ML17171A320
| ML17171A320 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/05/2017 |
| From: | David Wrona Plant Licensing Branch III |
| To: | Bryan Hanson Exelon Generation Co |
| Vaidya B | |
| References | |
| CAC MF9708, CAC MF9709 | |
| Download: ML17171A320 (11) | |
Text
Mr. Bryan C. Hanson Senior Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 5, 2017 Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 - RELIEF FROM REQUIREMENTS OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI, (ASME CODE) REGARDING RELIEF REQUEST 14R-10, PROPOSED ALTERNATIVE TO UTILIZE CODE CASE N-513-4 (CAC NOS. MF9708 AND MF9709)
Dear Mr. Hanson:
By letter dated May 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17137A351), Exelon Generation Company, LLC (Exelon the licensee), submitted a request in accordance with Paragraph 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (1 O CFR) for a proposed alternative to the requirements of Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for LaSalle County Station, Units 1 and 2 (LSCS). The proposed alternative, relief request (RR) 14R-10, would allow the licensee to use ASME Code Case N-513-4, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1,"
for the evaluation and temporary acceptance of flaws in moderate energy Class 2 and 3 piping in lieu of specified ASME Code requirements for the fourth 10-year inservice inspection (ISi)
Interval which would begin on October 1, 2017, and end on September 30, 2027, or until such time as the U.S. Nuclear Regulatory Commission (NRC) approves Code Case N-513-4 for general use through revision of NRC Regulatory Guide (RG) 1.147 or other document.
Specifically, pursuant to 1 O CFR 50.55a(z)(2), the licensee requested to use the alternative on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
As set forth in the enclosed safety evaluation, the NRC staff determined that the proposed alternative, RR 14R-10, provides reasonable assurance of structural integrity of the subject components and that complying with IWC-3120, IWC-3130, IWD-3120(b), and IWD-3400 of the ASME Code,Section XI, would result in a hardship or unusual difficulty without a compensating increase in the 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(z)(2).
Therefore, the NRC staff authorizes the use of the licensee's proposed alternative as described in RR 14R-10, to use ASME Code Case N-513-4 at LSCS, Units 1 and 2, for the fourth 10-year ISi interval. If the proposed alternative is applied to a flaw near the end of the authorized 10-year ISi interval, and the next refueling outage is in the subsequent interval, the licensee is
authorized to continue to apply the proposed alternative to the flaw until the next refueling outage.
All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested and authorized by NRC staff remain applicable, including a third-party review by the Authorized Nuclear In-service Inspector. The NRC staff notes that approval of this alternative does not imply or infer NRC approval of ASME Code Case N-513-4.
Please contact the Project Manager, Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions.
Docket Nos. 50-373 and 50-37 4
Enclosure:
As stated cc w/encl.: Distribution via Listserv Sincerely, (J _
_y 9 CJ/'--
David J. Wrona, Chief Plant Licensing Branch 111 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST 14R-10 PROPOSED ALTERNATIVE TO UTILIZE ASME CODE CASE N-513-4 OPERATING LICENSE NOS. NPF-21 AND NPF-18 LASALLE COUNTY STATION. UNITS 1 AND 2 EXELON GENERATION COMPANY. LLC DOCKET NOS. 50-373 AND 50-374 CAC NOS. MF9708 AND MF9709
1.0 INTRODUCTION
By letter dated May 17, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17137A351), Exelon Generation Company, LLC (Exelon the licensee}, submitted a request in accordance with paragraph 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to the requirements of Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for LaSalle County Station, Units 1 and 2 (LSCS). The proposed alternative, relief request (RR) 14R-10, would allow the licensee to use ASME Code Case N-513-4, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping Section XI, Division 1,"
for the evaluation and temporary acceptance of flaws in moderate energy Class 2 and 3 piping in lieu of specified ASME Code requirements for the fourth 10-year inservice inspection (ISi)
Interval which would begin on October 1, 2017, and end on September 30, 2027.
Specifically, pursuant to 1 O CFR 50.55a(z)(2), the licensee requested to use the alternative on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY EVALUATION
The licensee's request proposes an alternative to the requirement of ASME Code,Section XI, Articles IWC-3000 and IWD-3000.
Adherence to Section XI of the ASME Code is mandated by 10 CFR 50.55a(g)(4), which states, in part, that ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI.
