ML052080215

Relief, Use a Subsequent Edition of ASME Code Examinations for the Third Inservice Inspection Interval

ML052080215
Person / Time
Site:	Callaway
Issue date:	08/18/2005
From:	Dan Collins NRC/NRR/DLPM/LPD4
To:	Naslund C Union Electric Co
Donohew J N, NRR/DLPM,415-1307
References
TAC MC6896
Download: ML052080215 (8)

Text

August 18, 2005 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - REQUEST FOR RELIEF TO USE A SUBSEQUENT EDITION OF ASME CODE EXAMINATIONS FOR THE THIRD INSERVICE INSPECTION INTERVAL (TAC NO. MC6896)

By letter dated April 27, 2005 (ULNRC-05143), the Union Electric Company (UEC) submitted a request to use a portion of a subsequent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at the Callaway Plant, Unit 1 (Callaway). Specifically, UEC requested to use Subparagraphs IWA-4520(a) and IWA-4520(b) of Section XI to the 2001 Edition of the ASME Code in lieu of the 1998 Edition through 2000 Addenda. The request is for the third 10-year inservice inspection (ISI) interval.

Based on the enclosed safety evaluation, the Nuclear Regulatory Commission (NRC) staff finds the licensees request to use the 2001 Edition of Section XI of the ASME Code, Subparagraphs IWA-4520(a) and IWA-4520(b) for the third 10-year ISI interval at Callaway acceptable provided that all related requirements are met, and subject to the limitations and modifications listed in paragraph 50.55a(b) of Title 10 of the Code of Federal Regulations (10 CFR). Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the request to use the 2001 Edition in lieu of the 1998 Edition through 2000 Addenda of Section XI of the ASME Code, Subparagraphs IWA-4520(a) and IWA-4520(b) is approved for the third 10-year ISI interval.

Sincerely,

/RA/

Daniel S. Collins, Acting Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Safety Evaluation cc w/encl: See next page

August 18, 2005 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - REQUEST FOR RELIEF TO USE A SUBSEQUENT EDITION OF ASME CODE EXAMINATIONS FOR THE THIRD INSERVICE INSPECTION INTERVAL (TAC NO. MC6896)

By letter dated April 27, 2005 (ULNRC-05143), the Union Electric Company (UEC) submitted a request to use a portion of a subsequent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at the Callaway Plant, Unit 1 (Callaway). Specifically, UEC requested to use Subparagraphs IWA-4520(a) and IWA-4520(b) of Section XI to the 2001 Edition of the ASME Code in lieu of the 1998 Edition through 2000 Addenda. The request is for the third 10-year inservice inspection (ISI) interval.

Based on the enclosed safety evaluation, the Nuclear Regulatory Commission (NRC) staff finds the licensees request to use the 2001 Edition of Section XI of the ASME Code, Subparagraphs IWA-4520(a) and IWA-4520(b) for the third 10-year ISI interval at Callaway acceptable provided that all related requirements are met, and subject to the limitations and modifications listed in paragraph 50.55a(b) of Title 10 of the Code of Federal Regulations (10 CFR). Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the request to use the 2001 Edition in lieu of the 1998 Edition through 2000 Addenda of Section XI of the ASME Code, Subparagraphs IWA-4520(a) and IWA-4520(b) is approved for the third 10-year ISI interval.

Sincerely,

/RA/

Daniel S. Collins, Acting Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-483 DISTRIBUTION:

PUBLIC

Enclosure:

Safety Evaluation PDIV-2 Reading TChan DNaujock DDuvigneaud RidsNrrDlpmPdiv (HBerkow) RidsOgcRp cc w/encl: See next page RidsNrrDlpmPdiv2 (RGramm) RidsNrrLALFeizollahi RidsAcrsAcnwMailCenter RidsNrrPMJDonohew RidsRegion4MailCenter (BJones)

ACCESSION NO.: ML052080215 NRR-028 OFFICE PDIV-2/PE PDIV-2/PM PDIV-2/LA EMCB/SC OGC PDIV-2/(A)SC NAME DDuvigneaud JDonohew LFeizollahi TChan MWoods DCollins DATE 8/12/05 8/18/05 8/15/05 06/22/2005 08/11/2005 8/18/05 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUEST FOR RELIEF TO USE A SUBSEQUENT EDITION OF THE ASME CODE UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By letter dated April 27, 2005, the Union Electric Company (the licensee) submitted a request to use a portion of a subsequent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee requested to use the 2001 Edition in lieu of the 1998 Edition through 2000 Addenda of the ASME Code,Section XI, Subparagraphs IWA-4520(a) and (b). The request is for the third 10-year inservice inspection (ISI) interval which begins on December 19, 2005, and ends on December 18, 2014. The second 10-year ISI interval ends December 18, 2005.

2.0 REGULATORY EVALUATION

The ISI of the ASME Code Class 1, 2, and 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by Paragraph 50.55a(g) of Title 10 of the Code of Federal Regulations (10 CFR), except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Paragraph 50.55a(a)(3) of 10 CFR states in part that alternatives to the requirements of paragraph (g) may be used when authorized by the Nuclear Regulatory Commission (NRC), if the applicant demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. However, 10 CFR 50.55a(g)(4)(iv) states that inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference

in paragraph 10 CFR 50.55a(b), subject to the limitations and modifications listed in 10 CFR 50.55a(b) and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The code of record for the third 10-year ISI interval at the Callaway Plant, Unit 1 is the 1998 Edition through 2000 Addenda of the ASME Code.

