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| | number = ML091600307 | | | number = ML091600307 |
| | issue date = 06/09/2009 | | | issue date = 06/09/2009 |
| | title = Calvert Cliffs, Units, 1 & 2 - Response to Request for Additional Information Concerning Relief Request ISI-04-04 | | | title = Units, 1 & 2 - Response to Request for Additional Information Concerning Relief Request ISI-04-04 |
| | author name = | | | author name = |
| | author affiliation = Calvert Cliffs Nuclear Power Plant, Inc, Constellation Energy Group | | | author affiliation = Calvert Cliffs Nuclear Power Plant, Inc, Constellation Energy Group |
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MONTHYEARML0904001862009-02-12012 February 2009 Acceptance Review of Relief Request ISI-04-04-Calvert Cliffs Nuclear Power Plant, Units 1 and 2-(TAC ME0298 and ME0299) Project stage: Acceptance Review ML0905401222009-02-24024 February 2009 Acceptance Review of Relief Requests ISI-04-01 Through ISI-04-04-Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 Project stage: Acceptance Review ML0910303782009-04-27027 April 2009 Request for Additional Information Concerning the Risk Evaluation for the Fourth Ten-Year Interval Inservice Inspection Program Plan for Calvert Cliffs Nuclear Power Plant Units 1 and 2 (TAC Nos. ME0298 and ME0299) Project stage: RAI ML0911802362009-05-0505 May 2009 Request for Additional Information Relief Request No. ISI-04-04 - Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Project stage: RAI ML0913302472009-05-13013 May 2009 Response to Request for Additional Information - ASME Code Case N-747 Relief Request ISI-04-0 1 Project stage: Response to RAI ML0915302742009-06-0101 June 2009 Response to Request for Additional Information Concerning Relief Request ISI-04-04, Attachment 1 Project stage: Response to RAI ML0916003072009-06-0909 June 2009 Units, 1 & 2 - Response to Request for Additional Information Concerning Relief Request ISI-04-04 Project stage: Response to RAI ML0932200902009-11-19019 November 2009 Relief Requests for the Fourth 10-Year Interval Inservice Inspection Program Project stage: Other 2009-04-27
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Category:- No Document Type Applies
MONTHYEARML21211A1522021-10-0404 October 2021 Problem Identification & Resolution Inspection Document Request ML21194A0632021-07-13013 July 2021 Tabulation of Proposed Changes in License Amendment Request RS-20-140, Proposed Changes to Decommissioning Trust Agreements2020-10-30030 October 2020 Proposed Changes to Decommissioning Trust Agreements ML19135A1362019-05-15015 May 2019 Aam - Sign in Sheet ML18096A0102018-04-0404 April 2018 Annual Assessment Meeting 04/04/2018 Sign in Sheet ML16266A2302016-09-21021 September 2016 ASP Analysis Reject - Calvert Cliffs, Unit 2 Automatic Reactor Trip Due to Loss of Offsite Power to Safety Related Buses (LER-318-2015-002) ML15327A2242015-12-0101 December 2015 Strainer Head Loss Test 6 Rejection ML15114A3872015-04-16016 April 2015 4/16/2015 - Calvert Cliffs 2014 Annual Assessment Meeting Sign-In Sheet ML15051A4102015-02-17017 February 2015 Evaluation of Risk Significance of Permanent ILRT Extension ML15092A3752015-02-0202 February 2015 IP 95001 Entrance and Exit Meeting Attendance Sheets ML13364A2832013-12-30030 December 2013 Announcement of 2014 Generic Fundamentals Examination Administration Dates-Letter Dated Dec 30, 2013 ML13319A7252013-11-0404 November 2013 CCNPP-CHLE-009 Rev 2 Considerations for Using Marinite in CE Testing ML12349A2852012-11-0909 November 2012 Seismic Walkdown Checklist, 1A1 Diesel Engine - Page C-150 - Page C-243 ML12349A2842012-11-0909 November 2012 Seismic Wlakdown Checklists, Fuel Oil Storage Tink 21 - Page C-51 - Page C-149 ML12056A0522012-03-12012 March 2012 Enclosure 6 - List of Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status RS-11-167, Final Effective Joint Proxy Statement/Prospectus Relating to Application for Approval of Indirect Transfer of Control of Licenses2011-10-11011 October 2011 Final Effective Joint Proxy Statement/Prospectus Relating to Application for Approval of Indirect Transfer of Control of Licenses ML1127100332011-09-28028 September 2011 ROP Tabletop Examples and Results ML1120201642011-07-21021 July 2011 Operations Plan for Technical Assistance in Calvert Cliffs Independent