Enclosure The regulation in 10 CFR 50.55a(z) states, in part, 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 that: (1) the proposed alternative provides 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 U.S. Nuclear Regulatory Commission (NRC) staff finds that regulatory authority exists for the licensee to request the use of an alternative and the NRC to authorize the proposed alternative.
3.0 TECHNICAL EVALUATION
3.1.1 ASME Code Component(s) Affected The affected components are ASME Code Class 2 and 3 moderate energy piping systems, as described in Code Case N-513-4, Section 1 "Scope," whose maximum operating temperature does not exceed 200 degrees Fahrenheit (°F) and whose operating pressure does not exceed 275 pounds per square inch gauge (psig).
3.1.2
Applicable Code Edition and Addenda
The Code of Record for the fourth 10-year ISi interval at LSCS is the ASME Code,Section XI, 2007 Edition, through the 2008 Addenda. The fourth 10-year ISi at LSCS is scheduled to begin on October 1, 2017, and end on September 30, 2027.
3.1.3
Applicable Code Requirement
ASME Code,Section XI, IWC-3120 and IWC-3130, require that flaws exceeding the defined acceptance criteria be corrected by repair/replacement activities or evaluated and accepted by analytical evaluation. ASME Code,Section XI, IWD-3120(b), requires that components exceeding the acceptance standards of IWD-3400 be subject to supplemental examination, or to a repair/replacement activity.
3.1.4
Reason for Request
The licensee stated that ASME Code Case N-513-3 currently approved for use in RG 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 17,"
August 2014, contains limitations regarding the evaluation of flaws in certain locations of moderate energy piping components. Many of these limitations have been addressed in Code Case N-513-4. Moderately degraded piping could require a plant shutdown within the required action statement timeframes to repair observed degradation. The licensee stated that plant shutdown activities result in additional dose and plant risk that would be inappropriate when a degraded condition is demonstrated to retain adequate margin to complete the component's function.
3.1.5
Licensee's Proposed Alternative and Basis for Use
The licensee's proposed alternative is to use ASME Code Case N-513-4 for the evaluation and temporary acceptance of flaws in moderate energy Class 2 and 3 piping in lieu of specified ASME Code,Section XI, requirements. In addition, the licensee's proposed alternative includes the determination of an allowable leakage rate by dividing the critical leakage rate by a safety factor of four.
The licensee stated that limitations in Code Case N-513-3, related to its use on piping components such as elbows, bent pipe, reducers, expanders, and branch tees and external tubing or piping attached to heat exchangers, have been addressed in Code Case N-513-4.
The licensee provided a high level overview of the differences between Code Case N-513-3 and Code Case N-513-4 as listed below:
- 1. Revised the maximum allowable time of use from no longer than 26 months to the next refueling outage.
- 2. Added applicability to piping elbows, bent pipe, reducers, expanders, and branch tees where the flaw is located more than (Rot) 112 [where Ro is the outside pipe radius and t is the evaluation wall thickness] from the centerline of the attaching circumferential piping weld.
- 3. Expanded use to external tubing or piping attached to heat exchangers.
- 4. Revised to limit the use to liquid systems.
- 5. Revised to clarify treatment of Service Level load combinations.
- 6. Revised to address treatment of flaws in austenitic pipe flux welds.
- 7. Revised to require minimum wall thickness acceptance criteria to consider longitudinal stress in addition to hoop stress.
- 8. Other minor editorial changes to improve the clarity of the Code Case.
The licensee previously submitted an alternative to use Code Case N-513-4 during the third 10-year ISi interval at LSCS (ADAMS Accession No. ML16029A003) which was approved by the NRC on September 6, 2016 (ADAMS Accession No. ML16230A237). The third 10-year ISi interval at LSCS is scheduled to end September 30, 2017. The licensee referenced the supporting information in its previous alternative request as being applicable to its current proposed alternative. The previously submitted supporting information includes a technical basis document for the fourth revision to N-513, "Proceedings of the ASME 2014 Pressure Vessels & Piping Conference, PVP2014, July 20-24, 2014, Anaheim, California, USA, PVP2014-28355, Technical Basis for Proposed Fourth Revision to ASME Code Case N-513."
