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| | issue date = 05/28/2014 | | | issue date = 05/28/2014 |
| | title = Summary of Telephone Conference Call Held on May 15, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 27, Pertaining to the Byron Station and Br | | | title = Summary of Telephone Conference Call Held on May 15, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 27, Pertaining to the Byron Station and Br |
| | author name = Robinson L R | | | author name = Robinson L |
| | author affiliation = NRC/NRR/DLR/RPB1 | | | author affiliation = NRC/NRR/DLR/RPB1 |
| | addressee name = | | | addressee name = |
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| | docket = 05000454, 05000455, 05000456, 05000457 | | | docket = 05000454, 05000455, 05000456, 05000457 |
| | license number = | | | license number = |
| | contact person = Robinson L R, 415-4115 | | | contact person = Robinson L, 415-4115 |
| | case reference number = TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882 | | | case reference number = TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882 |
| | document type = Meeting Summary | | | document type = Meeting Summary |
| | page count = 8 | | | page count = 8 |
| | project = TAC:MF1879, TAC:MF1880, TAC:MF1881, TAC:MF1882 | | | project = TAC:MF1879, TAC:MF1880, TAC:MF1881, TAC:MF1882 |
| | stage = Other | | | stage = Draft RAI |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter: | | {{#Wiki_filter:May 28, 2014 LICENSEE: Exelon Generation Company, LLC FACILITY: Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2 |
| May 28, 2014 | |
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| LICENSEE: Exelon Generation Company, LLC FACILITY: Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2 | |
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| ==SUBJECT:== | | ==SUBJECT:== |
| SUMMARY OF TELEPHONE CONFERENCE CALL HELD ON MAY 15, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 27, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION AND RESPONSES FOR REQUEST FOR ADDITIONAL INFORMATION B.2.1.30-3 AND B.2.1.29-1, DATED APRIL 17, 2014 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882)
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| 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 May 15, 2014, to discuss and clarify the staff's draft request for additional information (DRAI), Set 27, 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 staff's DRAIs.
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| In addition, the staff discussed the responses for request for additional information (RAI) B.2.1.30-3 and RAI B.2.1.29-1, dated April 17, 2014. Specifically, for the response to RAI B.2.1.30-3, the staff requested that the applicant consider revising the updated final safety analysis report (UFSAR) supplement associated with the ASME Section XI, Subsection IWL with certain information provided in the RAI responses. The applicant agreed to update the UFSAR supplement accordingly. With regard to the response to RAI B.2.1.29-1, the staff requested clarifying information, which the applicant provided.
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| Enclosure 1 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 Richard Plasse for/ 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
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| ==Enclosures:== | | ==SUMMARY== |
| : 1. List of Participants
| | OF TELEPHONE CONFERENCE CALL HELD ON MAY 15, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 27, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION AND RESPONSES FOR REQUEST FOR ADDITIONAL INFORMATION B.2.1.30-3 AND B.2.1.29-1, DATED APRIL 17, 2014 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882) |
| : 2. List of Draft Request for Additional Information cc w/encls: Listserv Enclosure 1 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 Richard Plasse for/ 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 50-45
| | 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 May 15, 2014, to discuss and clarify the staffs draft request for additional information (DRAI), |
| | Set 27, 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. |
| | In addition, the staff discussed the responses for request for additional information (RAI) |
| | B.2.1.30-3 and RAI B.2.1.29-1, dated April 17, 2014. Specifically, for the response to RAI B.2.1.30-3, the staff requested that the applicant consider revising the updated final safety analysis report (UFSAR) supplement associated with the ASME Section XI, Subsection IWL with certain information provided in the RAI responses. The applicant agreed to update the UFSAR supplement accordingly. With regard to the response to RAI B.2.1.29-1, the staff requested clarifying information, which the applicant provided. |
| | 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 Richard Plasse for/ |
| | 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 |
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| ==Enclosures:== | | ==Enclosures:== |
| 1. List of Participants 2. List of Draft Request for Additional Information | | : 1. List of Participants |
| | : 2. List of Draft Request for Additional Information cc w/encls: Listserv |
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| cc w/encls: Listserv DISTRIBUTION: EMAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsOgcMailCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource
| | ML14140A385 *concurred via email OFFICE LA:DLR* PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME IKing LRobinson (RPlasse for) YDiazSanabria LRobinson (RPlasse for) |
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| | DATE 5/28/14 5/28/14 5/28/14 5/28/14 TELEPHONE CONFERENCE CALL BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS May 15, 2014 PARTICIPANTS AFFILIATIONS Lindsay Robinson U.S. Nuclear Regulatory Commission (NRC) |
