ML13175A125

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Relief from the Requirements of the ASME Code, Relief Request No. I5R-07
ML13175A125
Person / Time
Site: Oyster Creek
Issue date: 08/06/2013
From: Veronica Rodriguez
Plant Licensing Branch 1
To: Pacilio M
Exelon Nuclear, Exelon Generation Co
Lamb J, NRR/DORL/LPLI-2, 415-3100
References
Relief Request No. I5R-07, TAC ME9490
Download: ML13175A125 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 6,2013 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60SSS

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - RELIEF FROM THE REQUIREMENTS OF THE ASME CODE, RELIEF REQUEST NO. ISR-07 (TAC NO. ME9494)

Dear Mr. Pacilio:

By letter dated August 28, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12243A287). Exelon Generation Company (Exelon, the licensee),

submitted Request for Relief (RR) ISR-07 for the U.S. Nuclear Regulatory Commission's (NRC's) approval. The licensee proposed an alternative to certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),

Section XI. RR ISR-07 is requested for the fifth 10-year inservice inspection (lSI) interval at Oyster Creek Nuclear Generating Station (Oyster Creek), which commenced on January 1S, 2013. The 2007 Edition through the 2008 Addenda of the ASME Code,Section XI, is the current Code of record at Oyster Creek. Specifically, pursuant to Title 10 of the Code Federal Regulations (10 CFR), paragraph SO.SSa(a)(3)(i), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety.

The NRC staff has reviewed the subject request and has concluded, as set forth in the enclosed safety evaluation, that the proposed alternative described in RR ISR-07 provides an acceptable level of quality and safety. Accordingly, the staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME Code's requirements.

Therefore, the NRC staff authorizes the alternative described in RR ISR-07 for the fifth 10-year lSI interval at Oyster Creek, which began on January 1S, 2013, and ends on January 14, 2023.

All other ASME Code requirements for which relief was not specifically requested and approved in the subject request remain applicable, including a third party review by the Authorized Nuclear Inservice Inspector.

M. Pacilio

- 2 If you have any questions regarding this matter, please contact the Senior Project Manager, John G. Lamb at (301) 415-3100 or bye-mail at John.Lamb@nrc.gov.

Sincerely,

~~

Veronica ROd~ing Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219

Enclosure:

Safety Evaluation cc w/enclosure: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF 15R-07 FOR THE FIFTH INSERVICE INSPECTION INTERVAL OYSTER CREEK NUCLEAR GENERATING STATION EXELON NUCLEAR DOCKET NO. 50-219

1.0 INTRODUCTION

By letter dated August 28, 2012, (Agencywide Documents Access and Management System (ADAMS), Accession No. ML12243A287), Exelon Generation Company (Exelon, the licensee) proposed Request for Relief (RR) No. 15R-07 from certain requirements of the American Society of Mechanical Engineers (ASME). Boiler and Pressure Vessel Code (Code), under the provisions of Title-1 0 of the Code of Federal Regulations (10 CFR), paragraph 50.55a(a)(3)(i),

for the fifth 10-year Inservice Inspection (lSI) Program for Oyster Creek Nuclear Generating Station (OCNGS).

2.0 REGULATORY EVALUATION

lSI of the ASME Code Class 1. 2, and 3 components is to be performed in accordance with Section XI of the ASME Code, and applicable addenda, as required by paragraph 50.55a(g) of 10 CFR, except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). The regulation at 10 CFR 50.55a(a)(3), state, in part, that alternatives to the requirements of paragraph (g) may be used, when authorized by the U.S. Nuclear Regulatory Commission (NRC), jf the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The licensee has proposed alternatives from ASME Code requirements pursuant to 10 CFR 50.55a(a)(3)(i). The ASME Code of record for the OCNGS fifth 10-year lSI interval program is the 2007 Edition through the 2008 Addenda of Section XI of the ASME Code. The fifth 10-year lSI intervai began on January 15, 2013 and is projected to end on January 14, 2023.

Enclosure

- 2

3.0 TECHNICAL EVALUATION

RR 15R-07 3.1 ASME Code Component{s) Affected (as stated by the licensee)

Code Class:

All Classes

Reference:

[ASME Code] IWA-2441 (b) and ASME Code Case N-532-4

[ASME Code] Examination Category:[Not Applicable] (N/A)

Item Number:

N/A

==

Description:==

Expanded Applicability for use of Code Case N-532-4 "Repair/Replacement Activity Documentation Requirements and Inservice Summary Report Preparation and Submission" Component Number:

N/A 3.2 ASME Code Requirements (as stated by the licensee)

[ASME Code,Section XI,] IWA-2441 (b) requires Code Cases be applicable to the Edition and Addenda specified in the Inspection Plan.

ASME Code Case N-532-4, "Repair/Replacement Activity Documentation Requirements and Inservice Summary Report Preparation and Submission, [Section XI, Division 1,]"

provides requirements that may be used to document repair/replacement activities.

