degradation Assessment February 2007, states that:

Thermal aging of CASS at boiling water reactor and pressurized water reactor operating temperatures is characterized by an increase in hardness and tensile strength and a decrease in ductility, impact strength and toughness. In addition, the "brittle-ductile" transition temperature increases and the upper shelf decreases (emphasis added).

The upper shelf decrease described in NUREG/CR-6923 relates directly to behavior of CASS at operating temperatures, contrary to the assertion in the RAI response that the concerns with thermal aging embrittlement only apply at low temperatures.

As cited in the Grimes letter, thermal aging of CASS results in reduced toughness, which means that the aged CASS component can tolerate smaller flaw sizes. Since the toughness of CASS is not directly measureable, the Grimes letter and the Generic Aging Lessons Learned (GALL)

Report cite that thermal aging of CASS can be appropriately managed by inspections to demonstrate that flaws of a potentially critical size are not present in the CASS component.

In addition, GALL Report AMP XI.M12 states that for high-molybdenum content steels (SA-351 Grades CF3M, CF3MA, and CF8M or other steels with 2.0 to 3.0 wt. percent Mo), static-cast steels with >14 percent ferrite and centrifugal-cast steels with >20 percent ferrite are potentially susceptible to thermal embrittlement. Static-cast high-molybdenum steels with 14 percent ferrite and centrifugal-cast high-molybdenum steels with 20 percent ferrite are not susceptible.

Issue:

Thermal aging embrittlement of CASS may result in reduction in fracture toughness of a component at operating conditions (i.e., 536-662 degrees Fahrenheit), contrary to the assertion in the RAI response that it only applies at low temperatures. The reduction in fracture toughness of CASS requires adequate aging management.

Request:

1. Please provide the composition, ferrite content, and the fabrication method to determine if the SA-351 CF3M CASS components are susceptible to thermal aging embrittlement in accordance with the guidance of aging management program (AMP) XI.M12. If so, a) Justify the assertion in the response to RAI 3.1.2.3.4-1 that the concern associated with thermal aging embrittlement is a reduction in fracture toughness and a potential for non-ductile failure at low temperatures (i.e., room temperature).

b) Discuss how the proposed examinations will be adequate to provide assurance that the CASS components will not have flaws that could either (a) challenge the ability of the component to perform its intended safety function during normal operation,

transient, and accident conditions; or (b) result in the generation of loose parts that could adversely affect the performance of other parts of the steam generator or downstream components.

Discussion: The applicant requested clarification on the staffs concern. No edits were made to this request. This question will be sent as a formal request titled: RAI 3.1.2.3.4-1a.