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| number = ML11266A003
| number = ML11266A003
| issue date = 09/22/2011
| issue date = 09/22/2011
| title = 2011/09/22 NRR E-mail Capture - Draft RAI Braidwood - Relief Request I3R-08 (TAC Nos. ME6024 & ME6025)
| title = NRR E-mail Capture - Draft RAI Braidwood - Relief Request I3R-08 (TAC Nos. ME6024 & ME6025)
| author name = DiFrancesco N
| author name = Difrancesco N
| author affiliation = NRC/NRR/DORL
| author affiliation = NRC/NRR/DORL
| addressee name = Schofield L
| addressee name = Schofield L
Line 14: Line 14:
| page count = 3
| page count = 3
| project = TAC:ME6024, TAC:ME6025
| project = TAC:ME6024, TAC:ME6025
| stage = RAI
| stage = Draft RAI
}}
}}


=Text=
=Text=
{{#Wiki_filter:1NRR-PMDAPEm ResourceFrom:DiFrancesco, NicholasSent:Thursday, September 22, 2011 2:27 PMTo:Lisa.Schofield@exeloncorp.comCc:david.gullott@exeloncorp.com; Zimmerman, Jacob; Mahoney, MichaelSubject:DRAFT RAI Braidwood - Relief Request I3R-08 (TAC NOs. ME6024 & ME6024)Lisa, Below are the draft RAI questions for the Braidwood Relief Request I3R-08. The draft RAIs have been provided to support RAI clarification discussion scheduled for September 27 and to establish a response date. Sincerely,  Nick  Project Manager  - Braidwood, Byron, and Clinton  U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing nicholas.difrancesco@nrc.gov l Tel: (301) 415-1115 DRAFT  REQUEST FOR ADDITIONAL INFORMATION  BRAIDWOOD STATION, UNITS 1 AND 2  REGARDING REQUEST FOR RELIEF I3R-08  DOCKET NOS. STN 50-456 AND STN 50-457 TAC NOS. ME6024 AND ME6025  By letters dated April 11, 2011 and June 6, 2011, (Agencywide Documents Access & Management System (ADAMS) Accession Numbers ML111020263 and ML111580106 respectively), Exelon Generation Company, LLC, (Licensee) submitted request for relief, I3R-08, from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at Braidwood Station, Units 1 and 2. Specifically, the licensee proposed using root mean square error (RMSE) criteria for sizing flaws that are greater than the requirements of ASME Code Case N-695, AQualification Requirements for Dissimilar Metal Piping Welds," and N-696, "Qualification Requirements for Appendix VIII Piping Examinations Conducted From the Inside Surface". To complete the review, the NRC staff requests the following additional information supporting the licensee's request.
{{#Wiki_filter:NRR-PMDAPEm Resource From:                       DiFrancesco, Nicholas Sent:                       Thursday, September 22, 2011 2:27 PM To:                         Lisa.Schofield@exeloncorp.com Cc:                         david.gullott@exeloncorp.com; Zimmerman, Jacob; Mahoney, Michael
1. The large differences in RMSE between non-Appendix VIII DMWs, Appendix VIII DMWs, and Appendix VIII austenitic-to-austenitic welds are influenced by changes to the surface conditions in the test mockups used to demonstrate capability, effectiveness, and skill. Unless the surface conditions of the field welds are exactly the same as test mockups, the applicability of a specific RMSE value may not be appropriate. Correlations between the essential variable "surface preparation" and RMSE values have not been developed. Therefore, the "best effort' RMSE values assigned by the Electric Power Research Institute (EPRI) - Performance Demonstration Initiative (PDI), which are referenced in the submittal for 2DMW and austenitic-to-austenitic welds, may not be appropriate depending on the relationship of RMSE and actual surface preparations (conditions). In the absence of any correlation between RMSE and surface conditions, the "best effort" PDI RMSE values are questionable with respect to reliability, reproducibility, and applicability to actual depth sizing of cracks identified during an examination. Provide a discussion on the following two probe-to-component surface contact conditions:  a. Based on the non-Appendix VIII vendor performance demonstrations performed on surfaces that are capable of maintaining good probe-to-component surface (defined by the EPRI Performance Demonstration Initiative as 1/32-inch gap or less) contact, the vendor's RMSE data suggest a reasonable probability of reproducibility. For surface conditions similar to those associated with the non-Appendix VIII performance demonstration, discuss a conservative approach for using RMSE values that would apply to both DMWs and austenitic-to-austenitic welds, i.e., one "best effort" RMSE value. b. In examinations performed during the last 10-year inservice inspection (ISI) interval, the licensee's vendor recorded no flaw (crack) indications for the subject welds. These examinations were performed with a combination of ultrasonic testing (UT) and eddy current testing (ET) methods. For upcoming examinations, any cracks that are detected would have occurred between the last ISI examination and upcoming examination. The most likely cracking mechanism (identified in the licensee's risk-informed program) is primary water stress corrosion cracks (PWSCC). In the event that the UT or ET examination detected PWSCC, UT depth sizing performed on surfaces exhibiting gaps greater than 1/32-inch between probe and component surface may be less conservative than the proposed alternative in 1a, above. Because sizing accuracy is unknown for gaps greater that 1/32-inch, the application of RMSE as a tolerance to adjust crack depth is questionable. As an alternative to the adjustment approach, cracks that are depth sized on rough surfaces may be bounded by calculating crack growth from the last crack free examination. For calculating purposes, the initial (at the time of the crack free examination) crack depth should be assumed 5-percent through-wall (the smallest crack size that may be in a performance demonstration test). For PWSCC, the bounding crack depth can be calculated using the guidance provided in the EPRI - Materials Reliability Program (MRP) MRP-115, MRP-252, and/or MRP-287, as appropriate, for representative DMW and austenitic-to-austenitic welds. Provide a discussion on the disposition of cracks as determine by calculating the maximum through-wall crack depth and identify the associated assumptions, if any. 2. The vendor participated in three non-PDI performance demonstrations on mockups with smooth ID surfaces (probe-to-component surface gaps of less than or equal to 1/32-inch). Each of the demonstrations used UT procedures and equipment nearly identical to those to be applied in the upcoming Braidwood 1 & 2 examinations. The personnel performing the Appendix VIII examinations are required to be qualified on the specific UT procedure that will be used for the examinations. Please provide a discussion on the participation in the non-PDI performance demonstrations of the UT ultrasonic testing personnel piping qualifications that will be performing the upcoming Braidwood 1 & 2 examinations. 3. To ensure that the examination method when performed will provide reasonable assurance of structural integrity. In the June 6, 2011 letter, the response to question 1(c), starts a sentence with, "The estimated lack of coverage for these welds-."  Please provide the estimated numerical coverage values, if they exist. DRAFT Hearing Identifier:  NRR_PMDA  Email Number:  155  Mail Envelope Properties  (Nicholas.DiFrancesco@nrc.gov20110922142700) 