| LRobinson DMcIntyre, OPA EDuncan, RIII JBenjamin, RIII AGarmoe, RIII JMcGhee, RIII JRobbins, RIII VMitlyng, RIII PChandrathil, RIII
| | Alice Erickson NRC Sam Cuadrado NRC Angela Buford NRC William Holston NRC John Hufnagel Exelon Generating Company, LLC (Exelon) |
| | Al Fulvio Exelon Albert Piha Exelon Casey Muggleston Exelon Jim Annett Exelon Paul Cervenka Exelon Don Warfel Exelon Ralph Wolen Exelon Don Brindle Exelon ENCLOSURE 1 |
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| ADAMS Accession No.: ML14140A385 *concurred via email OFFICE LA:DLR* PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME IKing LRobinson (RPlasse for) YDiazSanabria LRobinson (RPlasse for)DATE 5/28/14 5/28/14 5/28/14 5/28/14 OFFICIAL RECORD COPY ENCLOSURE 1 TELEPHONE CONFERENCE CALL BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS May 15, 2014 PARTICIPANTS AFFILIATIONS Lindsay Robinson U.S. Nuclear Regulatory Commission (NRC) Alice Erickson NRC Sam Cuadrado NRC Angela Buford NRC William Holston NRC John Hufnagel Exelon Generating Company, LLC (Exelon)
| | DRAFT REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION May 15, 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 May 15, 2014, to discuss and clarify the following draft request for additional information (DRAI), |
| Al Fulvio Exelon Albert Piha Exelon Casey Muggleston Exelon Jim Annett Exelon Paul Cervenka Exelon Don Warfel Exelon Ralph Wolen Exelon Don Brindle Exelon ENCLOSURE 2 DRAFT REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION May 15, 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 May 15, 2014, to discuss and clarify the following draft request for additional information (DRAI), Set 27, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application (LRA). DRAI B.2.1.16-1a Applicability:
| | Set 27, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application (LRA). |
| Byron Station (Byron) and Braidwood Station (Braidwood), all units | | DRAI B.2.1.16-1a Applicability: |
| | Byron Station (Byron) and Braidwood Station (Braidwood), all units |
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| ==Background:== | | ==Background:== |
| The applicant's response, dated March 13, 2014, to Request 1 for request for additional information (RAI) B.2.1.16-1 states that the Fire Water System program will be enhanced to include non-destructive examinations (NDE) "capable of detecting internal flow blockage (e.g., | | |
| digital radiography) or internal visual inspections." The response also states that inspections will be performed by opening a flushing connection at the end of one [emphasis added by NRC] main in each structure containing in-scope water-based fire suppression systems. | | The applicants response, dated March 13, 2014, to Request 1 for request for additional information (RAI) B.2.1.16-1 states that the Fire Water System program will be enhanced to include non-destructive examinations (NDE) capable of detecting internal flow blockage (e.g., |
| | digital radiography) or internal visual inspections. The response also states that inspections will be performed by opening a flushing connection at the end of one [emphasis added by NRC] |
| | main in each structure containing in-scope water-based fire suppression systems. |
| Issue: | | Issue: |
| The staff notes that the National Fire Protection Association (NFPA) 25, Section 14.2.2, requires an internal inspection of every other wet pipe system (in buildings with multiple wet pipe systems) and that the alternate systems (not inspected during the previous inspection) be inspected during the next inspection. Since the response only stated that one main in each structure will be opened, it is not clear whether there are multiple wet pipe systems in any of the structures containing in-scope fire water systems and, if so, whether all wet pipe systems will be inspected as stated in NFPA 25. The staff also notes that LR-ISG-2012-02 AMP XI.M27 Table 4a limits the alternative NDE methods, which are permitted by NFPA 25, Sections 14.2.1.1 and 14.3.2.3, to those that can ensure that flow blockage will not occur. Because of its similarity to raw water applications in fire water systems, the staff further notes that the Electric Power Research Institute (EPRI) TR-102063, "Guide for the Examination of Service Water System Piping," cites radiography as an effective NDE method capable of measuring the extent of occlusions or biofouling conditions. Although the EPRI guide includes ultrasonic testing, the discussion of its capability is limited to wall thickness measurement. Because the response proposes digital radiography as an example and not the only method, it was not clear how other NDE methods, if used, would be shown to ensure that flow blockage will not occur demonstrated to be capable of detecting flow blockage. | | The staff notes that the National Fire Protection Association (NFPA) 25, Section 14.2.2, requires an internal inspection of every other wet pipe system (in buildings with multiple wet pipe systems) and that the alternate systems (not inspected during the previous inspection) be inspected during the next inspection. Since the response only stated that one main in each structure will be opened, it is not clear whether there are multiple wet pipe systems in any of the structures containing in-scope fire water systems and, if so, whether all wet pipe systems will be inspected as stated in NFPA 25. |
| - 2 - Request: 1. State whether there are multiple wet pipe systems in any of the structures containing in-scope fire water systems and, if there are, confirm that internal inspections will be conducted as stated in NFPA 25, Section 14.2.2, or provide the basis for not conducting the internal inspections on every other wet pipe system every 5 years.
