ML072950144
| ML072950144 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/27/2007 |
| From: | Russell Gibbs NRC/NRR/ADRO/DORL/LPLIII-2 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| Wiebe, J | |
| References | |
| TAC MD5556 | |
| Download: ML072950144 (10) | |
Text
November 27, 2007 Mr. Mark B. Bezilla Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST TO USE LATER EDITION AND ADDENDA TO AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE SECTION XI FOR REPAIR AND/OR REPLACEMENT ACTIVITIES (TAC NO. MD5556)
Dear Mr. Bezilla:
By letter dated May 15, 2007, FirstEnergy Nuclear Operating Company, requested to use a later edition and addenda to American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI requirements for the Davis-Besse Nuclear Power Station, Unit No. 1. The licensee requested to use Subarticle IWA-4461.4 of Section XI of the 2000 Addenda of the 1998 Edition of the ASME Code. Subarticle IWA-4461.4 provides requirements for qualification of thermal removal processes as an alternative to mechanical processing of thermally cut surfaces. The licensee submitted the request to use a later Code Edition and Addenda in accordance with Title 10 Code of the Federal Regulations (10 CFR), Part 50, Section 50.55a(g)(4)(iv). The Nuclear Regulatory Commission (NRC) staff found the request to be acceptable and approves the use of Subarticle IWA-4461.4 of Section XI of the 2000 Addenda of the1998 Edition of the ASME Code.
The NRC staffs evaluation and conclusions are contained in the enclosed Safety Evaluation.
Sincerely,
/RA/
Russell Gibbs, Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346
Enclosure:
Safety Evaluation cc w/encls: See next page
Mr. Mark B. Bezilla November 27, 2007 Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST TO USE LATER EDITION AND ADDENDA TO AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE SECTION XI FOR REPAIR AND/OR REPLACEMENT ACTIVITIES (TAC NO. MD5556)
Dear Mr. Bezilla:
By letter dated May 15, 2007, FirstEnergy Nuclear Operating Company, requested to use a later edition and addenda to American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI requirements for the Davis-Besse Nuclear Power Station, Unit No.
- 1. The licensee requested to use Subarticle IWA-4461.4 of Section XI of the 2000 Addenda of the 1998 Edition of the ASME Code. Subarticle IWA-4461.4 provides requirements for qualification of thermal removal processes as an alternative to mechanical processing of thermally cut surfaces.
The licensee submitted the request to use a later Code Edition and Addenda in accordance with Title 10 Code of the Federal Regulations (10 CFR), Part 50, Section 50.55a(g)(4)(iv). The Nuclear Regulatory Commission (NRC) staff found the request to be acceptable and approves the use of Subarticle IWA-4461.4 of Section XI of the 2000 Addenda of the1998 Edition of the ASME Code.
The NRC staffs evaluation and conclusions are contained in the enclosed Safety Evaluation.
Sincerely,
/RA/
Russell Gibbs, Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346
Enclosure:
Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC LPL3-2 R/F RidsNrrPMTWengert RidsNrrDciCvib RidsNrrDirsItsb RidsOgcRp RidsNrrPMJWiebe RidsRgn3MailCenter RidsAcrsAcnwMailCenter GHill (2) RidsNrrLAEWhitt EAndruszkiewicz, NRR RidsNrrDorlLpl3-2 RidsNrrDorlDpr Accession Number: ML072950144 *Concurrence via ML072480415 OFFICE LPL3-2/PM LPL3-2/PM LPL3-2/LA DCI/CVIB/BC OGC LPL3-2/BC NAME JWiebe TWengert EWhitt MMitchell* MLoftus RGibbs DATE 11/9/07 11/9/07 11/9/07 9/5/07 11/19/07 11/27/07 OFFICIAL RECORD COPY
Davis-Besse Nuclear Power Station, Unit No. 1 cc:
Manager, Site Regulatory Compliance President, Board of County FirstEnergy Nuclear Operating Company Commissioners of Ottawa County Davis-Besse Nuclear Power Station Port Clinton, OH 43252 Mail Stop A-DB-3065 5501 North State Route 2 President, Board of County Oak Harbor, OH 43449-9760 Commissioners of Lucas County One Government Center, Suite 800 Director, Ohio Department of Commerce Toledo, OH 43604-6506 Division of Industrial Compliance Bureau of Operations & Maintenance The Honorable Dennis J. Kucinich 6606 Tussing Road United States House of Representatives P.O. Box 4009 Washington, D.C. 20515 Reynoldsburg, OH 43068-9009 Resident Inspector The Honorable Dennis J. Kucinich U.S. Nuclear Regulatory Commission United States House of Representatives 5503 North State Route 2 14400 Detroit Avenue Oak Harbor, OH 43449-9760 Lakewood, OH 44107 Stephen Helmer Joseph J. Hagan Supervisor, Technical Support Section President and Chief Nuclear Officer Bureau of Radiation Protection FirstEnergy Nuclear Operating Company Ohio Department of Health Mail Stop A-GO-14 35 East Chestnut Street, 7th Floor 76 South Main Street Columbus, OH 43215 Akron, OH 44308 Carol OClaire, Chief, Radiological Branch David W. Jenkins, Attorney Ohio Emergency Management Agency FirstEnergy Corporation 2855 West Dublin Granville Road Mail Stop A-GO-15 Columbus, OH 43235-2206 76 South Main Street Akron, OH 44308 Zack A. Clayton DERR Danny L. Pace Ohio Environmental Protection Agency Senior Vice President, Fleet Engineering P.O. Box 1049 FirstEnergy Nuclear Operating Company Columbus, OH 43266-0149 Mail Stop A-GO-14 76 South Main Street State of Ohio Akron, OH 44308 Public Utilities Commission 180 East Broad Street Manager, Fleet Licensing Columbus, OH 43266-0573 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Attorney General 76 South Main Street Office of Attorney General Akron, OH 44308 30 East Broad Street Columbus, OH 43216
Davis-Besse Nuclear Power Station, Unit No. 1 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF LATER ASME CODE SECTION XI FOR THERMAL REMOVAL PROCESSES FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated May 15, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071370714), FirstEnergy Nuclear Operating Company (the licensee) requested to use Subarticle IWA-4461.4 of Section XI of the 2000 Addenda of the1998 Edition of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) at Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). Subarticle IWA-4461.4 provides requirements for qualification of thermal removal processes as an alternative to mechanical processing of thermally cut surfaces.
The licensee submitted the request to use a later Code Edition and Addenda in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(g)(4)(iv).
Section 50.55a(g)(4)(iv) of 10 CFR has been clarified by NRC Regulatory Issue Summary (RIS) 2004-16, Use of later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities, dated October 19, 2004. RIS 2004-16 states 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 10 CFR 50.55a(g)(4)(iv).
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 inservice inspection (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.
Enclosure
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 the 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) of 10 CFR 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, 10 CFR 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 through the 2003 Addenda.
3.0 LICENSEES REQUEST TO USE LATER EDITION AND ADDENDA TO ASME CODE, SECTION XI 3.1 ASME Code Component Affected ASME Code Class 1, 1-1/2" Pressurizer Thermo Well Nozzle (MK 29) 3.2 Applicable Code Edition and Addenda Repair/replacement activities at DBNPS are currently performed in accordance with the 1995 Edition through 1996 Addenda of ASME Code,Section XI.
The third 120-month ISI interval commenced on September 21, 2000, and will end on September 20, 2012. A 2-year extension was added to the interval due to the 2 year shutdown following the units 13th operating cycle.
3.3 Proposed Subsequent Code Edition and Addenda (or Portion) 3.3.1 Background The licensee currently performs repair/replacement activities in accordance with the 1995 Edition through 1996 Addenda of ASME Code,Section XI. However, Subarticle IWA-4000 in the 1995 Edition through 1996 Addenda does not contain rules for qualifying thermal removal processes, such as electrodischarge machining, that can be used without mechanical processing of thermally cut surfaces.
The 2000 Addenda of the 1998 Edition of the ASME Code,Section XI contains the rules applicable to thermal removal processes for all repair/replacement activities. The 2000 Addenda also contains rules that exempt mechanical processing of thermally cut surfaces provided the thermal removal process was qualified in accordance with Subarticle IWA-4461.4 of the ASME Code,Section XI.
