ML101380042
| ML101380042 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/28/2009 |
| From: | Price J Dominion, Dominion Nuclear Connecticut |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IR-3-12, N-513-2, FOIA/PA-2011-0115 | |
| Download: ML101380042 (7) | |
Text
Dominion Nuclear Connecticut, Inc.
lu Dominion Boulevard, Glen Alien, Virginm ,l)6f) D o m inioE
.L .'\ddrcss: wwwdom.com May 28, 2009 U. S. Nuclear Regulatory Commission Serial No.09-283 Attention: Document Control Desk NSSL/WDC RO.
Washington, DC 20555 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 3 ALTERNATIVE REQUEST IR-3-12 FOR THE USE OF ASME CODE CASE N-51 3-2 On April 23, 2009, Dominion Nuclear Connecticut, Inc. (DNC) began the Millstone Power Station Unit 3 (MPS3) Third 10-year Interval Inservice Inspection (ISI) program, which meets the requirements of the 2004 Edition of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. Within the 2004 Edition of Section Xl, subparagraph IWA-2441(b) requires that Code Cases shall be applicable to the Edition and Addenda specified in the Inspection Plan. Code Case N-513-2, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1," has an applicability limited to the 2003 Addenda and therefore does not meet this requirement.
Currently, Code Case N-513-2 is listed as acceptable for use with no conditions in Nuclear Regulatory Commission (NRC) Regulatory Guide 1.147, Revision 15.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), DNC is requesting approval to use Code Case N-513-2 at MPS3 in accordance with the information provided in the attached request.
If you have any questions regarding this submittal, please contact W. D. Craft at (804) 273-4687.
Sincerely, J. ce" ViiU resident- Nuclear Engineering
Attachment:
- 1. Alternative Request IR-3-12 For The Use of ASME Code Case N-513-2 Commitments made in this letter:
- 1. None "0Pu-
Serial No.09-283 Alternative Request IR-3-12 Docket No. 50-423 Page 2 of 2 cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Ms. C. J. Sanders Project Manager - Millstone Power Station U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop O-8B3 Rockville, MD 20852-2738 Mr. S. W. Shaffer (w/o attachments)
NRC Senior Resident Inspector Millstone Power Station
Serial No.09-283 Alternative Request IR-3-12 Docket No. 50-423 ATTACHMENT 1 ALTERNATIVE REQUEST IR-3-12 FOR THE USE OF ASME CODE CASE N-513-2 DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 3
Serial No.09-283 Alternative Request IR-3-12 Docket No. 50-423 Attachment 1 Page 1 of 4 ALTERNATIVE REQUEST IR-3-12 FOR THE USE OF ASME CODE CASE N-513-2 CONTENTS A C R O N Y MS ..................................................................................................... . . 1 1.0 REASO N FO R THE REQUEST ................................................................. 2 2.0 CODE COMPONENTS FOR WHICH THE ALTERNATIVE IS R E Q UE S T E D ......................................................................................... . . 2 3.0 CODE REQUIREMENTS FOR WHICH THE ALTERNATIVE IS REQUESTED ................................................ 3 4.0 PROPOSED ALTERNATIVES AND SUPPORTING INFORMATION ...... 3 5.0 DURATION OF THE PROPOSED REQUEST ............................................... 3 6 .0 P R E C E D E NT S ........................................................................................... .3 7 .0 R E F E R E NC E S .......................................................................................... . .4 8 .0 C O N C LUS IO N .......................................................................................... .. 4 ACRONYMS ASME American Society of Mechanical Engineers DNC Dominion Nuclear Connecticut, Inc MPS3 Millstone Power Station Unit 3 NRC Nuclear Regulatory Commission RIS Regulatory Issue Summary
Serial No.09-283 Alternative Request IR-3-12 Docket No. 50-423 Attachment 1 Page 2 of 4 ALTERNATIVE REQUEST IR-3-12 FOR THE USE OF CODE CASE N-513-2 ProposedAlternative In Accordance with 10 CFR 50.55a(a)(3)(i)
- Alternative Provides an Acceptable Level of Quality and Safety -
1.0 REASON FOR THE REQUEST On April 23, 2009, Dominion Nuclear Connecticut, Inc. (DNC) began the Millstone Power Station Unit 3 (MPS3) Third 10-year Interval Inservice Inspection (ISI) program, which meets the requirements of the 2004 Edition of Section Xl of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Reference
- 1) and is specified in the Inspection Plan.
When using Code Cases with the 2004 Edition of Section XI, subparagraph IWA-2441(b) requires the following be met:
"IWA-2441 Section XI Code Cases (b) Code Cases shall be applicable to the Edition and Addenda specified in the Inspection Plan."
Code Case N-513-2, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1," (Reference 2) has an applicability limited to the 2003 Addenda, which is identified in Section 7 of the Case and in the latest applicability index of the ASME Code Cases Book, 2007 Edition, Code Cases: Nuclear Components, Supplement 5 Applicability Index (Reference 3). Since Code Case N-513-2 only applies up to the 2003 Addenda, IWA-2441(b) does not allow the use of Code Case N-513-2 for MPS3.
The Nuclear Regulatory Commission (NRC) has accepted the use of Code Case N-513-2 in its Regulatory Issue Summary (RIS) 2005-20, Rev.1, Revision to NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations &
Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality and Safety," (Reference 4) as an acceptable method for evaluating the structural integrity of flaws identified in moderate-energy piping. Additionally, the NRC has accepted Code Case N-513-2 in the latest revision of Regulatory Guide 1.147 (Reference 5).
2.0 CODE COMPONENTS FOR WHICH THE ALTERNATIVE IS REQUESTED Code Case N-513-2 will be applied as needed at MPS3 to accept flaws, including through-wall flaws, in moderate energy Class 2 or 3 piping, without performing a
Serial No.09-283 Alternative Request IR-3-12 Docket No. 50-423 Attachment 1 Page 3 of 4 repair/replacement activity for a limited time, not exceeding the time to the next scheduled refueling outage, which is within the requirements contained in the Code Case.
3.0 CODE REQUIREMENTS FOR WHICH THE ALTERNATIVE IS REQUESTED "IWA-2441 Section XI Code Cases (b) Code Cases shall be applicable to the Edition and Addenda specified in the Inspection Plan" 4.0 PROPOSED ALTERNATIVES AND SUPPORTING INFORMATION Since Code Case N-513-2 is the latest NRC approved version of this Case, DNC requests approval to use this Code Case without meeting the requirements of IWA-2441(b). The applicability requirements will be limited to those in Section 7 of the Code Case currently written as follows:
"7 APPLICABILITY This Case is applicable from the 1983 Edition with the Winter 1985 Addenda through the 2001 Edition with the 2003 Addenda. References in this Case to Appendix C shall mean Appendix C of the 2002 Addenda. Foreditions and addenda priorto 2002 Addenda, Class I pipe flaw evaluation proceduresmay be used for otherpiping classes. As a matter of definition, the term "structuralfactor" is equivalent to the term "safety factor"that is used in earliereditions and addenda."
No technical changes to Code Case N-513-2 are being proposed in this request.
5.0 DURATION OF THE PROPOSED REQUEST The proposed alternative to the requirements in IWA-2441(b), to use Code Case N-513-2 with the applicability to the 2003 Addenda, will be applied to the end of the current MPS3 third 10-year ISI interval or until such time as Code Case N-513-3 is accepted for use in a later revision of NRC Regulatory Guide 1.147. Code Case N-513-3 has been approved by the ASME and includes a new applicability for the Case up to the 2007 Edition with the 2008 Addenda of Section Xl. When Code Case N-513-3 is accepted for use by the NRC in NRC Regulatory Guide 1.147, this alternative will no longer be needed.
6.0 PRECEDENTS Because of the recent approval of the 2004 Edition of Section XI in 10 CFR 50.55a, there are no precedents for this type .of request at this time.
Serial No.09-283 Alternative Request IR-3-12 Docket No. 50-423 Attachment 1 Page 4 of 4
7.0 REFERENCES
- 1. ASME Code, Section Xl, 2004 Edition, no Addenda.
- 2. ASME Code Case N-513-2, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1,"
dated February 20, 2004.
- 3. ASME Code Cases Book, 2007 Edition, Code Cases: Nuclear Components, Supplement 5 Applicability Index.
- 4. NRC Regulatory Issue Summary 2005-20, Revision1, Revision to NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality and Safety," dated April 16, 2008.
- 5. NRC Regulatory Guide 1.147 Revision 15, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," October 2007.
8.0 CONCLUSION
With the application of the 2004 Edition of Section XI for the third 10-year ISI interval as specified in the Inspection Plan, Code Case N-513-2, which references only up to the 2003 Addenda of Section Xl, is no longer applicable for MPS3 under the requirements of IWA-2441(b). This request is being submitted to allow use of approved Code Case N-513-2 as an alternative to the requirements of the 2004 Edition of Section Xl. The Code Case will be applied to the end of the current MPS3 third 10-year ISI interval or until Code Case N-513-2 is approved by the NRC in Regulatory Guide 1.147. Since no technical change is proposed in this request, DNC considers this proposed alternative provides an acceptable level of quality and safety and is consistent with the provisions of 10 CFR 50.55a(a)(3)(i).