| | The staff also notes that LR-ISG-2012-02 AMP XI.M27 Table 4a limits the alternative NDE methods, which are permitted by NFPA 25, Sections 14.2.1.1 and 14.3.2.3, to those that can ensure that flow blockage will not occur. Because of its similarity to raw water applications in fire water systems, the staff further notes that the Electric Power Research Institute (EPRI) |
| 2. If NDE methods other than digital radiography are used, state how the other NDE methods will be demonstrated to be capable of detecting flow blockage. Discussion: The applicant requested clarity on the staff's concern. The applicant requested the last sentence of the issue section be edited as shown by the strikethrough and underlined portion of the text. This question will be sent as part of the formal request titled: "RAI B.2.1.16-1a." | | TR-102063, Guide for the Examination of Service Water System Piping, cites radiography as an effective NDE method capable of measuring the extent of occlusions or biofouling conditions. |
| DRAI B.2.1.16-1b Applicability: Byron and Braidwood | | Although the EPRI guide includes ultrasonic testing, the discussion of its capability is limited to wall thickness measurement. Because the response proposes digital radiography as an example and not the only method, it was not clear how other NDE methods, if used, would be shown to ensure that flow blockage will not occur demonstrated to be capable of detecting flow blockage. |
| | ENCLOSURE 2 |
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| | Request: |
| | : 1. State whether there are multiple wet pipe systems in any of the structures containing in-scope fire water systems and, if there are, confirm that internal inspections will be conducted as stated in NFPA 25, Section 14.2.2, or provide the basis for not conducting the internal inspections on every other wet pipe system every 5 years. |
| | : 2. If NDE methods other than digital radiography are used, state how the other NDE methods will be demonstrated to be capable of detecting flow blockage. |
| | Discussion: The applicant requested clarity on the staffs concern. The applicant requested the last sentence of the issue section be edited as shown by the strikethrough and underlined portion of the text. This question will be sent as part of the formal request titled: RAI B.2.1.16-1a. |
| | DRAI B.2.1.16-1b Applicability: |
| | Byron and Braidwood |
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| ==Background:== | | ==Background:== |
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| RAI B.2.1.16-1 requested that either: (a) it is confirmed that follow-up volumetric examinations will be conducted whenever internal fire water system visual inspections detect surface irregularities indicative of material loss below nominal wall thickness [emphasis added by NRC]; or (b) the bases be provided for why the visual inspection alone will provide reasonable assurance that the current licensing basis intended functions of in-scope components will be met. | | RAI B.2.1.16-1 requested that either: (a) it is confirmed that follow-up volumetric examinations will be conducted whenever internal fire water system visual inspections detect surface irregularities indicative of material loss below nominal wall thickness [emphasis added by NRC]; or (b) the bases be provided for why the visual inspection alone will provide reasonable assurance that the current licensing basis intended functions of in-scope components will be met. |
| The applicant's response, dated March 13, 2014, to RAI B.2.1.16-1 states that noticeable deposits in excess of a normal oxide layer, which could be indicative of wall loss below nominal, are documented; inspection results that are unusual or unexpected (e.g., surface irregularities indicative of significant loss of material [emphasis added by NRC]) are documented in the corrective action program for evaluation; and, based on the results of the evaluation, appropriate corrective actions are taken including repair, replacement, or follow-up volumetric examinations to quantify the remaining wall thickness, as applicable. | | The applicants response, dated March 13, 2014, to RAI B.2.1.16-1 states that noticeable deposits in excess of a normal oxide layer, which could be indicative of wall loss below nominal, are documented; inspection results that are unusual or unexpected (e.g., surface irregularities indicative of significant loss of material [emphasis added by NRC]) are documented in the corrective action program for evaluation; and, based on the results of the evaluation, appropriate corrective actions are taken including repair, replacement, or follow-up volumetric examinations to quantify the remaining wall thickness, as applicable. |
| Issue: | | Issue: |
| The staff noted that LR-ISG-2012-02 AMP XI.M27 states that, "[i]nternal visual inspections used to detect loss of material are capable of detecting surface irregularities that could be indicative of wall loss below nominal pipe wall thickness due to corrosion and corrosion product deposition. Where such irregularities are detected, followup volumetric examinations are performed." Based on the wording "surface irregularities indicative of significant loss of material," it is not clear to the staff that surface irregularities indicative of wall loss below nominal would be documented in the corrective action program. It is also not clear to the staff that volumetric wall thickness measurements would be conducted when visual inspection results reveal surface irregularities that could be indicative of wall loss below nominal pipe wall thickness. | | The staff noted that LR-ISG-2012-02 AMP XI.M27 states that, [i]nternal visual inspections used to detect loss of material are capable of detecting surface irregularities that could be indicative of wall loss below nominal pipe wall thickness due to corrosion and corrosion product deposition. Where such irregularities are detected, followup volumetric examinations are performed. Based on the wording surface irregularities indicative of significant loss of material, it is not clear to the staff that surface irregularities indicative of wall loss below nominal would be documented in the corrective action program. It is also not clear to the staff that volumetric wall thickness measurements would be conducted when visual inspection results reveal surface irregularities that could be indicative of wall loss below nominal pipe wall thickness. |
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| - 3 - Request: 1. State whether surface irregularities indicative of wall loss below nominal would be documented in the corrective action program.
