ML15064A125

Request for Relief I4R-01 from ASME Code Requirements for Replacement of Class 3 Essential Service Water Buried Piping with High Density Polyethylene Piping, for the Fourth 10-year Inservice Testing Interval

ML15064A125
Person / Time
Site:	Callaway
Issue date:	05/12/2015
From:	Markley M Plant Licensing Branch IV
To:	Diya F Union Electric Co
Lyon C
References
TAC MF4271
Download: ML15064A125 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 12, 2015 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - REQUEST FOR RELIEF 14R-01, ALTERNATIVE TO ASME CODE INSERVICE INSPECTION REQUIREMENTS FOR CLASS 3 BURIED PIPING (TAC NO. MF4271)

Dear Mr. Diya:

By application dated June 10, 2014, as supplemented by letters dated September 30, 2014, and April 24, 2015, Union Electric Company (dba Ameren Missouri, the licensee), requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, associated with requirements for Class 3 buried piping systems at Callaway Plant, Unit 1 (Callaway Plant). The licensee requested relief for the remaining life of the Callaway Plant, including plant life extension that has been sought through October 18, 2044, beginning with the fourth 10-year inservice inspection (ISi) interval, which began on December 19, 2014. The ASME Code Edition applicable to the fourth 10-year ISi interval for Callaway Plant is the 2007 Edition (up to and including the 2008 Addenda).

Subsequent to the licensee's application, on March 6, 2015, the NRC renewed the operating license for Callaway Plant for an additional 20 years, through October 18, 2044.

Specifically, pursuant to Title 10 of the Code of Federal Regulations ( 10 CFR) paragraph 50.55a(a)(3)(i)), the licensee requested continued use of installed high density polyethylene piping on the basis that the alternative examination provides an acceptable level of quality and safety.

The paragraph headings in 10 CFR 50.55a were changed by Federal Register notice dated November 5, 2014 (79 FR 65776), which became effective on December 5, 2014 (e.g., 10 CFR 50.55a(a)(3)(i) is now 50.55a(z)(1), and 50.55a(a)(3)(ii) is now 50.55a(z)(2)). See the cross reference tables, which are cited in the notice, in the Agencywide Documents Access and Management System at Accession No. ML14015A191 and ADAMS package Accession No. ML14211A050.

Based on the enclosed safety evaluation, the NRC staff determines that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1 ). Therefore, the NRC staff authorizes the use of Relief Request 14R-01 at Callaway Plant for the remaining life of the Callaway Plant, including plant life extension through October 18, 2044, for the subject components.

F. Diya All other ASME Code requirements for which relief was not specifically requested and approved remain applicable, including the third-party review by the Authorized Nuclear lnservice Inspector. If you have any questions, please contact Fred Lyon at 301-415-2296 or via e-mail at fred. lyon@nrc.gov.

Sincerely,

~c&d- t21~?tf2 Michael T. Markley, Chief

+-

Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

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 REQUEST FOR RELIEF 14R-01 RELATED TO THE INSERVICE INSPECTION PROGRAM FOR CLASS 3 BURIED PIPING UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By application dated June 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14161A399), as supplemented by letters dated September 30, 2014, and April 24, 2015 (ADAMS Accession Nos. ML14273A528 and ML15114A172, respectively), Union Electric Company (dba Ameren Missouri, the licensee), requested relief from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, associated with requirements for Class 3 buried piping systems at Callaway Plant, Unit 1 (Callaway Plant). The applicable ASME Code requirement is IWA-4221 (b), which requires that, "An item to be used for repair/replacement activities shall meet the Construction Code specified in accordance with (1 ), (2), or (3)," and ASME Section XI, IWA-4221(b)(1), which requires that "when replacing an existing item, the new item shall meet the Construction Code to which the original item was constructed." The licensee requested relief for the remaining life of the Callaway Plant, including plant life extension that has been sought through October 18, 2044, beginning with the fourth 10-year inservice inspection (ISi) interval, which began on December 19, 2014. The ASME Code Edition applicable to the fourth 10-year ISi interval for Callaway Plant is the 2007 Edition (up to and including the 2008 Addenda). Subsequent to the licensee's application, on March 6, 2015, the NRC renewed the operating license for Callaway Plant for an additional 20 years, through October 18, 2044.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(a)(3)(i)), the licensee requested continued use of installed high density polyethylene (HOPE) piping on the basis that the alternative examination provides an acceptable level of quality and safety.