==Subject:==
==Subject:==
DRAFT RAI Braidwood - Relief Request I3R-08 (TAC NOs. ME6024 & ME6024) Sent Date:   9/22/2011 2:27:26 PM Received Date: 9/22/2011 2:27:00 PM From:   DiFrancesco, Nicholas Created By:   Nicholas.DiFrancesco@nrc.gov Recipients:     "david.gullott@exeloncorp.com" <david.gullott@exeloncorp.com> Tracking Status: None "Zimmerman, Jacob" <Jacob.Zimmerman@nrc.gov>
DRAFT RAI Braidwood - Relief Request I3R-08 (TAC NOs. ME6024 & ME6024)
Tracking Status: None "Mahoney, Michael" <Michael.Mahoney@nrc.gov> Tracking Status: None "Lisa.Schofield@exeloncorp.com" <Lisa.Schofield@exeloncorp.com> Tracking Status: None Post Office:     Files     Size     Date & Time MESSAGE   6256     9/22/2011 2:27:00 PM Options Priority:     Standard   Return Notification:   No   Reply Requested:   No   Sensitivity:     Normal Expiration Date:     Recipients Received:      
: Lisa, Below are the draft RAI questions for the Braidwood Relief Request I3R-08. The draft RAIs have been provided to support RAI clarification discussion scheduled for September 27 and to establish a response date.
}}
Sincerely, Nick Project Manager - Braidwood, Byron, and Clinton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing nicholas.difrancesco@nrc.gov l Tel: (301) 415-1115 DRAFT REQUEST FOR ADDITIONAL INFORMATION BRAIDWOOD STATION, UNITS 1 AND 2 REGARDING REQUEST FOR RELIEF I3R-08 DOCKET NOS. STN 50-456 AND STN 50-457 TAC NOS. ME6024 AND ME6025 By letters dated April 11, 2011 and June 6, 2011, (Agencywide Documents Access & Management System (ADAMS) Accession Numbers ML111020263 and ML111580106 respectively), Exelon Generation Company, LLC, (Licensee) submitted request for relief, I3R-08, from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at Braidwood Station, Units 1 and 2. Specifically, the licensee proposed using root mean square error (RMSE) criteria for sizing flaws that are greater than the requirements of ASME Code Case N-695, AQualification Requirements for Dissimilar Metal Piping Welds, and N-696, Qualification Requirements for Appendix VIII Piping Examinations Conducted From the Inside Surface. To complete the review, the NRC staff requests the following additional information supporting the licensee's request.
: 1. The large differences in RMSE between non-Appendix VIII DMWs, Appendix VIII DMWs, and Appendix VIII austenitic-to-austenitic welds are influenced by changes to the surface conditions in the test mockups used to demonstrate capability, effectiveness, and skill. Unless the surface conditions of the field welds are exactly the same as test mockups, the applicability of a specific RMSE value may not be appropriate. Correlations between the essential variable surface preparation and RMSE values have not been developed. Therefore, the best effort RMSE values assigned by the Electric Power Research Institute (EPRI) - Performance Demonstration Initiative (PDI), which are referenced in the submittal for 1
 