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| 2. State whether volumetric wall thickness measurements would be conducted when visual inspection results reveal surface irregularities that could be indicative of wall loss below nominal pipe wall thickness. 3. If not, state the basis for the portion(s) of the response that represent an exception to LR-ISG-2012-02 AMP XI.M27. Discussion: The applicant requested clarity on the staff's concern. The applicant discussed their concern with the staff's position of using "below nominal wall thickness" as the basis for conducting follow-up inspections. The staff decided to keep the question as written and not make any edits. This question will be sent as part of the formal request titled: "RAI B.2.1.16-1b." DRAI 3.5.2.10-1 | | : 1. State whether surface irregularities indicative of wall loss below nominal would be documented in the corrective action program. |
| | : 2. State whether volumetric wall thickness measurements would be conducted when visual inspection results reveal surface irregularities that could be indicative of wall loss below nominal pipe wall thickness. |
| | : 3. If not, state the basis for the portion(s) of the response that represent an exception to LR-ISG-2012-02 AMP XI.M27. |
| | Discussion: The applicant requested clarity on the staffs concern. The applicant discussed their concern with the staffs position of using below nominal wall thickness as the basis for conducting follow-up inspections. The staff decided to keep the question as written and not make any edits. This question will be sent as part of the formal request titled: RAI B.2.1.16-1b. |
| | DRAI 3.5.2.10-1 |
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| ==Background:== | | ==Background:== |
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| Title 10 of the Code of Federal Regulations (10 CFR) Part 54.21 (a)(3) states that for structures and components (SCs) subject to an aging management review (AMR) it shall be demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation (PEO). | | Title 10 of the Code of Federal Regulations (10 CFR) Part 54.21 (a)(3) states that for structures and components (SCs) subject to an aging management review (AMR) it shall be demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation (PEO). |
| | | LRA Table 3.5.2-10, Main Steam & Auxiliary Feedwater Tunnels and Isolation Valve Rooms Summary of Aging Management Evaluation, states that polymer blowout panels exposed to air-indoor (uncontrolled) or air-outdoor will be managed for change in material properties by the Structures Monitoring Program. The AMR items cite generic note J, which states that neither the component nor the material and environment combination is evaluated in NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2. The AMR items also cite plant specific note 1, which states that the blowout panels are constructed of extruded polystyrene. |
| LRA Table 3.5.2-10, "Main Steam & Auxiliary Feedwater Tunnels and Isolation Valve Rooms Summary of Aging Management Evaluation," states that polymer blowout panels exposed to air- indoor (uncontrolled) or air-outdoor will be managed for change in material properties by the Structures Monitoring Program. The AMR items cite generic note J, which states that neither the component nor the material and environment combination is evaluated in NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Revision 2. The AMR items also cite plant specific note 1, which states that the blowout panels are constructed of extruded polystyrene. | |
| Issue: | | Issue: |
| Although the scope of the Structures Monitoring Program has been enhanced to include inspection of blowout panels, the parameters monitored or inspected and acceptance criteria for this material have not been specified in the program elements. Unlike GALL Report aging management programs (AMPs) XI.M36, "External Surfaces Monitoring of Mechanical Components" and XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," GALL Report AMP XI.S6, "Structures Monitoring Program," does not include examples of inspection parameters for polymeric components. Based on the staff's review of this material exposed to an air-indoor and air-outdoor environment, the staff noted that at high temperatures, this material may begin to degrade. The staff does not have sufficient information to conclude that the visual inspections performed under the Structures Monitoring Program would identify a change in material properties, prior to a loss of intended function. | | Although the scope of the Structures Monitoring Program has been enhanced to include inspection of blowout panels, the parameters monitored or inspected and acceptance criteria for this material have not been specified in the program elements. Unlike GALL Report aging management programs (AMPs) XI.M36, External Surfaces Monitoring of Mechanical Components and XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, GALL Report AMP XI.S6, Structures Monitoring Program, does not include examples of inspection parameters for polymeric components. Based on the staffs review of this material exposed to an air-indoor and air-outdoor environment, the staff noted that at high temperatures, this material may begin to degrade. The staff does not have sufficient information to conclude that the visual inspections performed under the Structures Monitoring Program would identify a change in material properties, prior to a loss of intended function. |
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| - 4 - Request: State how the visual inspections performed under the Structures Monitoring Program would identify a change in material properties for these components, and provide the acceptance criteria by which they would be evaluated.
