ULNRC-06256, Supplement to Request 14R-02 for Relief from Requirements of ASME Section XI, Table IWF-2500-1 for 100 Percent Visual Examination of Class 1 Supports
| ML15280A045 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/06/2015 |
| From: | Maglio S Ameren Missouri, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MF5613, ULNRC-06256 | |
| Download: ML15280A045 (6) | |
Text
JIi1eteII Callaway Plant MISSOURI October 6, 2015 ULNRC-0625 6 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 50.55a Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
RENEWED FACILITY OPERATING LICENSE NPF-30 SUPPLEMENT TO REQUEST 14R-02 FOR RELIEF FROM REQUIREMENTS OF ASME SECTION XI, TABLE IWF-2500-1 FOR 100% VISUAL EXAMINATION OF CLASS 1 SUPPORTS, TAC NO. MF5613
Reference:
1.
ULNRC-06 176, Request 14R-02 for Relief from Requirements of ASME Section XI, Table IWF-2500-l for 100% Visual Examination of Class 1 Supports, dated January 26, 2015 (ADAMS Accession No. ML15026A6$6)
Reference 1 transmitted a request for relief from the requirements of ASME Section XI, Table IWF 2500-1, Category F-A, Item Number Fl.40, to perform a 100% visual examination of the Reactor Pressure Vessel supports, on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. The requested relief is intended for the fourth 10-year inservice inspection interval of Callaways Inservice Inspection (ISI) Program. With regard to the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code, i.e.,Section XI, Rules and Inservice Inspection of Nuclear Power Plant Components, the Code Edition and Addenda applicable to Callaways fourth 10-year ISI interval is the 2007 Edition through 2008 Addenda. Supporting information and essential details for the requested Code relief, including proposed alternative and basis for use, were provided in Relief Request 14R-02 attached to the Reference 1 letter.
P0 Box 620 Fulton, FV0 65251 8nierenV1issourLcorn STARS Alliance
ULNRC-06256 October 6, 2015 Page 2 After submittal of Reference 1 and attached Relief Request 14R-02, it was found that that these documents had incorrectly cited 10 CFR 50.55a(a)(3)(ii), which was superseded by 10 CFR 50.55a(z)(2), as the regulatory basis for requesting relief Thus, to be clear, pursuant to 10 CFR 50.55a(z)(2), Ameren Missouri is requesting relief from the requirements of ASME Section XI, Table IWF-2500-1, Category F-A, Item Number F 1.40, to perform a 100% visual examination of the Reactor Pressure Vessel supports, on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. A change page to correct previously submitted Relief Request 14R-02 is attached.
This letter does not contain new commitments. If there are any questions, please contact J. P. Kovar at 314-225-1478.
Sincerely, A.
S. A. Mag}
Manager, Regulatory Affairs JPK
Attachment:
10 CFR 50.55a Request Number 14R-02 Change Page
ULNRC-062 56 October 6, 2015 Page 3 cc:
Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission
$201 NRC Road Steedman, MO 65077 Mr. L. John Kios Project Manager, Callaway Plant Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O$H4 Washington, DC 20555-0001
ULNRC-06256 October 6, 2015 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:
Certrec Corporation 6100 Western Plaza Suite 1050 Fort Worth, TX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Other Situations ULNRC Distribution:
F. M. Diya D. W. Neterer L. H. Graessle T. E. Herrmann B. L. Cox M. M. Hall S. A. Maglio T. B. Elwood M. G. Hoehn Corporate Communications N$RB Secretary STARS Regulatory Affairs Mr. John ONeill (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission
Attachment to ULNRC-06256 10 CFR 50.55a Request Number 14R-02 Change Page 1 Page
Enclosure to ULNRC-06 176 Change Page (ref. ULNRC-06256) 10 CFR 50.55a Request Number 14R-02 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(2)
Hardship or Unusual Difficulty Without a Compensating Increase in the Level of Quality or Safety ASME Code Components Affected Reactor Vessel Supports, Component Numbers 2-RBB01-01, 2-RBBOI-02, 2-RBBO1-03 and 2-RBBOI-04
===2.
Applicable Code Edition and Addenda===
ASME Boiler and Pressure Vessel Code,Section XI. 2007 Edition through 2008 Addenda
===3.
Applicable Code Requirement===
Relief is requested from the requirements of ASME Section XI, Table IWF-2500-l, Category F-A, Item Number F 1.40 which requires that 100% of Class I supports, other than piping supports, be subject to a visual, VT-3 examination once every inspection interval.
===4.
Reason for Request===
Pursuant to 10 CFR 50.55a(z)(2), relief is requested on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. Conformance with the applicable inservice inspection requirements would necessitate a design modification to the Reactor Pressure Vessel (RPV) supports and associated insulationlwalk-plate to allow 100% visual examination of the subject supports.
In addition, limited accessibility and high radiation levels in the area where these supports are located further reduces the percentage of the supports available for visual examination.
The Callaway RPV is supported by two cold leg nozzles and two hot leg nozzles. There is a support assembly at each of these nozzles that consists of a nozzle weld build-up, shoe plate, air cooled box, and steel support structure embedded in the primary shield wall. Figures 1 and 2 depict these support assemblies. As shown in the Figures, only the nozzle weld build-up and shoe plate are completely accessible for a visual VT-3 examination. Most of the air cooled box and the entire steel support structure are located beneath a steel walk-plate, and only the top of the air cooled box is directly accessible. An additional 20 to 30 percent of the air cooled box and a very small percentage of the steel support structure would be made accessible if the steel walk plate and insulation were removed.
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