JAFP-19-0057, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880

Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880

ML19155A214
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	06/04/2019
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-19-0057, NMP1L3289, RS-18-065, TMl-19-060
Download: ML19155A214 (7)

Text

200 Exelon Way Exelon Generation © Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-18-065 NMP1L3289 JAFP-19-0057 TMl-19-060 June 4, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRG Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 N RC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRG Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRG Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRG Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRG Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRG Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRG Docket Nos. 50-352 and 50-353

Response to Request for Additional Information Proposed Alternative to Utilize Code Cases N-878 and N-880 June 4, 2019 Page2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880

References:

1) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Proposed Alternative to Utilize Code Cases N-878 and N-880," dated May 30, 2018

2) Letter from B. Purnell (U.S. Nuclear Regulatory Commission) to B.

Hanson (Exelon Generation Company, LLC), Supplemental Information Needed for Acceptance of Requests to Use ASME Code Cases N-878, N-879, and N-880, dated July 10, 2018

3) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Proposed Alternatives to Utilize Code Cases N-878, N-879, and N-880," dated July 26, 2018

4) Email from B. Purnell (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), "Exelon Generation Company, LLC -

Fleet Request to use ASME Code Cases N-878 and N-880 (EPID L-2018-LLR-0077)," dated December 11, 2018

5) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880," dated January 8, 2019

Response to Request for Additional Information Proposed Alternative to Utilize Code Cases N-878 and N-880 June 4, 2019 Page 3

6) Email from B. Purnell (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), "Exelon Generation Company, LLC -

Fleet Request to use ASME Code Cases N-878 and N-880 (EPID L-2018-LLR-0077)," dated April 24, 2019

7) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880," dated May 1, 2019

8) Email from B. Purnell (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), "Exelon Generation Company, LLC -

Request for Additional Information Regarding Fleet Request to use ASME Code Cases N-878 and N-880 (EPID L-2018-LLR-0077)," dated May 22, 2019 In the Reference 1 letter, in accordance with 10 CFR 50.55a(z)(2), Exelon Generation Company, LLC (Exelon) requested proposed alternatives to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," on the basis that compliance with the code results in hardship without a compensating increase in quality. Specifically, these proposed alternatives requested the use of Code Case N-878 ("Alternative to QA Program Requirements of IWA-4142 Section XI, Division 1") and N-880 ("Alternative to Procurement Requirements of IWA-4143 for Small Nonstandard Welded Fittings Section XI, Division 1"), which address the procurement of material from a material supplier that does not possess ASME accreditation as a Quality System Certificate Holder or an NPT Certificate Holder.

In the Reference 8 email, the U.S. Nuclear Regulatory Commission requested additional information. Attached is our response.

There are no regulatory commitments contained in this letter.

If you have any questions, please contact Tom Loomis (610) 765-5510.

Respectfully, James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880

Response to Request for Additional Information Proposed Alternative to Utilize Code Cases N-878 and N-880 June 4, 2019 Page4 cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - James A. FitzPatrick Nuclear Power Plant NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - Quad Cities Nuclear Power Station NRC Project Manager - R. E. Ginna Nuclear Power Plant NRC Project Manager - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Department of Nuclear Safety R. R. Janati - Bureau of Radiation Protection, Commonwealth of Pennsylvania D. A. Tancabel - State of Maryland A. L. Peterson - NYSERDA

Attachment Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880

Response to Request for Additional Information Proposed Alternative to Utilize Code Cases N-878 and N-880 Page 1 Question:

For each plant, either ( 1) limit the scope of the request to the current 10-year in service test interval or (2) identify the specific ASME Code edition and addenda applicable to future 10-year inservice test intervals in which the proposed alternative will be used. In addition, provide a basis for each plant where use of the alternative is requested beyond the current interval.

Response

The subject relief will be limited to a 10-year inservice inspection intervals as shown below.

PLANT INTERVAL EDITION START END Braidwood Station, Units Fourth 2013 Edition August 29, 2018 July 28, 2028 1and2 October 17, 2018 October 16, 2028 Byron Station, Fourth 2007 Edition, through 2008 July 16, 2016 July 15, 2025 Units 1 and 2 Addenda Calvert Cliffs Nuclear Fifth 2013 Edition July 1, 2019 June 30, 2029 Power Plant, Units 1 and 2

Clinton Power Station, Third 2004 Edition July 1, 2010 June 30, 2020 Unit 1 Clinton Power Station, Fourth 2013 Edition July 1, 2020 June 30, 2030 Unit 1 Dresden Nuclear Power Fifth 2007 Edition, through 2008 January 20, 2013 January 19, 2023 Station, Units 2 and 3 Addenda James A. FitzPatrick Fifth 2007 Edition, through 2008 August 1, 2017 June 15, 2027 Nuclear Power Plant Addenda LaSalle County Stations, Fourth 2007 Edition, through 2008 October 1, 2017 September 30, 2027 Units 1 and 2 Addenda Limerick Generating Fourth 2007 Edition, through 2008 February 1, 2017 January 31, 2027 Station, Units 1 and 2 Addenda Nine Mile Point Nuclear Fifth 2013 Edition August 23, 2019 August22,2029 Station, Unit 1 Nine Mile Point Nuclear Fourth 2013 Edition October 6, 2018 August 22, 2028 Station, Unit 2 Peach Bottom Atomic Fifth 2013 Edition January 1, 2019 December 31, 2028 Power Station, Units 2 and 3

Response to Request for Additional Information Proposed Alternative to Utilize Code Cases N-878 and N-880 Page 2 PLANT INTERVAL EDITION START END Quad Cities Nuclear Fifth 2007 Edition, through 2008 April 2, 2013 April 1, 2023 Power Station, Units 1 Addenda and2 A. E. Ginna Nuclear Fifth 2004 Edition January 1, 2010 December 31, 2019 Power Plant R. E. Ginna Nuclear Sixth 2013 Edition January 1, 2020 December 31, 2029 Power Plant Three Mile Island Nuclear Fourth 2004 Edition April 20, 2011 April 19, 2022 Station, Unit 1