3.3.2 Proposed Subsequent Code Edition and Addenda Pursuant to 10 CFR 50.55a(g)(4)(iv), the licensee requested permission to use Subarticle IWA-4461.4 in the 2000 Addenda of the1998 Edition of ASME Code,Section XI. Subarticle
IWA-4461.4 provides rules for qualifying thermal removal processes as an alternative to mechanical processing of thermally cut surfaces. The NRC approved the use of the 2000 Addenda of the1998 Edition as documented in 10 CFR 50.55a(b)(2) with no limitations, conditions, or modifications on Subarticle IWA-4461.4.
3.3.3 Related Requirements Subarticle IWA-4461.4 of the 2000 Addenda of the1998 Edition specifies rules for qualification of a thermal removal process as an alternative to mechanical processing of thermally cut surfaces. When applying Subarticle IWA-4461.4, the following related requirement also applies.
Subarticle IWA-4461.4 states that Mechanical processing of thermally cut surfaces for materials identified in IWA-4461.2 and IWA-4461.3 is not required when using a thermal removal process qualified as follows Because Subarticle IWA-4461.4 is an alternative to mechanical processing of thermally cut surfaces for the materials identified in Subarticles IWA-4461.2 and IWA-4461.3, it is only applicable to P-Number 3, 4, 5, 6, 7, 8, 9, 10, 11A, and 43 materials; it cannot be applied to P-Number 1 materials of Subarticle IWA-4461.1. Therefore, when invoking Subarticle IWA-4461.4 in the 2000 Addenda of the1998 Edition, the licensee will also apply this related requirement.
The NRC prohibition on evaluation of thermally cut surfaces in paragraph 10 CFR 50.55a(b)(2)(xxiii) does not apply to the qualification alternative of IWA-4461.4.
Rather, this NRC prohibition applies to Subarticle IWA-4461.4.2, Evaluation of Thermally Cut Surfaces, which was not included in the ASME Code,Section XI until the 2001 Edition.
3.4 Duration of Proposed Request This request will remain in effect for the duration of repairs to the 1-1/2" Pressurizer Thermo Well Nozzle (MK 29) planned for the next maintenance and refueling outage (15RFO), which is currently scheduled to commence in December 2007.
4.0 TECHNICAL EVALUATION
The NRC staff evaluated the licensee's request to use a later ASME Code edition and addenda 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 edition and addenda of the ASME Code,Section XI that will be used in the proposed request is incorporated by reference in 10 CFR 50.55a(b). Currently, 10 CFR 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 2000 Addenda of the 1998 Edition of the ASME Code,Section XI which was proposed by the licensee. Therefore, the NRC staff finds that the first criterion has been satisfied.
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 edition and addenda of the ASME
Code,Section XI. 10 CFR 50.55a(b) sets no limitations and modifications on Subarticle IWA-4461.4 of the 2000 Addenda of the 1998 Edition of the ASME Code,Section XI.
Therefore, the NRC staff finds that the second criterion has been satisfied.
The third criterion is that if portions of subsequent editions or addenda of the ASME Code,Section XI 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 Subarticle IWA-4461.4 of the 2000 Addenda of the1998 Edition of the ASME Code,Section XI that are relevant to the stated repair/replacement activities. Therefore, the NRC staff finds that the third criterion has been satisfied.
Based on the above, the NRC staff finds that the criteria of 10 CFR 50.55a(g)(4)(iv) are satisfied and that the licensees request to use the 2000 Addenda of the1998 Edition of the ASME Code,Section XI for the specified repair/replacement activities is acceptable.
5.0 CONCLUSION
On the basis of evaluating the information submitted, the NRC staff concludes that the proposed request to use a later ASME Code edition and addenda is acceptable and approves the use of Subarticle IWA-4461.4 of the 2000 Addenda of the1998 Edition of the ASME Code,Section XI for repairs to the 1-1/2" Pressurizer Thermo Well Nozzle (MK 29) performed during the next maintenance and refueling outage (15RFO), which is currently scheduled to commence in December 2007 at DBNPS.
All other requirements of the ASME Code, Sections 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: E. Andruszkiewicz, NRR Date: November 27, 2007