DMW and austenitic-to-austenitic welds, may not be appropriate depending on the relationship of RMSE and actual surface preparations (conditions). In the absence of any correlation between RMSE and surface conditions, the best effort PDI RMSE values are questionable with respect to reliability, reproducibility, and applicability to actual depth sizing of cracks identified during an examination.
Provide a discussion on the following two probe-to-component surface contact conditions:
: a. Based on the non-Appendix VIII vendor performance demonstrations performed on surfaces that are capable of maintaining good probe-to-component surface (defined by the EPRI Performance Demonstration Initiative as 1/32-inch gap or less) contact, the vendors RMSE data suggest a reasonable probability of reproducibility. For surface conditions similar to those associated with the non-Appendix VIII performance demonstration, discuss a conservative approach for using RMSE values that would apply to both DMWs and austenitic-to-austenitic welds, i.e., one best effort RMSE value.
: b. In examinations performed during the last 10-year inservice inspection (ISI) interval, the licensees vendor recorded no flaw (crack) indications for the subject welds. These examinations were performed with a combination of ultrasonic testing (UT) and eddy current testing (ET) methods. For upcoming examinations, any cracks that are detected would have occurred between the last ISI examination and upcoming examination. The most likely cracking mechanism (identified in the licensees risk-informed program) is primary water stress corrosion cracks (PWSCC). In the event that the UT or ET examination detected PWSCC, UT depth sizing performed on surfaces exhibiting gaps greater than 1/32-inch between probe and component surface may be less conservative than the proposed alternative in 1a, above.
Because sizing accuracy is unknown for gaps greater that 1/32-inch, the application of RMSE as a tolerance to adjust crack depth is questionable. As an alternative to the adjustment approach, cracks that are depth sized on rough surfaces may be bounded by calculating crack growth from the last crack free examination. For calculating purposes, the initial (at the time of the crack free examination) crack depth should be assumed 5-percent through-wall (the smallest crack size that may be in a performance demonstration test). For PWSCC, the bounding crack depth can be calculated using the guidance provided in the EPRI - Materials Reliability Program (MRP) MRP-115, MRP-252, and/or MRP-287, as appropriate, for representative DMW and austenitic-to-austenitic welds. Provide a discussion on the disposition of cracks as determine by calculating the maximum through-wall crack depth and identify the associated assumptions, if any.
: 2. The vendor participated in three non-PDI performance demonstrations on mockups with smooth ID surfaces (probe-to-component surface gaps of less than or equal to 1/32-inch). Each of the demonstrations used UT procedures and equipment nearly identical to those to be applied in the upcoming Braidwood 1 & 2 examinations. The personnel performing the Appendix VIII examinations are required to be qualified on the specific UT procedure that will be used for the examinations. Please provide a discussion on the participation in the non-PDI performance demonstrations of the UT ultrasonic testing personnel piping qualifications that will be performing the upcoming Braidwood 1 & 2 examinations.
: 3. To ensure that the examination method when performed will provide reasonable assurance of structural integrity. In the June 6, 2011 letter, the response to question 1(c), starts a sentence with, The estimated lack of coverage for these welds. Please provide the estimated numerical coverage values, if they exist.
DRAFT 2
 
