ML070470155
| ML070470155 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/08/2007 |
| From: | Bowman C South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G25, NOC-AE-07002116, STI: 32116681 | |
| Download: ML070470155 (6) | |
Text
Nuclear Operating Company South Tcaws Pre/ed Ekcdr/ Generatin Station PO. Boa 289 advorth, Tewas 77483 February 8, 2007 NOC-AE-07002116 File No.: G25 1 OCFR50.55a U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves (Revision 2)
References:
- 1) Letter from David W. Rencurrel, STP Nuclear Operating Company, to NRC Document Control Desk, "Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves," dated December 13, 2006 (ML063530358)
- 2) Letter from David W. Rencurrel, STP Nuclear Operating Company, to NRC Document Control Desk, "Revised Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves," dated January 22, 2007 (ML070290358)
Pursuant to 10 CFR 50.55a(f)(4)(iv), STP Nuclear Operating Company (STPNOC) requests permission to use a more recent edition of Section ISTC of the ASME Code in monitoring check valves at the South Texas Project, Units 1 and 2. ASME OM Code 2001 Edition with 2003 Addenda describes the condition monitoring approach to be applied at the South Texas Project.
The condition monitoring approach will be applied to all of the check valves presently in the scope of the inservice testing program.
The current code of record for the South Texas Project is the 1987 Edition of the Code for Operation and Maintenance of Nuclear Power Plants through the 1988 Addenda.
As an alternative to the testing and examination requirements for check valves in the current code of record, STPNOC intends to use the testing and examination requirements for check valves in Section ISTC of the 2001 Edition with 2003 Addenda of the OM Code. The purpose is to improve check valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain continued acceptable check valve performance. The attached application provides details justifying approval for use of the 2001 Edition with 2003 Addenda of the OM Code.
The attached application is revised from that provided in the referenced correspondence.
Revised sections are indicated by bars in the margin.
STI: 32116681 A04q
NOC-AE-07002116 Page 2 of 3 STPNOC requests NRC approval by March 1, 2007. Implementation will begin following NRC approval. The program will be implemented by April 21, 2008, for Unit 1 and October 27, 2008, for Unit 2.
Commitments are provided as an attachment.
If there are any questions, please contact either Philip Walker at (361) 972-8392 or me at (361) 972-7454.
Charles T. Bowman General Manager, Oversight PLW Attachments: 1) Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves (Revision 2)
- 2) List of Commitments
NOC-AE-07002116 Page 3 of 3 cc:
(paper copy)
(electronic copy)
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Mohan C. Thadani U. S. Nuclear Regulatory Commission Steve Winn Christine Jacobs Eddy Daniels Marty Ryan NRG South Texas LP J. J. Nesrsta R. K. Temple Kevin Polio City Public Service C. Kirksey City of Austin Jon C. Wood Cox Smith Matthews NOC-AE-07002116 Page 1 of 3 SOUTH TEXAS PROJECT UNITS 1 & 2 REVISED APPLICATION TO USE ASME OM CODE 2001 EDITION WITH 2003 ADDENDA FOR CONDITION MONITORING OF CHECK VALVES
- 1. ASME CODE COMPONENTS AFFECTED The condition monitoring approach will be applied to the check valves presently in the scope of the inservice testing (IST) program.
- 2. APPLICABLE CODE EDITION AND ADDENDA The current code of record for the South Texas Project is the 1987 Edition of the Code for Operation and Maintenance of Nuclear Power Plants through the 1988 Addenda. Section 4.3.2 identifies check valve testing under the current code of record.
- 3. PROPOSED SUBSEQUENT CODE EDITION AND ADDENDA Pursuant to 10 CFR 50.55a(f)(4)(iv), STP Nuclear Operating Company (STPNOC) requests permission to use Section ISTC of the 2001 Edition with 2003 Addenda of the ASME Code in monitoring check valves at the South Texas Project, Units 1 and 2.
- 4. RELATED REQUIREMENTS There are no other requirements affected by this proposed change.
The NRC approved application of check valve condition monitoring program requirements specified in the OM Code, 2001 Edition with 2003 Addenda, with no limitations or modifications (Federal Register 69 FR 58814). The Federal Register states in part:
The modification in (b)(3)(iv) does not apply to the 2003 Addenda of the ASME OM Code because the earlier Code provisions on which this regulation was based were revised in the 2003 Addenda of the ASME OM Code to address the underlying issues which led to the NRC to impose the modification. The check valve monitoring program requirements in Appendix II of the 2003 Addenda of the ASME OM Code are equivalent to the check valve monitoring requirements in 10 CFR 50.55a(b)(3)(iv).