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| Discussion: The applicant requested clarity on the staff's concern. No edits were proposed. This question will be sent as part of the formal request titled: "RAI 3.5.2.10-1." | | Request: |
| }} | | State how the visual inspections performed under the Structures Monitoring Program would identify a change in material properties for these components, and provide the acceptance criteria by which they would be evaluated. |
| | Discussion: The applicant requested clarity on the staffs concern. No edits were proposed. |
| | This question will be sent as part of the formal request titled: RAI 3.5.2.10-1.}} |
Letter Sequence Draft RAI |
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Results
Other: ML13212A367, ML14050A304, ML14071A620, ML14072A369, ML14092A346, ML14177A430, ML14238A691, ML15098A181, ML15106A736, RS-14-183, Updated Responses to NRC Set 14 Requests for Additional Information, Related License Renewal Application, RS-14-249, Results of Detailed Review Performed in Response to Request 1 of NRC RAI B.2.1.7-7 from Set 17, Related to License Renewal Application
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MONTHYEARML13212A3672013-08-12012 August 2013 Plan for the Aging Management Program Regulatory Audits Regarding the Byron and Braidwood Nuclear Stations License Renewal Application Review (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: Other ML13281A5742013-11-25025 November 2013 Requests for Additional Information for the Review of the Byron Nuclear Station, Units 1 and 2, and Braidwood Nuclear Station, Units 1 and 2, License Renewal Application - Aging Management, Set 3 (TAC Nos. MF1879, MF1880, MF1881, and MF1882 Project stage: RAI ML13303B4632013-11-25025 November 2013 Summary of Telephone Conference Call Held on October 22, 2013, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning RAI Set 3 for the Byron-Braidwood LRA Project stage: RAI ML13281A5692013-12-12012 December 2013 Request for Additional Information for the Review of the Byron Nuclear Station Units 1 and 2, and the Braidwood Nuclear Station Units 1 and 2, LRA - Aging Management, Set 4 Project stage: RAI ML13282A3692013-12-13013 December 2013 Requests for Additional Information for the Review of the Byron Nuclear Station, Units 1 and 2, and Braidwood Nuclear Station, Units 1 and 2, License Renewal Application - Aging Management, Set 2 (TAC Nos. MF1879, MF1880, MF1881, and MF1882 Project stage: RAI RS-13-273, Responses to NRC Requests for Additional Information, Set 3, Dated November 25, 2013, Related to the License Renewal Application2013-12-17017 December 2013 Responses to NRC Requests for Additional Information, Set 3, Dated November 25, 2013, Related to the License Renewal Application Project stage: Response to RAI RS-13-274, Response to NRC Requests for Additional Information, Set 5, Dated November 22, 2013, Related to License Renewal Application2013-12-19019 December 2013 Response to NRC Requests for Additional Information, Set 5, Dated November 22, 2013, Related to License Renewal Application Project stage: Response to RAI ML13317A0752014-01-13013 January 2014 Requests for Additional Information for Review of Byron, Units 1 & 2, and Braidwood, Units 1 & 2, License Renewal Applications, Set 6 Project stage: RAI RS-14-003, Bryon, Units 1 and 2, Response to NRC Requests for Additional Information, Set 2, Dated December 13, 2013, Related to the License Renewal Application2014-01-13013 January 2014 Bryon, Units 1 and 2, Response to NRC Requests for Additional Information, Set 2, Dated December 13, 2013, Related to the License Renewal Application Project stage: Response to RAI ML14007A6582014-01-22022 January 2014 Requests for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 9 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML13309A9322014-01-23023 January 2014 Summary of Telephone Conference Call Held on October 31, 2013, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Draft Requests for Additional Information Pertaining to the Byron Station and Braid Project stage: Draft RAI RS-14-030, Response to NRC Requests for Additional Information, Set 6, Dated January 13, 2014, Related to License Renewal Application2014-02-0404 February 2014 Response to NRC Requests for Additional Information, Set 6, Dated January 13, 2014, Related to License Renewal Application Project stage: Response to RAI ML14006A0212014-02-0606 February 2014 Requests for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application- Aging Management, Set 8 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14023A5642014-02-0707 February 2014 RAI for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 13 (TAC MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14030A5962014-02-10010 February 2014 Requests for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 12 (TAC MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14007A6032014-02-18018 February 2014 Request for Additional Information for the Review of the Byron Nuclear Station, Units 1 and 2, and Braidwood Nuclear Station, Units 1 and 2, LRA - Aging Management - Set 17 Project stage: RAI ML14035A1892014-02-20020 February 2014 Summary of Telephone Conference Call Held on January 30, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Draft Request for Additional Information Pertaining to the Byron Station and Braidw Project stage: Draft RAI ML14035A5342014-02-20020 February 2014 January 22, 2014, Summary of Telephone Conference Call Held Between NRC and Exelon Generation Company, Llc., Concerning Draft Requests for Additional Information Pertaining to the Byron Station and Braidwood Station, License Renewal Applica Project stage: Draft RAI RS-14-051, Response to NRC Requests for Additional Information, Set 8, Dated February 6, 2014 Related to the License Renewal