RS-13-142, Relief Request Associated with the Third 10-Year Inservice Inspection Program Interval
| ML13149A144 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/28/2013 |
| From: | Gullott D Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-13-142 | |
| Download: ML13149A144 (4) | |
Text
4300 Winfield Road Warrenville, IL 60555 Exeton Generation, RS-13-142 10 CFR 50.55a May 28, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN-50-456 and STN-50-457
Subject:
Relief Request Associated with the Third 10-Year Inservice Inspection Program Interval In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (a)(3)(i), Exelon Generation Company, LLC, (EGC) hereby requests NRC approval of the attached relief request associated with the Third 10-year Inservice Inspection (ISI) Program Interval for Braidwood Station, Units 1 and 2. The third interval of the Braidwood Station ISI program complies with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2001 Edition through the 2003 Addenda.
NRC approval of the attached relief is requested on the basis that performing visual examinations of Braidwood Station, Units 1 and 2 containment liners during post repair pressure test as required by IWE-5240 are not possible due to the containments inaccessibility during the pressure test.
The details of the 10 CFR 50.55a request are enclosed. EGC requests approval of this relief request by September 6, 2013 to support the upcoming Braidwood Station, Unit 1 refueling outage (Al R17) scheduled to commence on September 9, 2013.
630 657 2000 Office 1
Exelon Generation(£)
RS-13-142 May 28,2013 U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN-50-456 and STN-50-457 4300 Winfield Road Warrenville. IL 60555 630 657 2000 Office 10 CFR 50.55a
Subject:
Relief Request Associated with the Third 10-Year Inservice Inspection Program Interval In accordance with 10 CFR 50.55a, IICodes and standards," paragraph (a)(3)(i), Exelon Generation Company, LLC, (EGC) hereby requests NRC approval of the attached relief request associated with the Third 10-year Inservice Inspection (lSI) Program Interval for Braidwood Station, Units 1 and 2. The third interval of the Braidwood Station lSI program complies with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, IIRules for Inservice Inspection of Nuclear Power Plant Components, II 2001 Edition through the 2003 Addenda.
NRC approval of the attached relief is requested on the basis that performing visual examinations of Braidwood Station, Units 1 and 2 containment liners during post repair pressure test as required by IWE-5240 are not possible due to the containments inaccessibility during the pressure test.
The details of the 10 CFR 50.55a request are enclosed. EGC requests approval of this relief request by September 6, 2013 to support the upcoming Braidwood Station, Unit 1 refueling outage (A1 R17) scheduled to commence on September 9,2013.
May 28, 2013 U. S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Ms. Dwi Murray at (630) 657-3695.
Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC
Attachment:
10 CFR 50.55a Relief Request 13R-13 cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRR Project Manager, Braidwood Station Illinois Emergency Management Agency -- Division of Nuclear Safety May 28,2013 U. S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Ms. Dwi Murray at (630) 657-3695.
Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC
Attachment:
10 CFR 50.55a Relief Request 13R-13 cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRR Project Manager, Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety
ATTACHMENT 10 CFR 50.55a RELIEF REQUEST 13R-13 Request for Relief for Alternative Requirements due to Applicability of ASME Code Case N-649, Alternative Requirements for IWE-5240 Visual Examination In Accordance with 10 CFR 50.55a(a)(3)(i)
Revision 0 Page 1 of 2 1.0 ASME CODE COMPONENTS AFFECTED:
Code Class:
Reference:
Examination Category:
Item Number:
==
Description:==
Component Number:
MC ASME Code Case N-649 and IWE-5240 N/A N/A Applicability of ASME Code Case N-649, Alternative Requirements for IWE-5240 Visual Examination Various 2.0 APPLICABLE CODE EDITION AND ADDENDA:
The Third Interval Inservice Inspection (ISI) program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2001 Edition through the 2003 Addenda.
3.0 APPLICABLE CODE REQUIREMENT:
ASME Section XI, Paragraph IWE-5240, "Visual Examination," requires that a detailed visual examination (IWE-2310) be performed during IWE-5220 required pressure test on areas affected by repair/replacement activities.
ASME Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination,"
allows for a VT-3, VT-1, or detailed visual examination depending on the timing of the pressure test.
4.0 REASON FOR REQUEST:
Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.
Braidwood Station, Units 1 and 2 have concrete containments with metal liners. Recent performance of augmented examinations for the containment liner plate identified additional degradation in normally inaccessible areas directly below the moisture barrier during Unit 1 refueling outage (April 2009) and Unit 2 refueling outage (October 2012).
The repairs that are required to be performed on the containment liners are scheduled for the upcoming refueling outages for Unit 1 (September 2013) and Unit 2 (May 2014).
Paragraph IWE-5240 requires that a detailed visual examination of repaired areas be completed during a post repair pressure test. The integrated leakage rate tests (ILRT) required by 10 CFR 50, Appendix J are scheduled during these refueling outages.
However, the IWE-5240 visual examination can not be performed because the ATTACHMENT 10 CFR 50.55a RELIEF REQUEST 13R-13 Request for Relief for Alternative Requirements due to Applicability of ASME Code Case N-649, Alternative Requirements for IWE-S240 Visual Examination In Accordance with 10 CFR 50.55a(a}(3}(i}
Revision 0 Page 1 of 2 1.0 ASME CODE COMPONENTS AFFECTED:
Code Class:
Reference:
Examination Category:
Item Number:
==
Description:==
Component Number:
MC ASME Code Case N w 649 and IWE*5240 N/A N/A Applicability of ASME Code Case N-649, Alternative Requirements for IWE-5240 Visual Examination Various 2.0 APPLICABLE CODE EDITION AND ADDENDA:
The Third Interval Inservice Inspection (lSI) program is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, 2001 Edition through the 2003 Addenda.