The licensee stated that the effects of leakage may impact the operability determination or the plant flooding analyses specified in paragraph 1 (f) of Code Case N-513-4. For a leaking flaw, the licensee stated that the allowable leakage rate will be determined by dividing the critical leakage rate by a safety factor of four. The critical leakage rate is determined as the limiting leakage rate that can be tolerated and may be based on the allowable loss of inventory or the maximum leakage that can be tolerated relative to room flooding, among others. The licensee contends that applying a safety factor of four to the critical leakage rate provides quantitative measurable limits which ensure the operability of the system and early identification of issues that could erode defense-in-depth and lead to adverse consequences.
The licensee stated that Code Case N-513-4 utilizes technical evaluation approaches that are based on principles that are accepted in other code documents already acceptable to the NRC.
The licensee also stated that application of this code case, in concert with safety factors on leakage limits, will maintain acceptable structural and leakage integrity while minimizing plant risk and personnel exposure by minimizing the number of plant transients that could be incurred if degradation is required to be repaired based on ASME Code,Section XI, acceptance criteria only.
3.1.6 Hardship Justification As stated by the licensee, moderately degraded piping could require a plant shutdown within the required action statement timeframes to repair observed degradation. Plant shutdown activities result in additional dose and plant risk that would be inappropriate when a degraded condition is demonstrated to retain adequate margin to complete the component's function. The licensee contends that use of an acceptable alternative analysis method in lieu of immediate action for a degraded condition will allow it to perform additional extent of condition examinations on the affected systems while allowing time for safe and orderly long term repair actions if necessary.
Actions to remove degraded piping from service could have a detrimental overall risk impact by requiring a plant shutdown, thus requiring use of a system that is in standby during normal operation. The licensee believes that compliance with the current code requirements results in a hardship without a compensating increase in the level of quality and safety.
3.1. 7 Duration of Proposed Alternative The licensee stated that the duration of the proposed alternative is the fourth 10-year ISi interval which is scheduled to begin on October 1, 2017 and end on September 30, 2027, or such time as the NRC approves Code Case N-513-4 in RG 1.147 or other document. The licensee stated that if a flaw is evaluated near the end of the interval, and the next refueling outage is in the subsequent interval, the flaw may remain in service until the next refueling outage.
3.2 NRC Staff's Evaluation The NRC staff evaluated the adequacy of the proposed alternative in maintaining the structural integrity of piping components identified in Code Case N-513-4. Code Case N-513-3, which is conditionally approved for use in RG 1.147, provides alternative evaluation criteria for temporary acceptance of flaws, including through-wall flaws, in moderate energy Class 2 and 3 piping.
However, Code Case N-513-3 contains limitations that the licensee considers restrictive and could result in an unnecessary plant shutdown. Code Case N-513-3 is limited to straight pipe with provisions for flaws that extend for a short distance, at the pipe to fitting weld, into the fitting. Evaluation criteria for flaws in elbows, bent pipe, reducers, expanders, branch tees and heat exchangers are not included within the scope of N-513-3. Code Case N-513-4 addresses these aforementioned limitations. Given that the previous revision of this code case (Code Case N-513-3) is conditionally approved for use in RG 1. 14 7, Revision 17, the staff focused its review on the differences between Code Cases N-513-3 and N-513-4. The significant changes in N-513-4 include: (1) revised temporary acceptance period, (2) added flaw evaluation criteria for elbows, bent pipe, reducers/expanders and branch tees, (3) expanded applicability to heat exchanger tubing or piping, (4) limited use to liquid systems, (5) clarified treatment of service load combinations, (6) revised treatment of flaws in austenitic pipe flux welds, (7) revised minimum wall thickness acceptance criteria to consider longitudinal stress in addition to hoop stress, and (8) revised leakage monitoring requirements. The NRC staff also evaluated the licensee's proposed limitation on the leakage rate and its hardship justification.
The NRC staff notes that many requirements specified in Code Case N-513-4 are not discussed in this safety evaluation (SE), but they should not be considered as less important. As part of the NRG-approved proposed alternative, all requirements in the code case must be followed.
Any exceptions or restrictions to the code case that are approved in this SE also need to be followed.
3.2.1 Temporary Acceptance Period Code Case N-513-3 specifies a temporary acceptance period of a maximum of 26 months.
Code Case N-513-3 is accepted for use in RG 1.14 7, Revision 17, with the following condition, "The repair or replacement activity temporarily deferred under the provisions of this Code Case shall be performed during the next scheduled outage." Code Case N-513-4 includes wording that limits the use of the code case to the next refueling outage. The NRC staff finds that Code Case N-513-4 appropriately addresses the NRC condition on Code Case N-513-3, and, is therefore, acceptable.