Application2014-02-27027 February 2014 Response to NRC Requests for Additional Information, Set 8, Dated February 6, 2014 Related to the License Renewal Application Project stage: Response to RAI ML14063A4952014-03-0404 March 2014 Units 1 & 2, Response to NRC Requests for Additional Information, Set 13, Dated February 7, 2014 Re License Renewal Application Project stage: Response to RAI ML14050A1672014-03-0404 March 2014 Summary of Telephone Conference Call on January 23, 2014, Between U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning RAI Set 11, for Byron-Braidwood License Renewal Application (TAC Nos. MF1879, MF1880, MF1881 Project stage: RAI ML14036A3102014-03-0404 March 2014 Summary of Telephone Conference Call Held on January 28, 2014, Between NRC and Exelon, Concerning RAI Set 10, for the Byron and Braidwood Station, LRA Project stage: RAI ML14051A4312014-03-0404 March 2014 Summary of Telephone Conferene Call Held on January 29, 2014, Between the NRC and Exelon Generating Company, Llc., Concerning RAI Set 10, for the Byron and Braidwood Station License Renewal Application (TAC Nos. MF1879, MF1880, MF1881, and Project stage: RAI ML14051A4282014-03-0606 March 2014 January 13, 2014, Summary of Telephone Conference Call Held Between the NRC and Exelon RAI Set 8, for the Byron and Braidwood Station LRA Project stage: RAI ML14050A0812014-03-0707 March 2014 Correction to Request for Additional Information B.2.1.10-1, Letter Dated February 7, 2014, for the Review of the Byron Station and Braidwood Station, Units 1 and 2, LRA Set 13 Project stage: RAI ML14058B1802014-03-11011 March 2014 Summary of Telephone Conference Call on February 18, 2014, Between U.S. Nuclear Regulatory Commission & Exelon Generation Company, LLC Concerning Draft Request for Additional Information Regarding Byron & Braidwood Stations, License Renewal Project stage: Draft RAI ML14064A4032014-03-11011 March 2014 Summary of Telephone Conference Call on February 27, 2014, Between U.S. Nuclear Regulatory Commission & Exelon Generation Company, LLC Concerning Draft Request for Additional Information Re Byron Station & Braidwood Station License Renewal Project stage: Draft RAI ML14064A3912014-03-11011 March 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 15 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14071A6202014-03-13013 March 2014 Aging Management Programs Audit Report Regarding the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 (Tac Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: Other ML14072A3692014-03-13013 March 2014 AMP Audit Enclosure (3) Project stage: Other ML14050A3042014-03-14014 March 2014 Scoping and Screening Methodology Audit Report Regarding the Byron Station, and Braidwood Station, Units 1 and 2, LRA Project stage: Other ML14058B1822014-03-18018 March 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 14 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14051A5032014-03-20020 March 2014 Request for Additional Information for the Review of the Byron Nuclear Station Units 1 and 2, and Braidwood Nuclear Station, Units 1 and 2, License Renewal Application - Set 17 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI RS-14-084, Responses to NRC Requests for Additional Information, Set 10, Dated February 26, 2014 Related to the License Renewal Application2014-03-28028 March 2014 Responses to NRC Requests for Additional Information, Set 10, Dated February 26, 2014 Related to the License Renewal Application Project stage: Response to RAI ML14084A3352014-04-0303 April 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 16 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14073A7052014-04-0303 April 2014 Summary of Telephone Conference Call Held on February 12, 2014, Between the NRC and Exelon, Concerning Drais Pertaining to the Byron and Braidwood Station, LRA Project stage: RAI ML14092A3462014-04-0707 April 2014 Project Manager Change for the License Renewal of Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: Other ML14092A2612014-04-0707 April 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 20 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14084A4882014-04-0707 April 2014 03/04/2014 Summary of Telephone Conference Call Held Between NRC and Exelon Generation Company, LLC, Concerning Draft Request for Additional Information Pertaining to the Byron and Braidwood License Renewal Application Set 16 Project stage: Draft RAI ML14094A3662014-04-0808 April 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 19 Project stage: RAI ML14093B2472014-04-10010 April 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 18 (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14099A4852014-04-17017 April 2014 Request for Additional Information for the Review of the Byron Station, Units 1 & 2, and Braidwood Station, Units 1 & 2, License Renewal Application, Set 21, (TAC Nos. MF1879, MF1880, MF1881, and MF1882) Project stage: RAI ML14099A4932014-04-22022 April 2014 April 03, 2014 Summary of Telephone Conference Call Held Between NRC and Exelon Generation Co., LLC, Concerning Draft Request for Additional Information, Set 21, Pertaining to Byron, Units 1 & 2, Braidwood, Units 1 & 2, License Renewal Appl Project stage: Draft RAI ML14111A1182014-04-24024 April 2014 Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 22 Project stage: RAI ML14107A0772014-04-25025 April 2014 Summary of Telephone Conference Call Held on April 9, 2014, Between the U.S. Nuclear Regulatory Commission & Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 23, Pertaining to the Byron Station & Braid Project stage: Draft RAI ML14107A2262014-05-14014 May 2014 Summary of Telephone Conference Call Held on March 26, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 21, Pertaining to the Byron Station and Project stage: Draft RAI ML14092A4402014-05-14014 May 2014 Summary of Telephone Conference Call Held on March 19, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 18, Pertaining to the Byron Station and Project stage: Draft RAI ML14112A4182014-05-14014 May 2014 Summary of Telephone Conference Call Held on April 10, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 22, Pertaining to the Byron Station and Project stage: Draft RAI ML14094A4252014-05-14014 May 2014 Summary of Telephone Conference Call Held on April 1, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 19, Pertaining to the Byron Station and B Project stage: Draft RAI ML14129A3392014-05-14014 May 2014 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance 2014-03-11
