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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 |
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| | page count = 3 | | | page count = 3 |
| | project = TAC:ME6024, TAC:ME6025 | | | project = TAC:ME6024, TAC:ME6025 |
| | stage = RAI | | | stage = Draft RAI |
| }} | | }} |
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| =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)
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| ==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:}} |
Letter Sequence Draft RAI |
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MONTHYEARRS-11-050, Third 10-Year Inservice Inspection Interval Relief Request I3R-08, Alternative Requirements to ASME Section XI Appendix VII (Supplements 2 and 10), Examinations of Class 1 Pressure Retaining Welds Conducted from the Inside.2011-04-11011 April 2011 Third 10-Year Inservice Inspection Interval Relief Request I3R-08, Alternative Requirements to ASME Section XI Appendix VII (Supplements 2 and 10), Examinations of Class 1 Pressure Retaining Welds Conducted from the Inside. Project stage: Supplement ML11147A1872011-05-20020 May 2011 NRR E-mail Capture - Draft Supplemental Information Request for Braidwood Station, Units 1 and 2 - Relief Request I3R-08: Alternative Requirements to ASME Code Requirements for Class 1 Pressure Retaining Welds Project stage: Draft Other ML1112605322011-05-25025 May 2011 Unacceptable with Opportunity to Supplement Relief Request I3R-08, Alternative Requirements to ASME Code Requirements for Class 1 Pressure Retaining Welds Project stage: Other RS-11-087, Supplemental Information Supporting Relief Request 13R-08: Alternative Requirements to ASME Code Requirements for Class 1 Pressure Retaining Welds2011-06-0606 June 2011 Supplemental Information Supporting Relief Request 13R-08: Alternative Requirements to ASME Code Requirements for Class 1 Pressure Retaining Welds Project stage: Supplement ML1117200082011-06-17017 June 2011 NRR E-mail Capture - Braidwood Station, Units 1 and 2 - Acceptance Review of Relief Request I3R-08, Alternative Requirements to ASME Code for Class 1 Pressure Retaining Welds Project stage: Acceptance Review ML11266A0032011-09-22022 September 2011 NRR E-mail Capture - Draft RAI Braidwood - Relief Request I3R-08 (TAC Nos. ME6024 & ME6025) Project stage: Draft RAI ML1127005992011-10-12012 October 2011 Request for Additional Information Request for Relief I3R-08 Project stage: RAI RS-11-173, Response to Request for Additional Information Related to Relief Request I3R-082011-11-0202 November 2011 Response to Request for Additional Information Related to Relief Request I3R-08 Project stage: Response to RAI ML12052A3232012-02-21021 February 2012 E-Mail to Lisa Schofield Project stage: Other ML12058A0052012-02-24024 February 2012 Request for Additional Information E-Mail Project stage: RAI ML1206006032012-03-0909 March 2012 Request for Additional Information Regarding Request for Relief I3R-08 (TAC Nos. ME6024, and ME6025) Project stage: RAI RS-12-040, Response to Request for Additional Information Related to Braidwood Station Relief Request 13R-082012-03-12012 March 2012 Response to Request for Additional Information Related to Braidwood Station Relief Request 13R-08 Project stage: Response to RAI ML12108A1232012-04-19019 April 2012 Safety Evaluation in Support of the Third 10-Year Inservice Inspection Interval Request for Relief 13R-08 (Tac Nos. ME6024 and ME6025) Project stage: Approval 2011-06-06
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Category:E-Mail
MONTHYEARML24325A4222024-11-20020 November 2024 NRR E-mail Capture - Byron/Braidwood Reschedule and Revised Resource Estimate for Spent Fuel Pool Criticality Amendment - L-2023-LLA-0136 ML24298A0202024-10-24024 October 2024 NRR E-mail Capture - Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Relief Request I4R-19 and I4-26, Associated with the Fourth and Fifth Inservice Inspection Intervals ML24282A7042024-10-0808 October 2024 NRR E-mail Capture - Acceptance Reviews of Relief Requests Associated with the Fifth Inservice Inspection Interval at Byron and Braidwood Stations ML24250A1062024-09-0606 September 2024 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC - Fleet Request - Proposed Alternative to Utilize Code Case OMN-32 (L-2024-LLR-0030) ML24197A0162024-07-12012 July 2024 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591 ML24180A0042024-06-28028 June 2024 NRR E-mail Capture - Acceptance Review for Braidwood and Byron - Request for Exemption from 10 CFR 50.46 and Appendix K (L-2024-LLE-0019) ML24180A0032024-06-28028 June 2024 NRR E-mail Capture - NRC Acceptance Review of Byron/Braidwood Amendment for Transition to Framatome Gaia Fuel (L-2024-LLA-0072) ML24176A0182024-06-20020 June 2024 NRR E-mail Capture - NRC Acceptance Review of Byron/Braidwood Amendment to Remove Extraneous Detail Related to Beacon ML24170A3912024-06-18018 June 2024 NRR E-mail Capture - Revision of Estimated Hours to Complete Review of Byron/Braidwood Amendment to Revise TS 3.7.15, 3.7.16, and 4.3.1 (L-2023-LLA-0136) ML24141A2452024-05-20020 May 2024 NRR E-mail Capture - NRC Acceptance Review of Byron/Braidwood Amendment to Delete Technical Specification 5.6.5.b.5 (L-2024-LLA-0055) ML24131A0612024-05-10010 May 2024 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Proposed Alternative to Utilize Code Case OMN-32 (L-2024-LLR-0030) ML24122B5072024-05-0101 May 2024 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of License Amendment Request to Adopt TSTF-591, Revision 0 ML24053A3382024-02-22022 February 2024 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC - Fleet Request - Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds (L-2023-LLR-0062) ML24039A0412024-01-30030 January 2024 NRR E-mail Capture - Request for Additional Information Regarding Braidwood Request for Alternative (I4R-18) ML24030A0022024-01-30030 January 2024 NRR E-mail Capture - NRC Acceptance Review for Braidwood Station, Units 1 and 2, Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators ML23331A8922023-11-22022 November 2023 Supplement - Braidwood Security Rule Exemption Request – ISFSI Docket No. Reference ML23321A2012023-11-17017 November 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds (L-2023-LLR-0062) ML23311A1682023-11-0707 November 2023 NRR E-mail Capture - Constellation - Fleet Request - Acceptance of Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections (L-2023-LLR-0053 and L-2023-LLR-005 ML23311A1692023-11-0707 November 2023 NRR E-mail Capture - Constellation - Fleet Request - Acceptance of Proposed Alternative for Examinations of Exam Categories B-B, B-D, and C-A SG Pressure Retaining Welds and Full Penetration Welded Nozzles (L-2023-LLR-0055 and L-2023-LLR-00 ML23304A0222023-10-30030 October 2023 NRR E-mail Capture - Final RCI - Constellation Energy Generation, LLC - Braidwood 1 & 2 - Exemption from Security Rule (L-2023-LLE-0030) ML23187A0092023-07-0606 July 2023 NRR E-mail Capture - NRC Acceptance Review of Byron and Braidwood Request to Adopt TSTF-370 ML23103A4692023-04-12012 April 2023 NRR E-mail Capture - NRC Acceptance Review of Braidwood Request for Amendment to Revise TS 3.7.9 ML23069A0332023-03-0606 March 2023 Email to K. 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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)
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