3.3 Licensee's Basis for Relief Request (as stated by the licensee)

Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.

On January 15, 2013, [OCNGS] will start its fifth ten-year interval lSI program under the requirements of the 2007 Edition through the 2008 Addenda of ASME

[Code] Section XI. When implementing this edition of ASME [Code,] Section XI, Paragraph IWA-2441 (b) requires code cases be applicable to the Edition and Addenda specified in the Inspection Plan.

ASME Code Case N-532-4 has an applicability limited up to the [ASME Code, Section XI] 2004 Edition through the 2005 Addenda, which is identified in the latest applicability index for ASME [Code,] Section XI Code Cases. Since ASME Code Case N-532-4 only applies up to the 2004 Edition through the 2005 Addenda, Paragraph IWA-2441 (b) does not allow the use of ASME Code Case N-532-4 for the [OCNGS] fifth ten-year interval lSI program.

3.4 Licensee's Proposed Alternative Examination (as stated by the licensee)

[OCNGS] requests the applicability of ASME Code Case N-532-4 be extended to the 2007 Edition through the 2008 Addenda for use in the plant's fifth interval lSI

- 3 program. The NRC has accepted the use of ASME Code Case N-532-4 as an acceptable method for repair/replacement activity documentation requirements and inservice summary report preparation and submission in the latest revision of Regulatory Guide 1.147, Revision 16.

No technical changes to ASME Code Case N-532-4 are being proposed in this relief request. This relief request is being submitted to correct a timing situation, which has resulted from the application of the 2007 Edition through the 2008 Addenda of ASME Section XI for [OCNGS.] Since no technical change is proposed in this relief request, [OCNGS] considers that this alternative provides an acceptable level of quality and safety, and is consistent with provisions of 10 CFR 50.55a(a)(3)(i).

3.5

NRC Staff Evaluation

The licensee's code of record for the fifth 10-year lSI interval is the 2007 Edition through the 2008 Addenda of the ASME Code,Section XI, IWA-2441 (b), requires ASME Code Cases be applicable to the Edition and Addenda specified in the Inspection Plan. The licensee intends to invoke ASME Code Case N-532-4; however, ASME Code Case N-532-4 has an applicability limited up to the ASME Code,Section XI, 2004 Edition through the 2005 Addenda, which is identified in the latest applicability index for ASME Code,Section XI, code cases. ASME Code Case N-532-4 only applies up to the 2004 Edition through the 2005 Addenda, Paragraph IWA 2441 (b) and does not allow the use of ASME Code Case N-532-4 for the OCNGS fifth 10-year interval lSI program. The licensee requested as an alternative the applicability of ASME Code Case N-532-4 be extended to the 2007 Edition through the 2008 Addenda for use in the plant's fifth 10-year lSI interval program.

There are no technical requirements contained in ASME Code Case N-532-4 and it is only used for repair/replacement activity documentation requirements and inservice summary report reparation and submission, and administrative record keeping. Therefore, the use of the subject ASME Code Case will not affect the structural integrity of any safety related operating components in OCNGS. The NRC staff has concluded that use of ASME Code Case N-532-4 for the OCNGS fifth 10-year lSI interval provides an acceptable level of quality and safety.

3.6 Duration of Relief RR 15R-07 is requested for the fifth 10-year lSI interval of OCNGS, which commenced on January 15, 2013.

4.0 CONCLUSION

As set forth above, the NRC staff has determined that authorizing alternatives pursuant to 10 CFR 50.55a(a)(3)(i) for RR 15R-07 provides an acceptable level of quality and safety.

Accordingly, the staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i). Therefore, the NRC staff authorizes the alternatives to the specified ASME Code,Section XI, contained in RR No. 15R-07 for the remainder of the OCNGS fifth 10-year lSI interval.

- 4 A" other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principle Contributor: T. McLellan Date: August 6, 2013

M. Pacilio

- 2 If you have any questions regarding this matter, please contact the Senior Project Manager, John G. Lamb at (301) 415-3100 or bye-mail at John.Lamb@nrc.gov.

Docket No. 50-219

Enclosure:

Safety Evaluation cc w/enclosure: Distribution via Listserv DISTRI BUTION:

PUBLIC LPL 1-2 R/F RidsNrrDorlLpl1-2 RidsNrrPMOysterCreek RidsNrrLAABaxter RidsNrrDeEpnb RidsRgn1 MailCenter RidsAcrsAcnw_MailCTR TMcLellan, NRR DMerzke, OEDO ADAMS Accession No.: ML13175A125 Sincerely, Ira!

Veronica Rodriguez, Acting Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

  • via email OFFICE LPL1-2/PM LPL3-1/LAiT LPL1-2/LA EVIB/BC LPL1-2/BC (A)

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