[Table View] |
Summary of Telephone Conference Call Held on May 15, 2014, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC Concerning Draft Request for Additional Information, Set 27, Pertaining to the Byron Station and BrML14140A385 |
Person / Time |
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Site: |
Byron, Braidwood ![Constellation icon.png](/w/images/b/be/Constellation_icon.png) |
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Issue date: |
05/28/2014 |
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From: |
Robinson L License Renewal Projects Branch 1 |
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To: |
Exelon Generation Co |
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Robinson L, 415-4115 |
References |
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TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882 |
Download: ML14140A385 (8) |
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Category:Meeting Summary
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[Table view] |
Text
May 28, 2014 LICENSEE: Exelon Generation Company, LLC FACILITY: Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 15, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION, SET 27, PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION AND RESPONSES FOR REQUEST FOR ADDITIONAL INFORMATION B.2.1.30-3 AND B.2.1.29-1, DATED APRIL 17, 2014 (TAC NOS. MF1879, MF1880, MF1881, AND 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 May 15, 2014, to discuss and clarify the staffs draft request for additional information (DRAI),
Set 27, 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.
In addition, the staff discussed the responses for request for additional information (RAI)
B.2.1.30-3 and RAI B.2.1.29-1, dated April 17, 2014. Specifically, for the response to RAI B.2.1.30-3, the staff requested that the applicant consider revising the updated final safety analysis report (UFSAR) supplement associated with the ASME Section XI, Subsection IWL with certain information provided in the RAI responses. The applicant agreed to update the UFSAR supplement accordingly. With regard to the response to RAI B.2.1.29-1, the staff requested clarifying information, which the applicant provided.
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 Richard Plasse for/
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
ML14140A385 *concurred via email OFFICE LA:DLR* PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME IKing LRobinson (RPlasse for) YDiazSanabria LRobinson (RPlasse for)
DATE 5/28/14 5/28/14 5/28/14 5/28/14 TELEPHONE CONFERENCE CALL BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS May 15, 2014 PARTICIPANTS AFFILIATIONS Lindsay Robinson U.S. Nuclear Regulatory Commission (NRC)
Alice Erickson NRC Sam Cuadrado NRC Angela Buford NRC William Holston NRC John Hufnagel Exelon Generating Company, LLC (Exelon)
Al Fulvio Exelon Albert Piha Exelon Casey Muggleston Exelon Jim Annett Exelon Paul Cervenka Exelon Don Warfel Exelon Ralph Wolen Exelon Don Brindle Exelon ENCLOSURE 1
DRAFT REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION May 15, 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 May 15, 2014, to discuss and clarify the following draft request for additional information (DRAI),
Set 27, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application (LRA).
DRAI B.2.1.16-1a Applicability:
Byron Station (Byron) and Braidwood Station (Braidwood), all units
Background:
The applicants response, dated March 13, 2014, to Request 1 for request for additional information (RAI) B.2.1.16-1 states that the Fire Water System program will be enhanced to include non-destructive examinations (NDE) capable of detecting internal flow blockage (e.g.,
digital radiography) or internal visual inspections. The response also states that inspections will be performed by opening a flushing connection at the end of one [emphasis added by NRC]
main in each structure containing in-scope water-based fire suppression systems.
Issue:
The staff notes that the National Fire Protection Association (NFPA) 25, Section 14.2.2, requires an internal inspection of every other wet pipe system (in buildings with multiple wet pipe systems) and that the alternate systems (not inspected during the previous inspection) be inspected during the next inspection. Since the response only stated that one main in each structure will be opened, it is not clear whether there are multiple wet pipe systems in any of the structures containing in-scope fire water systems and, if so, whether all wet pipe systems will be inspected as stated in NFPA 25.
The staff also notes that LR-ISG-2012-02 AMP XI.M27 Table 4a limits the alternative NDE methods, which are permitted by NFPA 25, Sections 14.2.1.1 and 14.3.2.3, to those that can ensure that flow blockage will not occur. Because of its similarity to raw water applications in fire water systems, the staff further notes that the Electric Power Research Institute (EPRI)
TR-102063, Guide for the Examination of Service Water System Piping, cites radiography as an effective NDE method capable of measuring the extent of occlusions or biofouling conditions.
