ML061100111
| ML061100111 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/01/2006 |
| From: | Terao D Plant Licensing Branch III-2 |
| To: | James M. Levine Arizona Public Service Co |
| Fields M, NRR/DLPM, 415-3062 | |
| References | |
| TAC MD1196, TAC MD1197, TAC MD1198 | |
| Download: ML061100111 (9) | |
Text
May 1, 2006 Mr. James M. Levine Executive Vice President, Generation Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -
REQUEST TO USE A SUBSEQUENT EDITION AND ADDENDA TO AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) BOILER AND PRESSURE VESSEL CODE (CODE) SECTION XI FOR REPAIR AND/OR REPLACEMENT ACTIVITIES (TAC NOS. MD1196, MD1197, AND MD1198)
Dear Mr. Levine:
By letter dated April 7, 2006, Arizona Public Service Company submitted a request to use the 2001 Edition, no Addenda to ASME Code Section XI, for repair and/or replacement activities.
The current inservice inspection (ISI) Code of record for Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3, is the 1992 Edition with the 1992 Addenda. The authorization of the subsequent edition and addenda of the ASME Code will allow qualification of the thermal metal removal process, avoiding the need to mechanically remove additional material from the processed areas that would be required under the current ISI Code of record.
Paragraph 50.55a(g)(4)(iv) of Title 10 of the Code of Federal Regulations (10 CFR) states that ISI of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda of the ASME Code provided that they 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.
Based on the enclosed Safety Evaluation, the NRC staff concludes that the proposed request is acceptable and authorizes the use of the 2001 Edition, no Addenda to ASME Code Section XI for the repair/replacement activities specified in the April 7, 2006, application for the remainder
J. M. Levine of the current 10-year ISI intervals for Palo Verde, Units 1, 2, and 3. All other requirements of the ASME Code,Section III and XI for which relief has not been specifically requested and approved remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA/
David Terao, Branch Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN-50-529, and STN 50-530
Enclosure:
Safety Evaluation cc w/encl: See next page
J. M. Levine of the current 10-year ISI intervals for Palo Verde, Units 1, 2, and 3. All other requirements of the ASME Code,Section III and XI for which relief has not been specifically requested and approved remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Sincerely,
/RA/
David Terao, Branch Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN-50-529, and STN 50-530
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION PUBLIC LPLIV r/f TBloomer, EDO RIV RidsNrrPMMFields RidsNrrDorlLplg RidsAcrsAcnwMailCenter RidsOgcRp RidsNrrLADJohnson RidsNrrDorlDpr KGruss RidsNrrDorl RidsRgn4MailCenter (TPruett)
Accession No.:
OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/CFEB/BC OGC NRR/LPL4/BC NAME MFields;sem2 DJohnson KGruss MLemoncelli (NLO)
DTerao DATE 4/21/06 5/1/06 4/27/06 5/1/06 5/1/06 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE A SUBSEQUENT EDITION AND ADDENDA TO AMERICAN SOCIETY FOR MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI, FOR REPAIR/REPLACEMENT ACTIVITIES ARIZONA PUBLIC SERVICE COMPANY, ET AL.
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530
1.0 INTRODUCTION
By letter dated April 7, 2006, Arizona Public Service Company (the licensee) submitted a request to use the 2001 Edition, no Addenda to American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code)Section XI for repair/replacement activities.
The current inservice inspection (ISI) Code of record is the 1992 Edition with the 1992 Addenda for the Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3. The authorization of the subsequent edition and addenda of the ASME Code will allow qualification of the thermal metal removal process, avoiding the need to mechanically remove additional material from the processed areas that would be required under the current ISI Code of record.
The licensee submitted this request in accordance with the guidance provided in NRC Regulatory Issue Summary (RIS) 2004-16, dated October 19, 2004. In this RIS, the NRC staff stated that licensees who wish to use provisions of subsequent editions and addenda of the ASME Code Section XI for activities, including repair/replacement activities, must receive prior NRC approval as required by section 50.55a(g)(4)(iv) of Title 10 of the Code of Federal Regulations (10 CFR).
2.0 REGULATORY REQUIREMENTS Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service 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. Section 50.55a(g)(4)(ii) of 10 CFR requires that ISI examination of components and system pressure tests conducted during successive 120-month inspection intervals must 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) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
The repair, replacement, and modification of plant components are not explicitly mentioned in 10 CFR 50.55a(g)(4) and associated subparagraphs. However, these activities are specifically mentioned in ASME Code Section XI. The NRC staff maintains that these activities are not separate and distinct from, but are included under, inservice examinations. Therefore, the requirements of 10 CFR 50.55a(g)(4)(iv) are applicable to repair/replacement activities.
Section 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 of the ASME Code provided that they 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. Currently, Section 50.55a(b)(2) incorporates by reference the ASME Code Section XI from the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition (Division 1) through the 2003 Addenda (Division 1).