3.0 APPLICABLE CODE REQUIREMENT:
ASME Section XI, Paragraph IWE-5240, "Visual Examination, II requires that a detailed visual examination (IWE-2310) be performed during IWE-5220 required pressure test on areas affected by repair/replacement activities.
ASME Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination, II allows for a VT -3, VT -1, or detailed visual examination depending on the timing of the pressure test.
4.0 REASON FOR REQUEST:
Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.
Braidwood Station, Units 1 and 2 have concrete containments with metal liners. Recent performance of augmented examinations for the containment liner plate identified additional degradation in normally inaccessible areas directly below the moisture barrier during Unit 1 refueling outage (April 2009) and Unit 2 refueling outage (October 2012).
The repairs that are required to be performed on the containment liners are scheduled for the upcoming refueling outages for Unit 1 (September 2013) and Unit 2 (May 2014).
Paragraph IWE-5240 requires that a detailed visual examination of repaired areas be completed during a post repair pressure test. The integrated leakage rate tests (ILRT) required by 10 CFR 50, Appendix J are scheduled during these refueling outages.
However, the IWE-5240 visual examination can not be performed because the
ATTACHMENT 10 CFR 50.55a RELIEF REQUEST I3R-13 Request for Relief for Alternative Requirements due to Applicability of ASME Code Case N-649, Alternative Requirements for IWE-5240 Visual Examination In Accordance with 10 CFR 50.55a(a)(3)(i)
Revision 0 Page 2 of 2 containment liners are inaccessible durin the post repair pressure tests (i.e., personnel are not able to be inside the containment during ILRT).
In recognition of the inability of performing visual examinations of containment liners during the post repair pressure test required by Paragraph IWE-5240, ASME Code Case N-649 was issued to allow the visual examination to be performed during or after the pressure test on the areas affected by the repair/replacement activity. ASME Section XI did not address this inability in the Code until the 2004 Edition through the 2006 Addenda was issued; therefore, ASME Code Case N-649 is needed when using the 2001 Edition through the 2003 Addenda of ASME Section XI, which is applicable to the Braidwood Station Third Interval ISI program.
The "Applicability Index for Section XI Cases" contained in the 2001 Edition of the ASME Code, "Code Cases: Nuclear Components," states that ASME Code Case N-649 is applicable up to and including the 1998 Edition with the 2000 Addenda of ASME Section Xl. The Edition/Addenda referenced in the Code Case text itself also ends at the 1998 Edition with the 2000 Addenda. However, the requirements of Paragraph IWE-5240 are identical in both the 1998 Edition through the 2000 Addenda and the 2001 Edition through the 2003 Addenda. Therefore, it is concluded that the proposed alternative provided an acceptable level of quality and safety.
5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE:
Braidwood Station requests that the applicability of ASME Code Case N-649 be extended to the 2001 Edition through 2003 Addenda for use during the station's third ISI interval.
NRC Regulatory Guide 1.147, Revision 16, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," lists ASME Code Case N-649 as acceptable for use with no conditions or limitations.
6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the third ten-year ISI interval for Braidwood Station which is currently scheduled to end on July 28, 2018 for Unit 1 and October 16, 2018 for Unit 2.
7.0 PRECEDENTS
A similar relief request to extend the applicability of Code Case N-649 was approved for Three Mile Island Unit 1 (NRC Safety Evaluation Report dated July 20, 2011 - ADAMS Accession ML111730475).
ATTACHMENT 10 CFR 50.55a RELIEF REQUEST 13R-13 Request for Relief for Alternative Requirements due to Applicability of ASME Code Case N-649, Alternative Requirements for IWE-5240 Visual Examination In Accordance with 10 CFR 50.55a(a)(3)(i)
Revision 0 Page 2 of 2 containment liners are inaccessible during the post repair pressure tests (Le., personnel are not able to be inside the containment during ILRT).
In recognition of the inability of performing visual examinations of containment liners during the post repair pressure test required by Paragraph IWE-5240, ASME Code Case N-649 was issued to allow the visual examination to be performed during or after the pressure test on the areas affected by the repair/replacement activity. ASME Section XI did not address this inability in the Code until the 2004 Edition through the 2006 Addenda was issued; therefore, ASME Code Case N-649 is needed when using the 2001 Edition through the 2003 Addenda of ASME Section XI, which is applicable to the Braidwood Station Third Interval lSI program.
The "Applicability Index for Section XI Cases" contained in the 2001 Edition of the ASME Code, "Code Cases: Nuclear Components," states that ASME Code Case N-649 is applicable up to and including the 1998 Edition with the 2000 Addenda of ASME Section XI. The Edition/Addenda referenced in the Code Case text itself also ends at the 1998 Edition with the 2000 Addenda. However, the requirements of Paragraph IWE-5240 are identical in both the 1998 Edition through the 2000 Addenda and the 2001 Edition through the 2003 Addenda. Therefore, it is concluded that the proposed alternative provided an acceptable level of quality and safety.
5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE:
Braidwood Station requests that the applicability of ASME Code Case N-649 be extended to the 2001 Edition through 2003 Addenda for use during the station's third lSI interval.
NRC Regulatory Guide 1.147, Revision 16, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, II lists ASME Code Case N-649 as acceptable for use with no conditions or limitations.
6.0 DURATION OF PROPOSED ALTERNATIVE:
Relief is requested for the third ten-year lSI interval for Braidwood Station which is currently scheduled to end on July 28, 2018 for Unit 1 and October 16, 2018 for Unit 2.
7.0 PRECEDENTS
A similar relief request to extend the applicability of Code Case N-649 was approved for Three Mile Island Unit 1 (NRC Safety Evaluation Report dated July 20, 2011 - ADAMS Accession ML111730475).