ML101110324
| ML101110324 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Byron, Braidwood, Limerick, LaSalle  |
| Issue date: | 07/23/2010 |
| From: | Robert Carlson Plant Licensing Branch III |
| To: | Pardee C Exelon Generation Co |
| DiFrancesco N, NRR/DORL/LPL3-2, 415-1115 | |
| References | |
| TAC ME1862, TAC ME1863, TAC ME1864, TAC ME1865, TAC ME1866, TAC ME1867, TAC ME1868, TAC ME1869, TAC ME1870, TAC ME1871 | |
| Download: ML101110324 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 July 23, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2, BYRON STATION, UNIT NOS. 1 AND 2, LASALLE COUNTY STATION, UNITS 1 AND 2, LIMERICK GENERATING STATION, UNITS 1 AND 2, PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - REQUEST TO USE SPECIFIC PROVISIONS FROM A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI (TAC NOS. ME1862, ME1863, ME1864, ME1865, ME1866, ME1867, ME1868, ME1869, ME1870 AND ME1871)
Dear Mr. Pacilio:
By letter dated August 7, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092220301), as supplemented by letter dated January 21, 2010 (ADAMS Accession No. ML100220163), Exelon Generation Company, LLC, (the licensee),
requested U.S. Nuclear Regulatory Commission (NRC) staff approval to use portions of a more recent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for ASME Code Class 1,2,3, and metal containment (MC) components at Braidwood, Units 1 and 2, Byron Station, Unit Nos. 1 and 2, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, and Peach Bottom Atomic Power Station, Units 2 and 3, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)( 4 )(iv).
The licensee requested approval to apply the requirements of the 2004 Edition and no Addenda of the ASME Code,Section XI, for magnetic particle examination and liquid penetrant examination, for the remainder of their 1 O-year inservice inspection (lSI) interval at the subject facilities. Specifically, the licensee requested to utilize IWA-2221 (a), IWA-2221(b), IWA-2221(c),
IWA-2222(a), and IWA-2222(b) from the 2004 Edition and no Addenda of the ASME Code,Section XI.
The regulations in 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 (b) of 10 CFR 50.55a, subject to the limitations and modifications listed in paragraph (b) of 10 CFR 50.55a, and subject to Commission approval.
The current Code of Record for the subject facilities is the 2001 Edition through 2003 Addenda of the ASME Code, Secti08 XI. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The 2004 Edition and no Addenda of the ASME Code,Section XI, has been incorporated by reference into 10 CFR 50.55a(b), subject to certain limitations and modifications.
The NRC staff has reviewed the licensee's request and found it acceptable. Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the NRC staff approves the use of the subparagraphs IWA-2221(a),
M. Pacilio
- 2 IWA-2221 (b), IWA-2221(c), IWA-2222(a), and IWA-2222(b) of the 2004 Edition and no Addenda of the ASME Code,Section XI, for the surface examination of ASME Code Class 1, 2, 3, and MC components for the remainder of the third 1 O-year lSI interval at Braidwood Station, Units 1 and 2, Byron Station, Unit Nos. 1 and 2, LaSalle County Station, Units 1 and 2, and Limerick Generating Station, Units 1 and 2, and for the remainder of the fourth 10-year lSI interval at Peach Bottom Atomic Power Station, Units 2 and 3.
A copy of the Safety Evaluation is enclosed. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Project Manager Nicholas J. DiFrancesco at 301-415-1115.
Sincerely, Robert D. Carlson, Branch Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-456, 50-457, 50-454, 50-455, 50-373, 50-374, 50-352, 50-353, 50-277, and 50-278
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST REGARDING USE OF LATER ASME CODE EDITION FOR ASME CODE CLASS 1, 2, 3, AND MC COMPONENTS BRAIDWOOD STATION, UNITS 1 AND 2, BYRON STATION, UNIT NOS. 1 AND 2, LASALLE COUNTY STATION, UNITS 1 AND 2, LIMERICK GENERATING STATION, UNITS 1 AND 2.