3.0 REQUEST TO USE A SUBSEQUENT EDITION AND ADDENDA TO ASME CODE SECTION XI FOR REPAIR/REPLACEMENT ACTIVITIES 3.1 Current Code Requirements The current ASME Section XI Code of record for Palo Verde, Units 1, 2, and 3, is the 1992 Edition with 1992 Addenda. The applicable code requirements in the 1992 Edition with 1992 Addenda are as follows:
IWA-4322, Process Requirements for P-No. 8 and P-No. 43 Materials If thermal removal processes are used on P-No. 8 and P-No. 43 materials, a minimum of 1/16 in. shall be mechanically removed from the thermally processed area.
3.2 Proposed Alternative Code Edition and Requirements The licensee proposes to use the 2001 Edition, no Addenda of the ASME Code Section XI for repair/replacement activities. The applicable requirements from that Code are as follows, subject to the limitations and modifications identified in 10 CFR 50.55a, Codes and Standards.
IWA-4461.3, P-Nos. 8 and 43 Materials If thermal removal processes are used on P-No. 8 and P-No. 43 materials, at least 1/16 in. (1.6 mm) of material shall be mechanically removed from the thermally processed area.
IWA-4461.4, Alternatives to Mechanical Processing Mechanical processing of thermally cut surfaces for materials identified in IWA-4461.3 is not required when the alternative of IWA-4461.4.1 is used.
IWA-4461.4.1, Qualification of Thermal Metal Removal Process Mechanical processing of thermally cut surfaces is not required when the thermal metal removal process is qualified as follows:
(a)
The qualification test shall consist of two coupons of the same P-No. material cut in production.
(b)
The qualification coupons shall be cut using the maximum heat input to be used in production.
(c)
The thermally cut surface of each coupon shall be visually examined at 10X and shall be free of cracks. The owner shall specify surface roughness acceptable for the application and shall verify that the qualification coupon meets the criterion.
(d)
Each qualification coupon shall be cross sectioned, and exposed surfaces shall be polished, etched with a suitable etchant, and visually examined at 10X. All sectioned surfaces shall be free of cracks.
(e)
Corrosion testing of the thermally cut surface and heat affected zone shall be performed if the cut surface is to be exposed to corrosive media. Alternatively, corrosion resistance of the thermally cut surface may be evaluated. The owner shall specify the acceptance criteria.
4.0 TECHNICAL EVALUATION
The NRC staff evaluated the licensee's request using the criteria contained in 10 CFR 50.55a(g)(4)(iv), which states that inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda of the ASME Code provided certain criteria are satisfied.
The first criterion is that the proposed edition and addenda is incorporated by reference in 10 CFR 50.55a(b). Currently, Section 50.55a(b)(2) incorporates by reference the ASME Code Section XI from the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition (Division 1) through the 2003 Addenda (Division 1), which includes the 2001 Edition, no Addenda of the ASME Section XI Code proposed by the licensee.
The second criterion is that the limitations and modifications listed in 10 CFR 50.55a(b) are satisfied for the specific use of the proposed subsequent Code edition and addenda. There is one restriction specified in 10 CFR 50.55a(b) for the portion of the 2001 Edition, no Addenda of the ASME Section XI Code that the licensee proposes to use. The restriction is contained in 10 CFR 50.55a(b)(2)(xxiii), Evaluation of Thermally Cut Surfaces, which states:
The use of the provisions for eliminating mechanical processing of thermally cut surfaces in IWA-4461.4.2 of Section XI, 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section are prohibited.
The licensee has stated in its April 7, 2006, application that this restriction will be complied with.
Therefore, the NRC staff finds that the second criterion has been satisfied.
The third criterion is that if portions of subsequent Code editions or addenda are used, all related requirements of the respective editions or addenda must be met. The NRC staff is satisfied that the licensee has listed all related requirements in the 2001 Edition, no Addenda of the ASME Section XI Code that are relevant to the stated repair/replacement activities.
Based on the above, the NRC staff finds that the criteria of 10 CFR 50.55a(g)(4)(iv) are satisfied and that the licensee<s request to use the 2001 Edition, no Addenda of the ASME Code Section XI for repair/replacement activities is acceptable.
5.0 CONCLUSION
The NRC staff concludes that the proposed request is acceptable and authorizes the use of the ASME Code Section XI, 2001 Edition, no Addenda, for the specified repair/replacement activities for the remainder of the current 10-year ISI intervals for Palo Verde, Units 1, 2, and 3.
All other requirements of the ASME Code,Section III and XI for which relief has not been specifically requested and approved remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: M. Fields Date: May 1, 2006
Palo Verde Generating Station, Units 1, 2, and 3 cc:
March 2006 Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Mr. Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Mr. Craig K. Seaman, General Manager Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. Hector R. Puente Vice President, Power Generation El Paso Electric Company 310 E. Palm Lane, Suite 310 Phoenix, AZ 85004 Mr. John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Mr. Thomas D. Champ Southern California Edison Company 5000 Pacific Coast Hwy Bldg D1B San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Mr. Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901 Mr. John Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Mr. Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326
Palo Verde Generating Station, Units 1, 2, and 3 cc:
March 2006 Ms. Karen O'Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix AZ 85003 Mr. Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004