3.2.2 Flaw Evaluation Criteria for Elbows, Bent Pipe, Reducers/Expanders and Branch Tees.
Evaluation and acceptance criteria have been added to Code Case N-513-4 for flaws in elbows, bent pipe, reducers, expanders, and branch tees using a simplified approach which is based on the Second International Piping Integrity Research Group (IPIRG-2) program reported in NUREG/CR-6444 BMl-2192, "Fracture Behavior of Circumferentially Surface-cracked Elbows,"
March 1996.
The flaw evaluation methodology approach in Code Case N-513-4 for piping components is conducted as if in straight pipe by scaling hoop and axial stresses using ASME Code piping design code stress indices and stress intensification factors to account for the stress variations caused by the geometric differences. Equations used in the code case are consistent with the piping design by rule approach in ASME Code, Section Ill, NC/ND-3600. NUREG/CR-6444 shows that this approach is conservative for calculating stresses used in flaw evaluations in piping elbows and bent pipe. The code case also applies this methodology to reducers, expanders, and branch tees.
The NRC staff finds that the flaw evaluation and acceptance criteria in Code Case N-513-4 for elbows, bent pipe, reducers, expanders, and branch tees is acceptable because the flaw evaluation methods in the code case are consistent with ASME Code,Section XI, ASME Code Section 111, design by rule approach and provides a conservative approach as confirmed by comparing the failure moments predicted using this approach to the measured failure moments from the elbow tests for through-wall circumferential flaws conducted as part of the IPIRG-2 program.
3.2.3 Flaw Evaluation in Heat Exchanger Tubing or Piping Code Case N-513-4 has been revised to include heat exchanger external tubing or piping provided that the flaw is characterized in accordance with Section 2(a) of the code case and leakage is monitored. Section 2(a) requires that the flaw geometry be characterized by volumetric inspection or physical measurement.
The NRC staff determined that the flaw evaluation criteria in Code Case N-513-4 for straight or bent piping, as appropriate, can be applied to heat exchanger external tubing or piping. The staff determined the methods for evaluating flaws in straight pipe are acceptable since they are currently allowed in Code Case N-513-3. For bent pipe, the acceptability is described in Section 3.2.2 above. Therefore, the NRC staff finds inclusion of heat exchanger external tubing or piping in the code case to be acceptable because only heat exchanger tubing flaws that are accessible for characterization and leakage monitoring may be evaluated in accordance with the code case and the code case provides acceptable methods for the evaluation flaws.
3.2.4 Limit Use to Liquid Systems Use of Code Case N-513-4 is specifically limited to liquid systems. The NRC staff finds this change acceptable since Code Case N-513 is not intended to apply to air or other compressible fluid systems.
3.2.5 Treatment of Service Load Combinations Modifications in N-513-4 now make clear that all service load combinations must be considered in flaw evaluations to determine the most limiting condition, although previously implied in Code Cases N-513-3 (N-513-4 makes this requirement clear). Therefore, the NRC staff finds this change acceptable.
3.2.6 Treatment of flaws in austenitic pipe flux welds Paragraph 3.1 (b) of N-513-4 contains modifications which include a reference to ASME Code Section XI, Appendix C, C-6320, to address flaws in austenitic stainless steel pipe flux welds.
Flaws in stainless steel pipe flux welds require the use of elastic plastic fracture mechanics criteria in lieu of limit load criteria. Equation 1 of the code case was also revised to be consistent with ASME Code,Section XI, Appendix C, C-6320, so the equation can be used for flaws in austenitic stainless steel pipe flux welds. The NRC staff finds this acceptable because the modification to the code case now includes the appropriate methods for the evaluation of stainless steel pipe flux welds in accordance with ASME Code,Section XI.
3.2.7 Minimum Wall Thickness Acceptance Criteria to Consider Longitudinal Stress Although it is unlikely that a longitudinal stress based minimum wall thickness would be limiting when compared to a hoop stress based minimum wall thickness, Code Case N-513-4 includes revisions that require consideration of longitudinal stress in the calculation of minimum wall thickness. Previous versions of the code case only required the use of hoop stress. The NRC staff finds this acceptable because it will ensure that the more limiting of the longitudinal or hoop stress is used to determine minimum wall thickness.