Hearing Identifier:    NRR_PMDA Email Number:          155 Mail Envelope Properties    (Nicholas.DiFrancesco@nrc.gov20110922142700)
 
==Subject:==
DRAFT RAI Braidwood - Relief Request I3R-08 (TAC NOs. ME6024 & ME6024)
Sent Date:             9/22/2011 2:27:26 PM Received Date:         9/22/2011 2:27:00 PM From:                 DiFrancesco, Nicholas Created By:           Nicholas.DiFrancesco@nrc.gov Recipients:
"david.gullott@exeloncorp.com" <david.gullott@exeloncorp.com>
Tracking Status: None "Zimmerman, Jacob" <Jacob.Zimmerman@nrc.gov>
Tracking Status: None "Mahoney, Michael" <Michael.Mahoney@nrc.gov>
Tracking Status: None "Lisa.Schofield@exeloncorp.com" <Lisa.Schofield@exeloncorp.com>
Tracking Status: None Post Office:
Files                         Size                     Date & Time MESSAGE                       6256                     9/22/2011 2:27:00 PM Options Priority:                     Standard Return Notification:           No Reply Requested:               No Sensitivity:                   Normal Expiration Date:
Recipients Received:}}

Latest revision as of 01:31, 6 December 2019

NRR E-mail Capture - Draft RAI Braidwood - Relief Request I3R-08 (TAC Nos. ME6024 & ME6025)
ML11266A003
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 09/22/2011
From: Nicholas Difrancesco
Division of Operating Reactor Licensing
To: Schofield L
Exelon Generation Co
References
TAC ME6024, TAC ME6025
Download: ML11266A003 (3)


Text

NRR-PMDAPEm Resource From: DiFrancesco, Nicholas Sent: Thursday, September 22, 2011 2:27 PM To: Lisa.Schofield@exeloncorp.com Cc: david.gullott@exeloncorp.com; Zimmerman, Jacob; Mahoney, Michael

Subject:

DRAFT RAI Braidwood - Relief Request I3R-08 (TAC NOs. ME6024 & ME6024)

Lisa, Below are the draft RAI questions for the Braidwood Relief Request I3R-08. The draft RAIs have been provided to support RAI clarification discussion scheduled for September 27 and to establish a response date.

Sincerely, Nick Project Manager - Braidwood, Byron, and Clinton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing nicholas.difrancesco@nrc.gov l Tel: (301) 415-1115 DRAFT REQUEST FOR ADDITIONAL INFORMATION BRAIDWOOD STATION, UNITS 1 AND 2 REGARDING REQUEST FOR RELIEF I3R-08 DOCKET NOS. STN 50-456 AND STN 50-457 TAC NOS. ME6024 AND ME6025 By letters dated April 11, 2011 and June 6, 2011, (Agencywide Documents Access & Management System (ADAMS) Accession Numbers ML111020263 and ML111580106 respectively), Exelon Generation Company, LLC, (Licensee) submitted request for relief, I3R-08, from certain examination requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at Braidwood Station, Units 1 and 2. Specifically, the licensee proposed using root mean square error (RMSE) criteria for sizing flaws that are greater than the requirements of ASME Code Case N-695, AQualification Requirements for Dissimilar Metal Piping Welds, and N-696, Qualification Requirements for Appendix VIII Piping Examinations Conducted From the Inside Surface. To complete the review, the NRC staff requests the following additional information supporting the licensee's request.

