ML061080655

Response to Request to Use Subsequent Edition and Addenda of ASME Code for Inservice Testing

ML061080655
Person / Time
Site:	Point Beach
Issue date:	05/04/2006
From:	Raghavan L Plant Licensing Branch III-2
To:	Koehl D Nuclear Management Co
lyon C, NRR/ADRO/DORL, 415-2296
References
TAC MC9783, TAC MC9784
Download: ML061080655 (7)

Text

May 4, 2006 Mr. Dennis L. Koehl Site Vice President Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241-9516

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - RESPONSE TO REQUEST TO USE SUBSEQUENT EDITION AND ADDENDA OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) CODE FOR INSERVICE TESTING (TAC NOS. MC9783 AND MC9784)

Dear Mr. Koehl:

By letter dated January 20, 2006, Nuclear Management Company, LLC (NMC, the licensee) submitted a request for approval to use portions of a later edition and addenda of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (IST) program at Point Beach Nuclear Plant, Units 1 and 2 (PBNP). Specifically, approval was requested to apply the portions of the requirements of Subarticle ISTC-3540, Manual Valves, of the 1999 Addenda of the ASME OM Code related to IST of manually operated valves. NMC requested approval through the end of the current (4th) IST interval, which ends on August 31, 2012, for Unit 1, and September 30, 2012, for Unit 2.

Consistent with the requirements set forth in 10 CFR 50.55a(f)(4)(iv), the Nuclear Regulatory Commission (NRC) staff has reviewed your request and has determined that all regulatory provisions were adequately addressed for PBNP. Therefore, pursuant to 10 CFR 50.55a(f)(4)(iv), the NRC staff approves the use of Subarticle ISTC-3540 of the 1999 Addenda of the ASME OM Code for exercising manual valves at Point Beach, subject to the limitations and modifications listed in 10 CFR 50.55a(b)(3)(vi), through the duration of the PBNP 4th IST intervals, which are scheduled to end on August 31, 2012, for Unit 1 and September 30, 2012, for Unit 2.

D. Koehl The detailed results of the NRC staffs review are provided in the enclosed safety evaluation. If you have any questions concerning this matter, please call Mr. Carl F. Lyon of my staff at (301) 415-2296.

Sincerely,

/RA/

L. Raghavan, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

As stated cc w/encl: See next page

D. Koehl The detailed results of the NRC staffs review are provided in the enclosed safety evaluation. If you have any questions concerning this matter, please call Mr. Carl F. Lyon of my staff at (301) 415-2296.

Sincerely,

/RA/

L. Raghavan, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-1 R/F RidsNrrPMFLyon RidsNrrLADClarke RidsNrrDorlLpl3-1 RidsOgcRp RidsAcrsAcnwMailCenter SLee RidsNrrDorlDpr PLouden, RIII OYee ADAMS Accession Number: ML061080655 *SE dated 4/12/06 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/CPTB/BC OGC NRR/LPL3-1/BC NAME FLyon:rsa DClarke SLee* PMoulding LRaghavan DATE 4/25/06 4/25/06 4/12/06 5/3/06 5/4/06 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE FOURTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM REQUEST FOR RELIEF NUCLEAR MANAGEMENT COMPANY, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301

1.0 INTRODUCTION

By letter dated January 20, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML060380566), Nuclear Management Company, LLC (NMC, the licensee) submitted a request for approval to use portions of a later edition and addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (IST) program at Point Beach Nuclear Plant, Units 1 and 2 (PBNP). Specifically, approval was requested to apply the portions of the requirements of Subarticle ISTC-3540, Manual Valves, of the 1999 Addenda of the ASME OM Code related to IST of manually operated valves. NMC requested approval through the end of the current (4th) IST interval, which ends on August 31, 2012, for Unit 1, and September 30, 2012, for Unit 2.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year)

IST program intervals in accordance with the specified ASME Code incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month IST program interval. In accordance with 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to Nuclear Regulatory Commission (NRC) approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.

ENCLOSURE

The NRCs findings with respect to granting or denying the IST program request from NMC are given below:

3.0 TECHNICAL EVALUATION

3.1 Code Requirements The applicable Code of record for PBNP is the ASME OM Code, 1995 Edition with 1996 Addenda. This Code requires that active function manual valves be exercised on a quarterly basis.