3.2.8 Leakage Monitoring for Through-Wall Flaws Code Case N-513-3 required through-wall leakage to be observed by daily walkdowns to confirm the analysis conditions used in the evaluation remain valid. Code Case N-513-4 modifies this requirement by continuing to require that leakage be monitored daily but now allows other techniques to be used to monitor leakage such as using visual equipment or leakage detection systems to determine if leakage rates are changing. The NRC staff finds this change acceptable because the code case continues to require through-wall leaks to be monitored daily and the expanded allowable monitoring methods should have no adverse impact.
3.2.9 Leakage Rate Code Case N-513-3, paragraph 1 (d), states, "The provisions of this Case demonstrate the integrity of the item and not the consequences of leakage. It is the responsibility of the Owner to demonstrate system operability considering effects of leakage." Code Case N-513-4 modified the last sentence, now located in paragraph (f), to state, "It is the responsibility of the Owner to consider effects of leakage in demonstrating system operability and performing plant flooding analyses."
The licensee stated that the allowable leakage rate will be determined by dividing the critical leakage rate by a safety factor of four. The critical leakage rate is determined as the limiting leakage rate that can be tolerated and may be based on the allowable loss of inventory or the maximum leakage that can be tolerated relative to room flooding, among others. The licensee contends that applying a safety factor of four to the critical leakage rate, provides quantitative measurable limits which ensure the operability of the system and early identification of issues that could erode defense-in-depth and lead to adverse consequences.
Code Cases N-513-3 and N-513-4 do not contain leakage limits for components with through-wall flaws. The NRC staff finds that the licensee's approach of applying a safety factor of four to the critical leakage rate is acceptable because it will provide sufficient time for corrective measures to be taken before significant increases in leakage erodes defense-in-depth which could lead to adverse consequences.
3.2.10 Hardship Justification The NRC staff finds that performing a plant shutdown to repair the subject piping would cycle the unit and increase the potential of an unnecessary transient resulting in undue hardship.
Additionally, performing certain ASME Code repair during normal operation would challenge the technical specification "Completion Time" and place the plant at higher safety risk than warranted. Therefore, the NRC staff determined that compliance with the specified ASME Code repair requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.3 Summary The NRC staff finds that the proposed alternative will provide reasonable assurance of the structural integrity because: (1) Code Case N-513-4 addresses the NRC condition in RG 1.147 for Revision 3, (2) flaw evaluations in component types added to Revision 4 of the code case are based on acceptable methodologies, and (3) the method for determining the allowable leakage rate is adequate to provide early identification of a significant increase in leakage. In addition, complying with ASME Code,Section XI, requirement would result in in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
4.0 CONCLUSION
As set forth above, the NRC staff determined that the proposed alternative, RR 14R-10, provides reasonable assurance of structural integrity of the subject components and that complying with IWC-3120, IWC-3130, IWD-3120(b), and IWD-3400, oftheASME Code,Section XI, would result in a hardship or unusual difficulty without a compensating increase in the 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(z)(2).
Therefore, the NRC staff authorizes the use of the licensee's proposed alternative as described in Relief Request 14R-10, to use ASME Code Case N-513-4, at LSCS, Units 1 and 2, for the fourth 10-year ISi interval which is scheduled to begin on October 1, 2017, and end on September 30, 2027, or until such time as the NRC approves Code Case N-513-4 for general use through revision of NRC RG 1.14 7 or other document. If the proposed alternative is applied to a flaw near the end of the authorized 10-year ISi interval, and the next refueling outage is in the subsequent interval, the licensee is authorized to continue to apply the proposed alternative to the flaw until the next refueling outage.
All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested and authorized by NRC staff remain applicable, including a third-party review by the Authorized Nuclear In-service Inspector. The NRC staff notes that approval of this alternative does not imply or infer NRC approval of ASME Code Case N-513-4.
Principal Contributor: R Davis, NRR/DE/EPNB Date: July 5, 2017
SUBJECT:
LASALLE COUNTY STATION, UNITS 1 AND 2 - RELIEF FROM REQUIREMENTS OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI, (ASME CODE) REGARDING RELIEF REQUEST 14R-10, PROPOSED ALTERNATIVE TO UTILIZE CODE CASE N-513-4 (CAC NOS. MF9708 AND MF9709) DATED JULY 5, 2017 DISTRIBUTION:
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