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 EXELON GENERATION COMPANY, LLC DOCKET NOS. 50-456, 50-457. 50-454, 50-455, 50-373. 50-374, 50-352.50-353,50-277, AND 50-278
1.0 INTRODUCTION
By letter dated August 7, 2009, as supplemented by letter dated January 21, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML092220301 and ML100220163, respectively), Exelon Generation Company, LLC, (EGC, the licensee), requested U.S. Nuclear Regulatory Commission (NRC) approval to use specific provisions of a later edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for ASME Code Class 1,2,3, and metal containment (MC) components at Braidwood, Units 1 and 2, Byron Station, Unit Nos. 1 and 2, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, and Peach Bottom Atomic Power Station, Units 2 and 3.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv),
the licensee requested to utilize IWA-2221(a), IWA-2221(b), IWA-2221(c), IWA-2222(a), and IWA-2222(b) from the 2004 Edition and no Addenda of the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components." The licensee's request pertains to ASIVIE Code Class 1, 2, 3, and MC components subjected tl) the surface examinations using magnetic particle and liquid penetrant.
2.0 REGULATORY REQUIREMENTS Title 10 of the Code of Federal Regulations Section 50.55a(g) specifies that inservice inspection (lSI) of nuclear power plant components shall be performed in accordance with the requirements of the ASME Code,Section XI, except where specific written relief has been granted by the Commission. The regulation at 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 (b) of 10 CFR 50.55a, subject to the limitations and modifications listed in paragraph (b) of 10 CFR 50.55a, and subject
-2 to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
Pursuant to 10 CFR SO.SSa(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, to the extent practical within the limitations of design, geometry, and materials of construction of components.
Components which are classified as Class MC pressure retaining components and their integral attachments must meet the requirements, except design and access provisions and pre-service examination requirements, set forth in Section XI of the ASME Code and Addenda that are incorporated by reference in paragraph (b) of 10 CFR SO.SSa, subject to the limitation listed in paragraph (b)(2)(vi) of 10 CFR SO.SSa and the modifications listed in paragraphs (b)(2)(viii) and (b)(2)(ix) of 10 CFR SO.SSa, to the extent practical within the limitation 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 1 O-year interval and subsequent intervals comply with the requirements of the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR SO.SSa(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The current code of record for the third 10-year lSI interval at Braidwood Station, Units 1 and 2, Byron Station, Unit Nos. 1 and 2, LaSalle County Station, Units 1 and 2, and Limerick Generating Station, Units 1 and 2, and for the fourth 10-year lSI interval at Peach Bottom Atomic Power Station, Units 2 and 3, is the 2001 Edition through 2003 Addenda of the ASME Code,Section XI.
Regulatory Issue Summary 2004-16, "Use of Later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities," dated October 19, 2004, maintains that, although the repair, replacement, and modification of plant components activities in the ASME Code Section XI are not explicitly mentioned in 10 CFR SO.SSa(g)(4) and associated subparagraphs, these activities are not separate and distinct and are included under inservice examination requirements of 10 CFR SO.SSa(g)(4)(iv). Licensees who wish to use provisions of subsequent editions and addenda of the ASME Code,Section XI, for activities, including repair and replacement activities (e.g., Code Case N-389-1), must receive prior NRC review and approval as required by 10 CFR 50.55a(g)(4)(iv).
3.0 TECHNICAL EVALUATION
3.1
Applicable Code Edition and Addenda
The licensee's request includes the nuclear power plant listed below. The code of record for the current 10-year lSI interval for the nuclear power plants below is the 2001 Edition through 2003 Addenda of the ASME Code,Section XI.
-3 ilearpower
3.2 ASME Code Components Affected
ASME Code Class 1,2,3, and MC components that are subjected to the surface examinations using magnetic particle and liquid penetrant are affected.
3.3 Proposed Alternative The licensee proposed to utilize IWA-2221(a), IWA-2221 (b), and IWA-2221(c) for the magnetic particle examination, and IWA-2222(a) and IWA-2222(b) for the liquid penetrant examination from the 2004 Edition and no Addenda of the ASME Code,Section XI, for ASME Code Class 1, 2, 3, and MC components subjected to the surface examinations.
The licensee stated that IWA-2221(c) and IWA-2222(b) were not included in the 2001 Edition through 2003 Addenda of the ASME Code,Section XI. IWA-2221 (c) and IW A-2222(b) in the 2004 Edition and no Addenda of the ASME Code,Section XI, will allow use of a visual acuity card to verify illumination adequacy in lieu of a digital light meter which was required by the 2001 Edition through 2003 Addenda of the ASME Code,Section XI. The licensee also stated that the use of a visual acuity card is an equivalent method to verify adequate lighting, does not require a calibrated digital light meter, and results in less radiation exposure to the personnel in order to maintain radiation exposure within As Low As Reasonably Achievable limits.
Further, the licensee stated that all the following related requirements associated with the 2004 Edition and no Addenda of the ASME Code,Section XI, IWA-2221 (a), IWA-2221(b), and IWA 2222 will be utilized.
IWA-2221 (a) in the 2001 Edition through 2003 Addenda of the ASME Code,Section XI, and the 2004 Edition and no Addenda of the ASME Code,Section XI, states: "Magnetic particle examination shall be conducted in accordance with Section V, Article 7." The requirements of Section V, Article 7 from the 2004 Edition and no Addenda of the ASME Code,Section XI, will be utilized.
IWA-2221 (b) in the 2001 Edition through 2003 Addenda of the ASME Code,Section XI, and the 2004 Edition and no Addenda of the ASME Code,Section XI, states: "Magnetic particle examination of coated materials shall be conducted in accordance with Plant Unit No.
10-Year 151 Interval 10-Year 151 Interval Start Date - End Date idwood 1
Third July 29,2008 July 28,2018 tion 2
Third October 17, 2008 - October 16, 2018 Byron 1
Third July 16, 2006 - July 15, 2016 Station 2
Third July 16, 2006 - July 15,2016 I
LaSalle 1
Third October 1, 2007 - September 30, 2017 County Station 2
Third October 1, 2007 - September 30, 2017 Limerick 1
Third February 1, 2007 - January 31,2017 Generating Station 2
Third February 1,2007 January 31,2017
- Peach Bottom 2
Fourth November 5, 2008 - November 4, 2018 Atomic Power Station 3
Fourth November 5,2008 November 4,2018
-4 Section V, Article 7, Appendix I." The requirements of Section V, Article 7, Appendix I from the 2004 Edition and no Addenda of the ASME Code,Section XI, will be utilized.
IWA-2222 in the 2001 Edition through 2003 Addenda of the ASME Code,Section XI, and IWA-2222(a) in the 2004 Edition and no Addenda of the ASME Code,Section XI, states:
"Liquid penetrant examination shall be conducted in accordance with Section V, Article 6." The requirements of Section V, Article 6 from the 2004 Edition and no Addenda of the ASME Code,Section XI, will be utilized.
3.4 Duration of Proposed Request The request is submitted for the remainder of the current 1 O-year lSI interval of the nuclear power plants shown in Section 3.1 of this safety evaluation.
4.0 STAFF EVALUATION The NRC staff has evaluated the information provided by the licensee in a letter dated August 7, 2009, as supplemented by letter dated January 21,2010, pursuant to the regulatory requirements of 10 CFR 50.55a(g)(4)(iv). The regulation at 10 CFR 50.55a(g)(4)(iv) states that lSI of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of 10 CFR 50.55a, subject to the limitations and modifications, 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 NRC staff notes that IWA-2221(c) and IWA-2222(b) in the 2004 Edition and no Addenda of the ASME Code,Section XI, will allow the use of a visual acuity card to verify illumination adequacy in lieu of a digital light meter which was required by the 2001 Edition through 2003 Addenda of the ASME Code,Section XI. The staff also notes that ASME Code Case N-685, "Lightening Requirements for Surface Examination Section XI, Division 1," was approved for use by the NRC in Regulatory Guide 1.147, Revision 15. ASME Code Case N-685 states, in part, that "In lieu of measuring the light intenSity with a light meter, lighting may be considered sufficient if the examiner can resolve standard test chart characters as described for VT -1 in IWA-2210." ASME Code Case N-685 was incorporated into the 2004 Edition and no Addenda of the ASME Code,Section XI, as IWA-2221(c) and IWA-2222(b).
The 2004 Edition and no Addenda of the ASME Code,Section XI, has been incorporated by reference into 10 CFR 50.55a(b) subject to certain limitations and modifications. The NRC staff has determined that there are no limitations and modifications specified in 10 CFR 50.55a for IWA-2221 (a), IWA-2221 (b), IWA-?-221(c), IWA-2222(a), and IWA-2222(b) for ASME Code Class 1,2,3, and MC components that are subjected to the surface examinations using magnetic particle and liquid penetrant. Therefore, the licensee may use these subarticles in the 2004 Edition and no Addenda of the ASME Code,Section XI.
By letter dated January 21,2010, the licensee responded to the NRC staff's request for additional information and confirmed the related requirements for IWA-2221 (a), IWA-2221(b),
IWA-2221(c), IWA-2222(a), and IWA-2222(b) in the 2004 Edition and no Addenda of the ASME Code,Section XI, shall be met for ASME Code Class 1, 2, 3, and MC components.
-5 Subparagraph requirements for magnetic particle examination as follows:
IWA-2221 (a) requires the use of Section V, Article 7 of the 2004 Edition and no Addenda of the ASME Code,Section XI.
IWA-2221 (b) requires the use of Section V, Article 7, Appendix I, of the 2004 Edition and no Addenda of the ASME Code,Section XI.
IWA-2221 (c) requires the use of VT-1 in IWA-2210 of the 2004 Edition and no Addenda of the ASME Code,.Section XI.
Subparagraph requirements for liquid penetrant examination are as follows:
IWA-2222(a) requires the use of Section V, Article 6, of the 2004 Edition and no Addenda of the ASME Code,Section XI.
IWA-2222(b) requires the use of VT-1 in IWA-2210 of the 2004 Edition and no Addenda of the ASME Code,Section XI.
The NRC staff finds that the licensee's request acceptable to utilize from 2004 Edition and no Addenda of the ASME Code,Section XI, IWA-2221{a), IWA-2221(b), IWA-2221(c), IWA-2222(a),
and IWA-2222(b) for magnetic particle examination and liquid penetrant examination of ASME Code Class 1, 2, 3, and MC components provided that all of the above related requirements are met.
5.0 CONCLUSION
Pursuant to 10 CFR 50.55a(g)( 4 )(iv), the NRC staff approves the use of the subparagraphs IWA-2221 (a), IWA-2221(b), IWA-2221(c), IWA-2222(a), and IWA-2222(b) of the 2004 Edition and no Addenda of the ASME Code,Section XI, for the surface examination of ASME Code Class 1, 2, 3, and MC components for the remainder of the third 10-year ISI interval at Braidwood Station, Units 1 and 2, Byron Station, Unit Nos. 1 and 2, LaSalle County Station, Units 1 and 2, and Limerick Generating Station, Units 1 and 2, and for the remainder of the fourth 10-year lSI interval at Peach Bottom Atomic Power Station, Units 2 and 3.
All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: A. Rezai Date: Jul y 23, 2010
M. Pacilio
- 2 IWA-2221(b), IWA-2221(c), IWA-2222(a), and IWA-2222(b) of the 2004 Edition and no Addenda of the ASME Code,Section XI, for the surface examination of ASME Code Class 1, 2, 3, and MC components for the remainder of the third 1 O-year lSI interval at Braidwood Station, Units 1 and 2, Byron Station, Unit Nos. 1 and 2, LaSalle County Station, Units 1 and 2, and Limerick Generating Station, Units 1 and 2, and for the remainder of the fourth 10-year lSI interval at Peach Bottom Atomic Power Station, Units 2 and 3.
A copy of the Safety Evaluation is enclosed. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Project Manager Nicholas J. DiFrancesco at 301-415-1115.
Sincerely, IRA!
Robert D. Carlson, Branch Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-456, 50-457, 50-454,50-455, 50-373,50-374,50-352,50-353, 50-277, and 50-278
Enclosure:
Safety Evaluation cc wtencl: Distribution via Listserv DISTRIBUTION:
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