Spent Fuel Storage Installation License Renewals, Rev. 2, Chg. 0 ML1002615342010-01-26026 January 2010 Attachment (1), SER Restrictions for Calvert Cliffs ML1001100642009-11-20020 November 2009 Biennial Problem Identification and Resolution Inspection Exit Meeting Roster for 11-20-2009, NRC Inspection Report 2009-007 ML0916003072009-06-0909 June 2009 Units, 1 & 2 - Response to Request for Additional Information Concerning Relief Request ISI-04-04 ML0915302742009-06-0101 June 2009 Response to Request for Additional Information Concerning Relief Request ISI-04-04, Attachment 1 ML0905704862009-02-26026 February 2009 Attachment (1), Summary of Calvert Cliffs, Unit 2 Deviation from MRP-139, Requirements ML0903706532009-02-0606 February 2009 Enclosure 1 - Problem Specification Sent to ORNL ML0903706662009-02-0606 February 2009 Enclosure 2 - Detailed Results Received from ORNL ML0836500592008-12-29029 December 2008 Response to Request for Additional Information Dated October 15, 2008 - Measurement Uncertainty Recapture Power Uprate ML0831703712008-11-12012 November 2008 Attachment 1, Alternative Pressure Boundary Requirements During Class 1 System Pressure Tests, Request for Alternative Relief Request PT-3-01 ML0817101052008-06-18018 June 2008 Attachment 1, Request for Extension of the Completion Date for Corrective Actions Related to Generic Letter 2004-02 ML0812303862008-05-0101 May 2008 Attachment (1) - Proposed Alternative ISI-020 in Accordance with 10 CFR 50.55a(a)(3)(i) - Alternative Provides Acceptable Level of Quality and Safety ML0810904932008-04-0808 April 2008 Annual Assessment Meeting Attendance List ML0734504992007-12-10010 December 2007 Attachment (1) Request for Extension of the Completion Date for Corrective Actions Related to Generic Letter 2004-02 ML0732400242007-10-25025 October 2007 Examples of Max Thermal Power License Conditions ML0726301142007-09-14014 September 2007 / P. Paquin Ltr Amendment to Certificate of Compliance No. 9208 for the Model No. 10-142B Package (TAC L24117)/S121170 ML0726303192007-09-14014 September 2007 P. Paquin Ltr Amendment to Certificate of Compliance No. 6574 for the Model No. 3-82B Package (TAC L24116)/ Register User List ML0729901542007-06-21021 June 2007 Inspection Request - Calvert Cliffs PI&R 2007-007 ML0715005442007-05-22022 May 2007 Attendance List for Calvert Cliffs Annual Assessment Meeting ML0727401082006-12-18018 December 2006 Differing Professional Opinion from E. Marinos ML0634705992006-12-14014 December 2006 Plant Service List ML0727105902006-06-0101 June 2006 Et/Lt Brief on the Status of the Measurement Uncertainty Recapture Issue ML0534604122005-11-18018 November 2005 Inspection Request Summary: Calvert Cliffs PI&R - IR 2005-07 ML0727104842005-11-15015 November 2005 Ufm Review Status and Anticipated Resolution Process ML0424005762004-08-18018 August 2004 72-8 Service List ML0404104922004-02-20020 February 2004 Order EA-03-009 Service List ML0331405822003-09-30030 September 2003 License Amendment Request: Increase the Unit 2 Spent Fuel Pool Maximum Enrichment Limit with Soluble Boron and Burnup Credit, Continuation of Attachment 5 Through 6 ML0331405812003-09-30030 September 2003 License Amendment Request: Increase the Unit 2 Spent Fuel Pool Maximum Enrichment Limit with Soluble Boron and Burnup Credit, Attachments 1 Through 5 ML0310504022003-03-31031 March 2003 Calvert Cliffs Annual Assessment Meeting NRC Public Meeting Feedback Form ML0309903832003-03-31031 March 2003 Annual Assessment Meeting Attendance List ML0203201882002-01-29029 January 2002 Attachment 1 to Ltr Dated 01/29/02 Re Calvert Cliffs Nuclear Power Plant Unit No. 2; Docket No. 50-318 Request for Regional Enforcement Discretion 2021-07-13
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Text
Calvert Cliffs Nuclear Power Plant, Inc.
June 9, 2009 ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON RELIEF REQUEST ISI-04-04
ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON RELIEF REQUEST ISI-04-04 1 NRC RAI 1: Section 3.3.1 of your submittal dated December 29, 2008, addresses Additional Examinations. The submittal states in part that, "The process for ordinary flaws is to perform the evaluation using ASME Code,Section XI."
Please explain the term "ordinary flaws" and/or confirm that all flaw evaluations are performed using ASME Code,Section XI.