Unlike earlier editions and addenda of the OM Code, the 2003 Addenda of the 2001 Edition contains the modifications imposed by the NRC for those earlier editions and addenda.
Included in these requirements is bi-directional testing of check valves. By adopting this edition and addenda of the OM Code, STPNOC will comply with these requirements.
- 6. IMPLEMENTATION OF UPDATED REQUIREMENTS STPNOC will begin implementing the condition monitoring program following NRC approval of this request.
STPNOC has identified 26 check valves in Unit 1 that are currently required to be uni-directionally tested in accordance with the IST Plan.
Of these, six are scheduled to be tested during outages. STPNOC will begin incorporating these six check valves into the condition monitoring program upon approval of this request. These valves will meet the ISTC requirements for bi-directional testing by completion of the Unit 1 Spring 2008 refueling outage.
STPNOC has identified 22 check valves in Unit 2 that are currently required to be uni-directionally tested in accordance with the IST Plan.
Of these, two are scheduled to be tested during outages. These valves will meet the ISTC requirements for bi-directional testing by completion of the Fall 2008 refueling outage.
NOC-AE-07002116 Page 2 of 2 The remaining 20 check valves in each unit that are uni-directionally tested are currently tested on-line, with provision for partial testing during refueling. These valves will meet the ISTC requirements for bi-directional testing by March 2008 for Unit 1 and Unit 2 except as follows:
STPNOC will make a good-faith effort to meet the requirements for bi-directional testing by March 2008 for Unit 1 and Unit 2. If STPNOC determines that bi-directional testing is only possible during an outage, STPNOC will perform such testing during the Spring 2008 and Fall 2008 refueling outages (Units 1 and 2, respectively).
Class 1, 2, and 3 check valves currently required to be bi-directionally tested in accordance with the IST plan will continue to be bi-directionally tested.
STPNOC will apply the requirements of Subsection ISTC to these valves by March 30, 2008.
If the condition monitoring program for a valve or valve group is discontinued, the testing or examination requirements of the 2001 Edition of the Code with 2003 Addenda, Section ISTC, will be applied to those affected check valves.
STP is currently in its second 10-year inservice testing interval.
As stated in NRC correspondence dated September 28, 2000 (ML003756896), the first inservice testing interval began September 25, 2000, for Unit 1 and October 19, 2000, for Unit 2. Therefore, the current inservice testing interval does not end until September 25, 2010, for Unit 1 and October 19, 2010, for Unit 2.
NOC-AE-07002116 Page 1 of 1 LIST OF COMMITMENTS The following table identifies the actions in this document to which the STP Nuclear Operating Company has committed. Statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments.
Please direct questions regarding these commitments to Philip Walker at (361) 972-8392.
Commitment Expected CR Action Completion STPNOC has identified 26 check valves in Unit 1 currently 04/21/2008 06-16412-7 required to be uni-directionally tested in accordance with the IST Plan. Of these, six are scheduled to be tested during outages. STPNOC will begin incorporating these six check valves into the condition monitoring program upon approval of this request.
These valves will meet the ISTC requirements for bi-directional testing by completion of the Unit 1 Spring 2008 refueling outage.
STPNOC has identified 22 check valves in Unit 2 that are 10/27/2008 06-16412-8 currently required to be uni-directionally tested in accordance with the IST Plan. Of these, two are scheduled to be tested during outages. These valves will meet the ISTC requirements for bi-directional testing by completion of the Unit 2 Fall 2008 refueling outage.
The remaining 20 check valves in each unit that are uni-03/30/2008 06-16412-9 directionally tested are currently tested on-line.
These valves will meet the ISTC requirements for bi-directional testing by March 2008 for Unit 1 and Unit 2 except as follows:
STPNOC will make a good-faith effort to meet the requirements for bi-directional testing by March 2008 for Unit 1 and Unit 2. If STPNOC determines that bi-directional testing is only possible during an outage, STPNOC will perform such testing during the Spring 2008 and Fall 2008 refueling outages (Units 1 and 2, respectively).
Class 1, 2, and 3 check valves currently required to be bi-On-going 06-16412-11 directionally tested in accordance with the IST plan will continue to be bi-directionally tested.
STPNOC will apply the requirements of Subsection ISTC to 03/30/2008 06-16412-6 these valves by March 30, 2008.
If the condition monitoring program for a valve or valve On-going 06-16412-12 group is discontinued, the testing or examination requirements of the 2001 Edition of the Code with 2003 Addenda, Section ISTC, will be applied to those affected check valves.