ML13358A030

Request for Additional Information, Relief Request I3R-15 Class 1 Pressure-Retaining Piping/Components Leakage Testing at Full Pressure, Third 10-Year Inservice Inspection Interval

ML13358A030
Person / Time
Site:	Callaway
Issue date:	12/24/2013
From:	Lyon C Plant Licensing Branch IV
To:	Heflin A Union Electric Co
Lyon C
References
TAC MF2921
Download: ML13358A030 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001

~ecember 24, 2013 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: 13R-15, PROPOSED ALTERNATIVE REGARDING PRESSURE RETAINING BOUNDARY DURING SYSTEM LEAKAGE TEST (TAC NO.

MF2921)

Dear Mr. Heflin:

By letter dated October 17,2013, Union Electric Company (dba Ameren Missouri, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval request for alternative (RFA) 13R-15 for the Callaway Pant, Unit 1. The licensee proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, regarding the scope of Class 1 pressure retaining piping and components required to be included in system leakage testing at a pressure corresponding to 100 percent power operation, as specified in Paragraph IWB-5222(b) of the ASME Code.

The NRC staff has reviewed the information provided in your application and determined that additional information is required in order to complete its formal review. The enclosed questions were provided to T. Elwood of your staff on December 17, 2013.

A. Heflin -2 Please provide a response to the enclosed questions by January 31,2014. If you have any questions, please contact me at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION 13R-15, PROPOSED ALTERNATIVE REGARDING PRESSURE RETAINING BOUNDARY DURING SYSTEM LEAKAGE TEST UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 By letter dated October 17,2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13291A041), Union Electric Company (dba Ameren Missouri, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval request for alternative (RFA) 13R-15. The licensee proposed an alternative to a certain requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

Section XI. RFA 13R-15 relates to the inservice inspection (lSI) requirement of IWB-5222(b) during system leakage tests at the Callaway Plant, Unit 1.

The NRC staff has reviewed the information provided in the application and determined that the additional information is required in order to complete its formal review.

1. Please provide additional discussion as requested below for the basis for hardship for not meeting the ASME Code system leakage test requirements of IWB-5222(b) for the Group 1, 2, 3, 4, and 5 piping system identified in Section 1 of RFA 13R-15. For example, refer to the request for Sequoyah, ADAMS Accession No. ML13178A280.

a. Discuss potential personnel safety hazards that could be introduced if each group of piping is subjected to the system leakage test in accordance with IWB-5222(b). Examples include occupational hazards, risk for spills, contaminations, and exposure to unwanted excess radiations.

b. Provide an estimate for person-rem (roentgen equivalent man) exposure with consideration of as low as reasonably achievable (ALARA).

c. Discuss whether the leakage test in accordance with the IWB-5222 requirements could cause a reactor trip or violate any requirement(s) of the technical speCifications (TS).

2. Discuss whether alternative options, such as the use of external pressure source, and temporary or permanent modifications, such as installing temporary or permanent piping to facilitate performance of the required system leakage test in accordance with fWB-5222, have been considered and determined to be not practical options.

Enclosure

- 2

3. For justification that the structural integrity or leak tightness of each group of piping identified in RFA 13R-15 will be reasonably ensured, without the required extension in pressure retaining boundary during system leakage test, discuss whether there has been any industry or plant-specific operating experience regarding potential degradation of the welded connections in the piping and components identified in RFA 13R-15 due to known degradation mechanisms that would lead to leakage.

ML13358A030 *email dated OFFICE NRR/DORUlPl4*1IPM NRR/DORUlPL4*1/LA NRRlDEIESGB/BC NRRlDORULPL4*1/BC NRR/DORULPl4*1/PM NAME FLyon JBurkhardt GKulesa' MMarkley FLyon DATE 12/24/13 12/24/13 12117/13 12/24/13 12/24/13