Although the EPRI guide includes ultrasonic testing, the discussion of its capability is limited to wall thickness measurement. Because the response proposes digital radiography as an example and not the only method, it was not clear how other NDE methods, if used, would be shown to ensure that flow blockage will not occur demonstrated to be capable of detecting flow blockage.
ENCLOSURE 2
Request:
- 1. State whether there are multiple wet pipe systems in any of the structures containing in-scope fire water systems and, if there are, confirm that internal inspections will be conducted as stated in NFPA 25, Section 14.2.2, or provide the basis for not conducting the internal inspections on every other wet pipe system every 5 years.
- 2. If NDE methods other than digital radiography are used, state how the other NDE methods will be demonstrated to be capable of detecting flow blockage.
Discussion: The applicant requested clarity on the staffs concern. The applicant requested the last sentence of the issue section be edited as shown by the strikethrough and underlined portion of the text. This question will be sent as part of the formal request titled: RAI B.2.1.16-1a.
DRAI B.2.1.16-1b Applicability:
Byron and Braidwood
Background:
RAI B.2.1.16-1 requested that either: (a) it is confirmed that follow-up volumetric examinations will be conducted whenever internal fire water system visual inspections detect surface irregularities indicative of material loss below nominal wall thickness [emphasis added by NRC]; or (b) the bases be provided for why the visual inspection alone will provide reasonable assurance that the current licensing basis intended functions of in-scope components will be met.
The applicants response, dated March 13, 2014, to RAI B.2.1.16-1 states that noticeable deposits in excess of a normal oxide layer, which could be indicative of wall loss below nominal, are documented; inspection results that are unusual or unexpected (e.g., surface irregularities indicative of significant loss of material [emphasis added by NRC]) are documented in the corrective action program for evaluation; and, based on the results of the evaluation, appropriate corrective actions are taken including repair, replacement, or follow-up volumetric examinations to quantify the remaining wall thickness, as applicable.
Issue:
The staff noted that LR-ISG-2012-02 AMP XI.M27 states that, [i]nternal visual inspections used to detect loss of material are capable of detecting surface irregularities that could be indicative of wall loss below nominal pipe wall thickness due to corrosion and corrosion product deposition. Where such irregularities are detected, followup volumetric examinations are performed. Based on the wording surface irregularities indicative of significant loss of material, it is not clear to the staff that surface irregularities indicative of wall loss below nominal would be documented in the corrective action program. It is also not clear to the staff that volumetric wall thickness measurements would be conducted when visual inspection results reveal surface irregularities that could be indicative of wall loss below nominal pipe wall thickness.
Request:
- 1. State whether surface irregularities indicative of wall loss below nominal would be documented in the corrective action program.
- 2. State whether volumetric wall thickness measurements would be conducted when visual inspection results reveal surface irregularities that could be indicative of wall loss below nominal pipe wall thickness.
- 3. If not, state the basis for the portion(s) of the response that represent an exception to LR-ISG-2012-02 AMP XI.M27.
Discussion: The applicant requested clarity on the staffs concern. The applicant discussed their concern with the staffs position of using below nominal wall thickness as the basis for conducting follow-up inspections. The staff decided to keep the question as written and not make any edits. This question will be sent as part of the formal request titled: RAI B.2.1.16-1b.
DRAI 3.5.2.10-1
Background:
Title 10 of the Code of Federal Regulations (10 CFR) Part 54.21 (a)(3) states that for structures and components (SCs) subject to an aging management review (AMR) it shall be demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) for the period of extended operation (PEO).
LRA Table 3.5.2-10, Main Steam & Auxiliary Feedwater Tunnels and Isolation Valve Rooms Summary of Aging Management Evaluation, states that polymer blowout panels exposed to air-indoor (uncontrolled) or air-outdoor will be managed for change in material properties by the Structures Monitoring Program. The AMR items cite generic note J, which states that neither the component nor the material and environment combination is evaluated in NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2. The AMR items also cite plant specific note 1, which states that the blowout panels are constructed of extruded polystyrene.
Issue:
Although the scope of the Structures Monitoring Program has been enhanced to include inspection of blowout panels, the parameters monitored or inspected and acceptance criteria for this material have not been specified in the program elements. Unlike GALL Report aging management programs (AMPs) XI.M36, External Surfaces Monitoring of Mechanical Components and XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, GALL Report AMP XI.S6, Structures Monitoring Program, does not include examples of inspection parameters for polymeric components. Based on the staffs review of this material exposed to an air-indoor and air-outdoor environment, the staff noted that at high temperatures, this material may begin to degrade. The staff does not have sufficient information to conclude that the visual inspections performed under the Structures Monitoring Program would identify a change in material properties, prior to a loss of intended function.
Request:
State how the visual inspections performed under the Structures Monitoring Program would identify a change in material properties for these components, and provide the acceptance criteria by which they would be evaluated.
Discussion: The applicant requested clarity on the staffs concern. No edits were proposed.
This question will be sent as part of the formal request titled: RAI 3.5.2.10-1.