JAFP-19-0009, End of Interval Relief Request Associated with the Fourth Ten-Year Inservice Inspection (ISI) Interval

End of Interval Relief Request Associated with the Fourth Ten-Year Inservice Inspection (ISI) Interval

ML19017A005
Person / Time
Site:	FitzPatrick
Issue date:	01/15/2019
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-19-0009
Download: ML19017A005 (5)

Text

Exelon Generation .~

200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.55a JAFP-19-0009 January 15, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

End of Interval Relief Request Associated with the Fourth Ten-Year lnservice Inspection (ISi) Interval

References:

1) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "End of Interval Relief Request Associated with the Fourth Ten-Year lnservice Inspection (ISi) Interval," dated July 26, 2018

2) Email from B. Venkataraman (U.S. Nuclear Regulatory Commission) to T. Loomis (Exelon Generation Company, LLC), "FitzPatrick- REQUEST FOR ADDITIONAL INFORMATION Re: Relief Request No. 14R-22, for fourth 10-Year lnservice Inspection Interval (EPID:L-2018-LLR-0103),"

dated December 19, 2018 In the Reference 1 letter, in accordance with 10 CFR 50.55a, "Codes and standards,"

paragraph (g)(5)(iii), Exelon Generation Company, LLC (Exelon), requested relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components." This relief request applied to the fourth ten-year lnservice Inspection (ISi) interval, which concluded on July 31, 2017, for the James A. FitzPatrick Nuclear Power Plant. The fourth ten-year ISi interval complied with the ASME Boiler and Pressure Vessel Code, Section XI, 2001 Edition with 2003 Addenda.

In the Reference 2 email, the U.S. Nuclear Regulatory Commission Staff requested additional information. Attached is our response.

End of Interval Relief Request Associated with the Fourth Ten-Year lnservice Inspection (ISi) Interval January 15, 2019 Page2 There are no regulatory commitments in this letter.

If you have any questions concerning this letter, please contact Tom Loomis at (61 O) 765-5510.

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

Attachment:

Response to the Request for Additional Information - Relief Request 14R-22 cc: Regional Administrator, Region I, USNRC USNRC Senior Resident Inspector, JAFNPP Project Manager USNRC, JAFNPP A. L. Peterson, NYSERDA

Attachment Response to the Request for Additional Information - Relief Request 14R-22

Response to Request for Additional Information Page 1 Question:

RAl-1 (a) Consistent with the criterion addressed in Note 3 of Table 1 of the Code Case N-578-1, the staff requests that the licensee provide a summary of its engineering evaluation for accepting the examination coverage that is less than essentially 100% for the welds in the table below.

This evaluation should include justification for not examining additional or alternative accessible welds in different categories e.g., B-F and B-J, in order to supplement the inspection results (with reduced area/volume of coverage) obtained from the examinations performed on the welds in the table below during the fourth 10-year ISi interval. If inspections of B-F and B-J welds that are similar to the subject welds (with respect to susceptibility to IGSCC) were performed during the fourth 10-year ISi interval, provide a summary of the inspection results.

Response

For the RI-ISi weld population, Examination Category R-A welds submitted in this relief request, a case by case review was performed to determine whether additional or alternative welds could have been examined to supplement the reduced volumetric coverage examination. It was determined that there were no other welds to select that would have resulted in better coverage. This determination was made based on comparison of configurations, delta core damage frequency (CDF) values, the systems involved, and inspection history. During outages, when situations were identified where coverage was an issue, personnel reviewed the systems for alternatives.

In addition to the above, the James A. FitzPatrick Nuclear Power Plant began using Hydrogen Water Chemistry controls in 1988, Noble Metals Chemical Application in 1999, and has been using Online Noble Chemical Addition since 2011.

Question:

(b) Provide the results of the previous examination coverage that was obtained for the welds as shown in the table below during the third 10-year ISi interval.

Response

For the lntergranular Stress Corrosion Cracking (IGSCC) augmented inspection population (147 total welds), the examination history shows satisfactory results for the fourth interval.

Two welds were identified during the fourth interval that required weld overlays. For welds included in the augmented inspection population, the James A. FitzPatrick Nuclear Power Plant utilizes the Hydrogen Water Chemistry/Noble Metals Chemical Application inspection interval and the Normal Water Chemistry inspection interval such that each Hydrogen Water Chemistry/Noble Metals Chemical Application treated weld is examined at least once every ten years and each Normal Water Chemistry weld is examined at least once every six years.

Additional Information Associated with this Relief Request:

Attached are corrections associated with Sequence Number 1.27 (weld Number BH 1-A) and Sequence Number 1.28 (Weld Number N3-A). These welds should be listed as "No" for Appendix VIII Qualified Exams. Attached is the corrected welds.

Response to Request for Additional Information Page2 Table 14R-22.1 James A. FitzPatrick Nuclear Power Plant List of Components with Limited Examination Coverage -

Sequence Class, Weld Material 1 and Material 2 Material 3 and Product Examination Examination Applicable Normal Appendix Number and Category Description Product Form Weld Form Code Limitations and Figures and Operating VIII Weld and Item Coverage Results Tables Conditions Qualified Identification No. Obtained' (Pressure/ Exam Number Temperature) 1.27 Class2 West CAD Head: Carbon Weld: Ferritic Shell: 24" Schedule BO UT=42.1Cl"/o Limitations From Location 1040 psig I No Scram Steel - Dished Steel Pipe, SA-106 Gr. C Shell Side Due to Figure 1-6, 550F BH1-A C-A Discharge Head-SA516 Bottom Head Figures 1 Instrument Gr. 70 Configuration, 1to1-27-4 C1.20 Volume Tank Support Brackets "A" Shell-to- and Weldolets Bottom Head with One Recordable Indication Dispositioned as an Isolated Geometric Root Reflector with No Through Wall Extent 1.28 Class 2 20" A AHR Nozzle: Weld: Ferritic Head: Carbon Steel - UT=73.10% Limitation No Location 400 psig I 450 No Heat Carbon Steel - Steel SA516 Gr. 70 Plate Axial Scan from Figure 1-7, F N3-A C-B Exchanger SA106 GR B MT= 100% Nozzle Side of Figure 1-28-1 Nozzle-to- Pipe Weld and Limited C2.21 Head Weld Scan Length of 2" Due to Adjacent N7-A Nozzle with No Recordable Indications