1. The large differences in RMSE between non-Appendix VIII DMWs, Appendix VIII DMWs, and Appendix VIII austenitic-to-austenitic welds are influenced by changes to the surface conditions in the test mockups used to demonstrate capability, effectiveness, and skill. Unless the surface conditions of the field welds are exactly the same as test mockups, the applicability of a specific RMSE value may not be appropriate. Correlations between the essential variable surface preparation and RMSE values have not been developed. Therefore, the best effort RMSE values assigned by the Electric Power Research Institute (EPRI) - Performance Demonstration Initiative (PDI), which are referenced in the submittal for 1

DMW and austenitic-to-austenitic welds, may not be appropriate depending on the relationship of RMSE and actual surface preparations (conditions). In the absence of any correlation between RMSE and surface conditions, the best effort PDI RMSE values are questionable with respect to reliability, reproducibility, and applicability to actual depth sizing of cracks identified during an examination.

Provide a discussion on the following two probe-to-component surface contact conditions:

a. Based on the non-Appendix VIII vendor performance demonstrations performed on surfaces that are capable of maintaining good probe-to-component surface (defined by the EPRI Performance Demonstration Initiative as 1/32-inch gap or less) contact, the vendors RMSE data suggest a reasonable probability of reproducibility. For surface conditions similar to those associated with the non-Appendix VIII performance demonstration, discuss a conservative approach for using RMSE values that would apply to both DMWs and austenitic-to-austenitic welds, i.e., one best effort RMSE value.
b. In examinations performed during the last 10-year inservice inspection (ISI) interval, the licensees vendor recorded no flaw (crack) indications for the subject welds. These examinations were performed with a combination of ultrasonic testing (UT) and eddy current testing (ET) methods. For upcoming examinations, any cracks that are detected would have occurred between the last ISI examination and upcoming examination. The most likely cracking mechanism (identified in the licensees risk-informed program) is primary water stress corrosion cracks (PWSCC). In the event that the UT or ET examination detected PWSCC, UT depth sizing performed on surfaces exhibiting gaps greater than 1/32-inch between probe and component surface may be less conservative than the proposed alternative in 1a, above.

Because sizing accuracy is unknown for gaps greater that 1/32-inch, the application of RMSE as a tolerance to adjust crack depth is questionable. As an alternative to the adjustment approach, cracks that are depth sized on rough surfaces may be bounded by calculating crack growth from the last crack free examination. For calculating purposes, the initial (at the time of the crack free examination) crack depth should be assumed 5-percent through-wall (the smallest crack size that may be in a performance demonstration test). For PWSCC, the bounding crack depth can be calculated using the guidance provided in the EPRI - Materials Reliability Program (MRP) MRP-115, MRP-252, and/or MRP-287, as appropriate, for representative DMW and austenitic-to-austenitic welds. Provide a discussion on the disposition of cracks as determine by calculating the maximum through-wall crack depth and identify the associated assumptions, if any.

2. The vendor participated in three non-PDI performance demonstrations on mockups with smooth ID surfaces (probe-to-component surface gaps of less than or equal to 1/32-inch). Each of the demonstrations used UT procedures and equipment nearly identical to those to be applied in the upcoming Braidwood 1 & 2 examinations. The personnel performing the Appendix VIII examinations are required to be qualified on the specific UT procedure that will be used for the examinations. Please provide a discussion on the participation in the non-PDI performance demonstrations of the UT ultrasonic testing personnel piping qualifications that will be performing the upcoming Braidwood 1 & 2 examinations.
3. To ensure that the examination method when performed will provide reasonable assurance of structural integrity. In the June 6, 2011 letter, the response to question 1(c), starts a sentence with, The estimated lack of coverage for these welds. Please provide the estimated numerical coverage values, if they exist.

DRAFT 2

Hearing Identifier: NRR_PMDA Email Number: 155 Mail Envelope Properties (Nicholas.DiFrancesco@nrc.gov20110922142700)

Subject:

DRAFT RAI Braidwood - Relief Request I3R-08 (TAC NOs. ME6024 & ME6024)

Sent Date: 9/22/2011 2:27:26 PM Received Date: 9/22/2011 2:27:00 PM From: DiFrancesco, Nicholas Created By: Nicholas.DiFrancesco@nrc.gov Recipients:

"david.gullott@exeloncorp.com" <david.gullott@exeloncorp.com>

Tracking Status: None "Zimmerman, Jacob" <Jacob.Zimmerman@nrc.gov>

Tracking Status: None "Mahoney, Michael" <Michael.Mahoney@nrc.gov>

Tracking Status: None "Lisa.Schofield@exeloncorp.com" <Lisa.Schofield@exeloncorp.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 6256 9/22/2011 2:27:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: