ML112971506
| ML112971506 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/21/2011 |
| From: | Onge R Southern California Edison Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| ISI-3-35 | |
| Download: ML112971506 (5) | |
Text
SOUTHERN CALIFORNIA EDISON ~
Richard J. St. Onge Director, Nuclear Regulatory Affairs and Emergency Planning An EDISON INTERNATlONAL~ Comp any U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 October 21, 2011 10 CFR 50.55a
Subject:
Docket Nos. 50-361 and 50-362 Request 151-3-35 in Accordance with 10 CFR 50.55a(g)(4)(iv)
Use of Subsequent Edition of AsME OM Code for Snubbers Program San Onofre Nuclear Generating Station Units 2 and 3
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(g)(4)(iv), Southern California Edison Company (SCE) submits the attached request for the NRC approval of the use of subsequent ASME Code for Operation and Maintenance of Nuclear Power Plants (OM) Edition and Addenda applicable to Safety Related Seismic Restraints (Snubbers) for the remainder of the 3rd 10 Year Interval and for the 4th 10 Year Interval at the San Onofre Nuclear Generating Station (SONGS), Unit 2 and Unit 3.
Paragraph 10 CFR 50.55a(g)(4)(iv) allows that inservice examination and tests of components may meet the requirements set forth in subsequent Editions arid Addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the conditions and clarifications listed in 10 CFR 50.55a(b) and subject to Commission approval. Southern California Edison requests the Commission's authorization for SONGS to use the ISTA and ISTD subsections of ASME OM 2004 Edition with OMa 2005 and OMb 2006 Addenda as allowed by the regulations pursuant to 10 CFR 50.55a(b)(3). SONGS will comply with all conditions and clarifications stated in 10 CFR 50.55a(b) related to implementation of the ASME OM Code 2004 Edition with OMa 2005 and OMb 2006 Addenda as they pertain to snubbers.
NRC approval of the SONGS use of subsequent Code Edition and Addenda is requested in time to support transition to the new program by the start of Unit 3 Cycle 17 Refueling Outage currently scheduled to begin October 7,2012.
There are no new commitments contained in this letter or the enclosure.
P.O. Box 128 San Clemente, CA 92672
Document Control Desk October 21, 2011 If you have any questions or would like additional information concerning this subject, please call Linda Conklin (949) 368-9443.
Sincerely,
Enclosure:
Request ISI-3-35 In Accordance with 10 CFR 50.55a(g)(4)(iv) for lSI Components use of Subsequent ASME Code Edition and Addenda.
cc:
E.E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 & 3 G.G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 & 3
ENCLOSURE Request ISI-3-35 10 CFR 50.55a(g)(4)(iv) for lSI Components Use of Subsequent ASME Code Edition and Addenda.
Snubber Program
Request 151-3-35 In Accordance with 10 CFR 50.55a(g)(4)(iv) for 151 Components to use Subsequent ASME OM Code Edition and Addenda for the remainder of the 3rd Ten Year Interval and for the 4th Ten Year Interval at the San Onofre Nuclear Generating Station (SONGS), Unit 2 and Unit 3
- 1. ASME Code Component Affected All seismic restraints (snubbers) in San Onofre Nuclear Generating Station (SONGS) Unit 2 and Unit 3 within the scope described in ASME OM Code, Subsection ISTA-1100(c).
2. Applicable Code Edition and Addenda
The Inservice Inspection Code of Record for the current 10 Year lSI Interval at SONGS, Unit 2 and Unit 3 is ASME B&PV Code - Section XI, 1995 Edition with 1996 Addenda. In accordance with Table IWA-1600-1 of the lSI Code of Record and 10 CFR 50.55a(b)(2)(vii), the Code of Record for the snubbers is the ASME/ANSI OM 4,1987 Edition with OMa-1988 Addenda.
- 3. Proposed Subsequent Code Edition and Addenda The proposed subsequent Code edition and addenda is the ASME OM Code 2004 Edition with OMa-2005 and OMb-2006 Addenda, Federal Register notice 76FR36232. In accordance with 10 CFR 50.55a(b)(3)(v)(B), Federal Register notice 75FR24324, the particular section of the subsequent Code applicable to snubbers is Subsection ISTO with the support of subsection ISTA for General Requirements.
The significant changes and improvements between the current Code of record and the subsequent Code are (1) testing is more performance based and (2) test plans rely on distinct test plan groups based on predetermined attributes.
SONGS is prepared to transition the Snubber Program out of the Licensee Controlled Specifications (LCS) to the ASME OM 1ST Code, Subsection ISTO in accordance with 10 CFR 50.55a(b)(3)(v)(B) and begin the use of the subsequent Code Edition and Addenda upon NRC approval of this request. The proposed edition and Addenda of the OM Code will apply to the Snubber Program for the remainder of the 3rd Ten Year Interval and for the 4th 10 Year Interval. With the use of ASME OM Code 2004 Edition with OMa-2005 and OMb-2006 Addenda, snubbers will no longer follow requirements of the ASME BPV Code,Section XI.
- 4. Related Requirements SONGS is requesting approva l for usage of the subsequent ASME OM 2004 Edition, OMa-2005 and OMb-2006 Addenda subject to all applicable conditions and clarifications in 10 CFR 50.55a(b) pertaining to snubbers. All applicable requirements of subsections ISTA and ISTO of the ASME OM Code 2004 Edition with OMa-2005 and OMb-2006 Addenda will be met and implemented. SONGS proposes to apply the requirements of the subsequent Code Edition and Addenda only to snubbers. No other requirements of the subsequent Code Edition and Addenda are proposed to be implemented.
- 5. Duration of Proposed Request The duration of this request is the remainder of the 3rd Ten Year lSI Interval (which ends August 17, 2013) and the 4th Ten Year 1ST Interval for SONGS Unit 2 and Unit 3 (which will begin on August 18, 2013).