NMP1L3279, Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants

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

ML19122A307
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:	05/01/2019
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L3279, RS-19-055, TMI-19-045
Download: ML19122A307 (6)

Text

Exelon Generation ~

200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-19-055 NMP1L3279 TMl-19-045 May 1, 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 N RC 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 NRG 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 N RC Docket Nos. 50-373 and 50-37 4 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 N RC Docket Nos. 50-352 and 50-353

Response to Request for Additional Information Proposed Alternatives to Utilize Code Cases N-878 and N-880 May 1, 2019 Page2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRG Docket Nos. 50-220 and 50-41 O 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 NRG Docket Nos. 50-254 and 50-265 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRG Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRG Docket No. 50-289

Subject:

Response to Request for Additional Information - Proposed Alternatives 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 8. 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 1o, 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 Alternatives to Utilize Code Cases N-878 and N-880 May 1, 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 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 6 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.

Res/'Tcttully,

{Al(,._,__ J-r L J~

David T. Gudger Manager - 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 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

Response to Request for Additional Information Proposed Alternatives to Utilize Code Cases N-878 and N-880 May 1, 2019 Page 4 cc (continued):

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 Alternatives to Utilize Code Cases N-878 and N-880 Page 1 of 1 Question:

For repair/replacement activities where the construction code is Section Ill of the ASME BPV Code, explain how Exelon will ensure that the requirements of Section Ill will be met when the design and testing activities associated with the qualification of non-welded and welded fittings is performed by a fabricator that does not have a QA program in accordance with Appendix B to 10 CFR Part 50, NQA-1, or ASME Certificate of Authorization. The response should address:

(1) review of design documentation; (2) the performance of the fabricator's qualification testing of fittings used to ensure compliance with the Owner's design specifications and paragraphs NB/NC/ND-3671.7 of ASME BPV Code, Section Ill; and (3) Authorized Nuclear lnservice Inspector involvement.

Response

The subject of the relief request is material procurement and fabrication by an organization not holding ASME accreditation or a 10 CFR 50, Appendix B Quality Assurance Program. The relief request does not ask for any relief from compliance with NB/NC/ND-3671.7 or any other Section Ill design requirement or any Appendix B design or test control requirement. These requirements will be met by Exelon as they would for any design activity. Piping system and fitting design activities will be performed or supervised only by appropriately-qualified suppliers. Exelon will be responsible for preparation and review of the design documentation for the use of the fittings. Exelon will either perform the piping system design applicable to use of the fittings or will commission a vendor qualified in accordance with 10 CFR 50, Appendix B to perform this design, in accordance with all applicable Section Ill design requirements, including those of NB/NC/ND-3671.7. The piping system designer will be responsible for verification and acceptance of applicable prototype qualification test results, in accordance with NB/NC/ND-3671.7, under a Quality Assurance Program complying with 10CFR50, Appendix B, Criterion Ill. The designer will be responsible for ensuring that prototype qualification test results comply with 10 CFR 50, Appendix B, Criterion XI. As required by Section XI, IWA-4170, the Authorized Nuclear lnservice Inspector will be given an opportunity to review the design activities, including verification of design documents, including prototype fitting test data, by reviewing the records at or before the time at which the piping systems containing the fittings are returned to service.