3.0 TECHNICAL EVALUATION

3.1 Affected Components ASME Code,Section III, Class 1, 2, and 3 components.

3.2 Applicable Code ASME Code,Section XI, 1998 Edition through 2000 Addenda.

3.3 Proposed Portion of Subsequent Code Edition and Addenda 2001 Edition of the ASME Code,Section XI, Subarticle IWA-4520, Subparagraphs (a) and (b).

3.4 Technical Bases The 2001 Edition of the ASME Code,Section XI is referenced in the Federal Register (69 FR 58804), dated October 1, 2004.

3.5 Duration of Proposed Request The duration of the proposed request is the third 10-year ISI interval which begins December 19, 2005, and ends December 18, 2014. The second 10-year ISI interval was extended as allowed by the ASME Code to end December 18, 2005.

4.0 EVALUATION The requirements of 10 CFR 50.55a(g)(4)(iv) allow licensees to use subsequent editions and addenda of the ASME Code Section XI, provided that the editions and addenda are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed in 10 CFR 50.55a(b), and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The requirements of 10 CFR 50.55a(b)(2) allow the use of the 2001 Edition subject to the modifications and limitations imposed by 10 CFR 50.55a(b)(2).

The differences between Subparagraph IWA-4520(a) of the1998 Edition through 2000 Addenda and the 2001 Edition of the Code are: (1) the clarification that Class 3 items are not required to be volumetrically examined when the Construction Code does not require that a full-penetration butt weld in the same location be volumetrically examined and (2) the examination requirements of IWA-4600 or IWA-4700 shall be met in lieu of the examinations required by the Construction Code or Section III.

Subparagraph IWA-4520(a) was changed in the 2001 Edition to provide clarification on using IWX-3000 exceptable flaw sizes for metal removal, welding restoration of thinned walls, and defect mitigation by modification. The modification simplifies defect removal requirements by using Section XI acceptance criteria for the disposition of flaws in the existing base material and weld material while maintaining the Construction Code or Section III criteria for new material and associated new welds.

The IWX-3000 criteria for evaluating flaws and examination requirements are not changed between the 1998 Edition through the 2000 Addenda and the 2001 Edition of Section XI.

However, Subparagraph IWA-4520(a) does reference IWA-4600 and IWA-4700 which have differences between the current code of record and the 2001 Edition, such as, IWA-4610(b) on welding qualifications and IWA-4611 on defect removal. Therefore, related requirements of the 2001 Edition include IWA-4600 and IWA-4700.

Clarifications provided in the 2001 Edition of Subparagraph IWA-4520(a) are already permitted in the code of record, and Subparagraph IWA-4520(b) is unchanged from the code of record.

5.0 CONCLUSION

Based on the above information, the NRC staff finds the licensees request to use the 2001 Edition of Section XI of the ASME Code, Subparagraphs IWA-4520(a) and IWA-4520(b) for the third 10-year ISI interval at Callaway Plant, Unit 1, acceptable provided that all related requirements are met, and subject to the limitations and modifications listed in 10 CFR 50.55a(b). Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the request to use the 2001 Edition in lieu of the 1998 Edition through 2000 Addenda of Section XI of the ASME Code, Subparagraphs IWA-4520(a) and IWA-4520(b) is approved for the third 10-year ISI interval.

Principal Contributor: D. Naujock Date: August 18, 2005

Callaway Plant, Unit 1 cc:

Professional Nuclear Consulting, Inc. Mr. Dan I. Bolef, President 19041 Raines Drive Kay Drey, Representative Derwood, MD 20855 Board of Directors Coalition for the Environment John ONeill, Esq. 6267 Delmar Boulevard Shaw, Pittman, Potts & Trowbridge University City, MO 63130 2300 N. Street, N.W.

Washington, D.C. 20037 Mr. Lee Fritz, Presiding Commissioner Callaway County Court House Mr. Mark A. Reidmeyer, Regional 10 East Fifth Street Regulatory Affairs Supervisor Fulton, MO 65151 Regulatory Affairs AmerenUE Mr. David E. Shafer P.O. Box 620 Superintendent, Licensing Fulton, MO 65251 Regulatory Affairs AmerenUE U.S. Nuclear Regulatory Commission P.O. Box 66149, MC 470 Resident Inspector Office St. Louis, MO 63166-6149 8201 NRC Road Steedman, MO 65077-1302 Mr. Keith D. Young Manager, Regulatory Affairs Mr. Les H. Kanuckel AmerenUE Manager, Quality Assurance P.O. Box 620 AmerenUE Fulton, MO 65251 P.O. Box 620 Fulton, MO 65251 Mr. Scott Clardy, Director Section for Environmental Public Health Missouri Public Service Commission P.O. Box 570 Governor Office Building Jefferson City, MO 65102-0570 200 Madison Street Jefferson City, MO 65102-0360 Certrec Corporation 4200 South Hulen, Suite 630 Regional Administrator, Region IV Fort Worth, TX 76109 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Director, Missouri State Emergency Arlington, TX 76011-4005 Management Agency P.O. Box 116 Mr. Mike Wells, Deputy Director Jefferson City, MO 65102-0116 Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839 Updated: July 2005