The paragraph headings in 10 CFR 50.55a were changed by Federal Register notice dated November 5, 2014 (79 FR 65776), which became effective on December 5, 2014 (e.g., 10 CFR 50.55a(a)(3)(i) is now 50.55a(z)(1 ), and 50.55a(a)(3)(ii) is now 50.55a(z)(2)). See the Enclosure

cross-reference tables, which are cited in the notice, at ADAMS Accession No. ML14015A191 and ADAMS package Accession No. ML14211A050.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(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 the components.

The regulations in 10 CFR 50.55a(z) state that alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (1) the proposed alternatives would provide an acceptable level of quality and safety or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the Commission to authorize the proposed alternative requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Proposed Request for Relief 14R-01 The ASME Code components affected by the licensee's request are as follows:

Essential Service Water (ESW) Supply Piping Lines:

• EF-003-AZC, A Train, 36-inch diameter, 411 feet

• EF-007-AZC, B Train, 36-inch diameter, 518 feet ESW Return Piping Lines:

• EF-083-AZC, A Train, 36-inch diameter, 279 feet

• EF-014-AZC, B Train, 36-inch diameter, 288 feet The Code of record for the fourth 10-year ISi interval is the ASME Code,Section XI, 2007 Edition through the 2008 Addenda. The fourth 10-year ISi interval began on December 19, 2014. Relief is requested for remaining life of the plant, including plant life extension that has been sought through October 18, 2044.

The applicable Code requirement is IWA-4221 (b), which requires that, "An item to be used for repair/replacement activities shall meet the Construction Code specified in accordance with (1 ),

(2), or (3)," and ASME Code,Section XI, IWA-4221 (b)(1 ), which requires that, "when replacing an existing item, the new item shall meet the Construction Code to which the original item was constructed."

The Construction Code of record for buried ASME Class 3 ESW piping is ASME Code, Section Ill, Division 1 Subsection ND, 1974 Edition, through Summer 1975 Addenda. This Construction Code and later editions and addenda of this Construction Code do not provide rules for the design, fabrication, installation, examination, and testing of piping constructed using polyethylene material. By letter dated October 31, 2008 (ADAMS Accession No. ML082640007), as supplemented by letter dated November 7, 2008 (ADAMS Accession No. ML083100288), the NRC approved HOPE for use for the buried section of the ESW system in lieu of the carbon steel piping for Callaway Plant's third 10-year ISi interval.

As part of its proposed alternative and basis for use for 14R-01, the licensee stated in its letter dated September 24, 2015, that, In regard to continued use of the HOPE piping at Callaway, and to address the regulator's position that periodic testing would serve as a means to ensure integrity of the piping throughout the remainder of plant life, (as acknowledged in Ameren Missouri's letter ULNRC-06146, "Supplement to 10 CFR 50.55a Request:

Proposed Alternative to ASME Section XI Requirements for Class 3 Buried Piping," dated September 30, 2014), 10-year periodic hydrostatic pressure testing of the HOPE piping will be performed prior to the end of the second period of the fourth 10-year ISi interval, and then once during each of the subsequent 10-year ISi intervals for the remainder of life of Callaway Plant.

3.2 NRC Staff Evaluation The use of HOPE was approved at Callaway Plant for the third 10-year ISi interval on October 31, 2008, as supplemented by letter dated November 7, 2008. At that time, HOPE was not in use in nuclear power facilities in the United States, which warranted a 10-year limit to the NRC staff's approval. With further research and inservice history, there is compelling evidence that the continued use of HOPE will provide an acceptable level of quality and safety for the remainder of plant life, provided that periodic testing is performed. Periodic hydrostatic testing will insure that if any slow crack growth or failures in the piping have occurred, the licensee will have the ability to perform repair/replacement activities before causing any adverse effects during operation of the ESW piping system.

4.0 CONCLUSION

As set forth above, the NRC staff determines that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1).

Therefore, the NRC staff authorizes the continued use of HOPE for the remaining life of the Callaway Plant, including plant life extension through October 18, 2044.

All other ASME Code,Section XI, requirements for which relief was not specifically requested and authorized remain applicable, including the third-party review by the Authorized Nuclear lnservice Inspector.

Principal Contributor: M. Audrain, NRR/DE/EPNB Date: May 12, 2015

ML15064A125 *email dated OFFICE NRR/DORL/LPL4-1 /PM NRR/DORL/LPL4-1 /LA NRR/DE/EPNB/BC* NRR/DORL/LPL4-1 /BC NAME FLyon JBurkhardt* DAiiey MMarkley (BSingal for)

DATE 5/11/15 3/6/15 3/5/15 5/12/15