3.2 Licensees Basis for Requesting Relief The requirement in 10 CFR 50.55a(f)(4)(iv) states that IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed in Paragraph (b) of 10 CFR50.55a, and subject to NRC approval. Portions of editions and addenda may be used, provided that all related requirements of the respective editions or addenda are met.

3.3 Licensees Proposed Alternative Testing Portions of the 1999 Addenda of the ASME OM Code relate to the IST of manually operated valves. Federal Register Volume 67, Number 187, dated September 26, 2002 (67 FR 60520),

incorporates by reference the 1997 Addenda, 1998 Edition, 1999 Addenda, and 2000 Addenda of the ASME OM Code for the IST programs in 10 CFR 50.55a(b).

Specifically, the requirements of ISTC-3540, Manual Valves, 1999 Addenda state:

ISTC-3540 Manual Valves. Manual valves shall be full-stroke exercised at least once every 5 years, except where adverse conditions may require the valve to be tested more frequently to ensure operational readiness. Any increased testing frequency shall be specified by the owner. The valve shall exhibit the required change of obturator position.

The licensee proposes to apply ISTC-3540 to all active function manual valves in the IST program at PBNP. In accordance with the limitation imposed by 10 CFR 50.55a(b)(3)(vi),

manual valves must be exercised on a 2-year interval rather than 5-year interval specified in paragraph ISTC-3540 of the 1999 Addenda through the latest edition and addenda, provided that adverse conditions do not require more frequent testing. The licensee states that adverse conditions have not been observed for manual valves within the scope of the IST program.

Therefore, a test exercise interval of less than 2 years would not be required.

3.4 NRC Staff Evaluation The licensee has requested approval to exercise manual valves in accordance with Subarticle ISTC-3540 of the 1999 Addenda of the ASME OM Code. The licensee also further acknowledged the requirement to test the manual valves consistent with the limitation imposed by 10 CFR 50.55a(b)(3)(vi), on a 2-year interval rather than the 5-year interval specified in the

2001 Edition and 2003 Addenda of the ASME OM Code, provided that adverse conditions (as defined in subsection ISTC) do not require more frequent testing. The NRC staff has identified no additional related requirements in the specified ASME Code Edition and Addenda that need to be met in order to implement the requested Subarticle ISTC-3540.

4.0 CONCLUSION

Consistent with the requirements set forth in 10 CFR 50.55a(f)(4)(iv), the NRC staff has reviewed the request and has determined that all regulatory provisions were adequately addressed for PBNP. Therefore, pursuant to 10 CFR 50.55a(f)(4)(iv), the NRC staff approves the use of Subarticle ISTC-3540 of the 1999 Addenda of the ASME OM Code for exercising manual valves at PBNP, subject to the limitations and modifications listed in 10 CFR 50.55a(b)(3)(vi), through the duration of the PBNP 4th IST intervals, which are scheduled to end on August 31, 2012, for Unit 1, and September 30, 2012, for Unit 2.

Principal Contributor: O. Yee Date: May 4, 2006

Point Beach Nuclear Plant, Units 1 and 2 cc:

Jonathan Rogoff, Esquire Mr. Jeffery Kitsembel Vice President, Counsel & Secretary Electric Division Nuclear Management Company, LLC Public Service Commission of Wisconsin 700 First Street P.O. Box 7854 Hudson, WI 54016 Madison, WI 53707-7854 Mr. F. D. Kuester Nuclear Asset Manager President & Chief Executive Officer Wisconsin Electric Power Company WE Generation 231 West Michigan Street 231 West Michigan Street Milwaukee, WI 53201 Milwaukee, WI 53201 Michael B. Sellman Regulatory Affairs Manager President and Chief Executive Officer Point Beach Nuclear Plant Nuclear Management Company, LLC Nuclear Management Company, LLC 700 First Street 6610 Nuclear Road Hudson, MI 54016 Two Rivers, WI 54241 Douglas E. Cooper Mr. Ken Duveneck Senior Vice President - Group Operations Town Chairman Palisades Nuclear Plant Town of Two Creeks Nuclear Management Company, LLC 13017 State Highway 42 27780 Blue Star Memorial Highway Mishicot, WI 54228 Covert, MI 49043 Chairman Site Director of Operations Public Service Commission Nuclear Management Company, LLC of Wisconsin 6610 Nuclear Road P.O. Box 7854 Two Rivers, WI 54241 Madison, WI 53707-7854 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, WI 54241 November 2005