CCNPP Response
- "Ordinary flaws" refers to the normal process of evaluating flaws and all flaw evaluations are performed using American Society of Mechanical Engineers (ASME) Code,Section XI.
NRC RAI 2: Table IWB-2500-1 of American Society of Mechanical Engineers,Section XI, 2001 Edition with 2004 Addenda requires volumetric and/or surface examination of all Category B-F or B-J Pressure Retaining Dissimilar Metal Welds greater than nominal pipe size (NPS) 1. Based on recent findings of primary water stress-corrosion cracking in Alloy 82/182 dissimilar metal welds, the staff would like more information on your inspection plans for these welds in the 4th Interval ISI Plan for Calvert Cliffs Nuclear Power Plant (CCNPP).
Please describe the inspection plan of Alloy 82/182 dissimilar metal welds greater than NPS 1 in the 4th Interval ISI Plan for CCNPP (e.g., are they included in the RI-ISI program, how many are selected for examination, what examination method(s) are being employed, what is the frequency of examination, disposition of limited coverage (<90%) examinations, etc.).
CCNPP Response
- All Category B-F or B-J Alloy 82/182 dissimilar metal welds greater than NPS 1 included in CCNPP Section XI program were included in CCNPP ASME Code Case N-578 Risk Informed-Inservice Inspection (RI-ISI) program for the current interval, and are also included in the proposed CCNPP ASME Code Case N-716 risk-informed/safety-based inservice inspection (RIS_B) program for the fourth interval. The total population of these welds is 27 for each CCNPP unit. Per the criteria of Code Case N-716, seven of these welds (per unit) were determined to be susceptible to primary water stress corrosion cracking (PWSCC), and six of these welds (per unit) were selected for examination under the RIS_B program.
Per Code Case N-716 (Table 1, Item No. 1.15, "Elements Subject to Primary Water Stress Corrosion Cracking (PWSCC)"), selected butt welds are subject to volumetric examination. Per Note 3 of this Table, the exam includes essentially 100% of the examination location. When the required examination volume or area cannot be examined due to interference by another component or part geometry, limited examinations shall be evaluated for acceptability. Areas with acceptable limited examinations (coverage less than 90%), and their bases, shall be documented and submitted for relief per the requirements of 10 CFR 50.55a.
A plant augmented inspection program has been implemented at CCNPP to meet all the requirements of Materials Reliability Program (MRP)-139, Revision 1, for all butt welds greater than NPS 1. Materials Reliability Program-139, Revision 1, provides requirements for the inspection and management of PWSCC-susceptible welds that are in addition to the requirements of Code Case N-716. Additionally, ATTACHMENT (1) RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON RELIEF REQUEST ISI-04-04 2 MRP-139, Revision 1, specifies requirements for welds with limited examinations (coverage less than 90%) such as the consideration of augmented non-destructive examination methods with technical bases, performing a degradation assessment for any volume that remains unexamined due to the limitation and to consider mitigation. Further, per MRP-139, Revision 1, some welds may be required to be examined multiple times during the interval in addition to the examination required by Code Case N-716. The RIS_B program has not and will not be used to eliminate any required MRP-139 examinations or requirements.
NRC RAI 3: On page 10, the licensee provides guidance in Section 3.3.2 "Program Relief Requests." For program relief requests, the licensee refers to the process outlined in Title 10 of the Code of Federal Regulations 50.55a that will be used. Please discuss how the effect on risk of the incomplete examination coverage will be assessed.
CCNPP Response
- Per footnote 3 of Table 1 of Code Case N-716, when the required examination volume or area cannot be examined due to interference by another component or part geometry, limited examinations shall be evaluated for acceptability. Acceptance of limited examinations or volumes shall not invalidate the results of the change-in-risk evaluation (paragraph 5 of Code Case N-716). The change in risk evaluation of Code Case N-716 is consistent with previous risk-informed ISI applications (e.g., EPRI TR-112657) and meets Regulatory Guide 1.174 change in risk acceptance criteria. Areas with acceptable limited examinations, and their bases, shall be documented.
Consistent with previously approved RI-ISI submittals [e.g., Waterford 3 Safety Evaluation (Reference 1)], Constellation will continue to calculate coverage and use additional examinations and techniques in the same manner it has for traditional Section XI examinations.
Experience has shown this process to be weld-specific (e.g., joint configuration). As such the effect on risk, if any, will not be known until that time. Relief requests, if needed, will be submitted per the guidance of 10 CFR 50.55a(g)(5)(iv).
REFERENCE 1. Letter from Mr. T. G. Hiltz (NRC) to Vice President, Operations (Entergy Operations) dated April 28, 2008, Waterford Steam Electric Station, Unit 3 - Request for Alternative W3-ISI-005, Request to use ASME Code Case N-716