NRC-05-0023, Request to Use Later Edition and Addenda of the ASME OM Code for Pressure Relief Valve Testing
| ML051230174 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/15/2005 |
| From: | O'Conner W DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-05-0023 | |
| Download: ML051230174 (3) | |
Text
NWilliam T. O'Connor, Jr.
V'icc President, Nuclear Generation Fermi 2 6400 North Dixie lHwsy, Newport, Michigan 48166 Tel: 734-586-5201 Fax: 734-586-4172 DTE Energy-10 CFR 50.55a(f)(4)(iv)
April 15, 2005 NRC-05-0023 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004
Subject:
Request to Use Later Edition and Addenda of the ASME OM Code for Pressure Relief Valve Testing Pursuant to 10 CFR 50.55a(f)(4)(iv), Detroit Edison hereby requests NRC approval to use the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance (OM) of nuclear power plants for Inservice Testing (IST) of pressure relief valves at Fermi 2.
10 CFR 50.55a(f)(4)(iv) permits the use of'subsequent editions and addenda of the ASME Code that have been incorporated by reference in paragraph 10 CFR 50.55a(b) subject to the limitations and modifications listed therein, and subject to approval by the Commission. It also permits the use of portions of editions and addenda provided that all related requirements of the respective editions and addenda are met.
Reference 2 states that "the staff has identified several instances in which nuclear power plants licensees have used portions of editions and addenda of the OM Code and/or B&PV Code issued after their Code of Record without requesting approval from the Commission." It also states that "the fact that these Code editions and addenda have been incorporated by reference into the regulations does not imply that 6DE
USNRC NRC-05-0023 Page 2 Commission approval has already been given. Licensees must request approval to use later Code editions and addenda via a letter to the NRC; they may not just update their IST or ISI program."
In response to Reference 2, Detroit Edison identified that a portion of a later edition of the ASME Code had been adopted in the IST program without obtaining a specific approval from the Commission.
Fermi 2 is currently in its second 10-year IST interval. The Code of Record approved for use in the second interval is the 1989 Edition of Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code. This edition of the Code requires the use of OM-1987, Part 1, for relief valves and OMa-1988, Parts 6 and 10, for pumps and valves, respectively.
Inservice testing of pressure relief valves at Fermi 2 was performed in accordance, with the 1989 Edition of the ASME B&PV (Code of Record) from the start of the second 10-year interval on February 17, 2000 until March 6,2003. At that time, Detroit Edison implemented a change' to the IST program to utilize the requirements of ASME OMa-1996, Appendix I, for testing pressure relief valves. A copy of the program change was submitted to the NRR Project Manager on March 6, 2003.
This change resulted inma revision to the acceptance tolerance for testing pressure relief valves with setpoints of 70 pounds per square inch (psi) or lower. In lieu of the 4 3 percent of set pressure tolerance per the 1989 Code edition, Appendix I of the 1996 Code edition allows the owner to establish and document the acceptance test tolerance for such valves based on the system and valve design or manufacturer specification. Accordingly, a + 2 psi tolerance was established and is documented in the implementing procedures as the acceptance tolerance from the nominal set pressure for pressure relief valves with setpoints of 70 psi or lower.
A review of testing records for pressure relief valves impacted by the IST program change indicates that all valves met the + 3 percent of set pressure acceptance tolerance with the exception of three valves. For these three valves, the test results fell between 0.25 and 0.80 psi lower than the + 3 percent tolerance; however, they were bounded by the 2 psi tolerance and are considered acceptable. '
In accordance with 10 CFR 50.55a(f)(iv) Detroit Edison requests approval to use the later edition of the ASME code as noted above for testing pressure relief valves at Fermi 2. Detroit Edison recognizes that 10 CFR 50.55a(f)(iv) requires that all related requirements of the respective editions and addenda must be met when the use of portions of the editions and addenda are authorized. In addition, Reference 2 states that "if portions of a later Code edition and addenda are used, licensees must assure
USNRC NRC-05-0023 Page 3 that all related requirements of the respective editions and addenda are met. A discussion of the related requirements should be included in the letter to the NRC."
Currently, paragraph 10 CFR 50.55a(b) endorses the 2001 Edition through the 2003 Addenda of the ASME OM Code with certain limitations and modifications. In addition to the general requirements in Subsection ISTA of the 2001 Edition through the 2003 Addenda of the ASME OM Code, Article ISTC-5240, "Safety and Relief Valves" states that safety and relief valves shall meet the inservice test requirements of Mandatory Appendix I. Therefore, the related requirements to testing pressure relief valves in the 2001 Edition through the 2003 Addenda of the ASME OM Code consist of Subsection ISTA and Mandatory Appendix I.
Based on the above, Detroit Edison is requesting NRC approval to use the 2001 Edition through the 2003 Addenda of the ASME OM Code for inservice testing of pressure relief valves. Specifically, this request is to use the ASME OM Code Subsection ISTA, "General Requirements," and Mandatory Appendix I, "Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants,"
for pressure relief valve testing at Fermi 2 for the remainder of the second 10-year interval. The 2001 Edition through the 2003 Addenda of the Code provides the same acceptance tolerance criterion as the 1996 edition for testing pressure relief valves with set points of 70 psi or lower.
Detroit Edison requests NRC approval of this change to the IST program by September 30, 2005. The requested date is based on the need to schedule and effectively implement pressure relief valve testing for the current second 10-year IST interval.
No-new commitments are being made in this letter.
Should you have any questions or require additional information, please contact Mr.
Norman K. Peterson of my staff at (734) 586-4258.
Sincerely, cc:
E. R. Duncan N. K. Ray NRC Resident Office Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission