ML17222A002

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI

ML17222A002
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	08/10/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML17222A002 (6)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.55a(g)(4)(iv)

August 10, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 N RC Docket Nos. 50-220 and 50-41 O R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI

Reference:

Letter from J. Zimmerman (U.S. Nuclear Regulatory Commission) to M. Pacilio (Exelon Generation Company, LLC), Request to Use a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, 11 Section XI, Rules for lnservice Inspection of Nuclear Power Plant Components 11 (TAC Nos. ME7286, ME7287, ME7288, ME7289, ME7290, ME7291, ME7292, ME7293, ME7294, ME7295, ME7296, ME7297, ME7298, ME7299, ME7300, ME7301, ME7302), dated March 29, 2012(ML120820266) 11 In accordance with 10 CFR 50.55a, Codes and standards, 11 paragraph (g)(4)(iv), Exelon Generation Company, LLC (Exelon) is requesting NRC approval to use a portion of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components." Specifically, Exelon proposes to implement Mandatory Appendix I, 1-2600, 11 Appendix VIII Examination, 11 from the 2007 Edition through the 2008 Addenda of the ASME B&PV Code. Implementation of Mandatory Appendix I, 1-2600 from the 2007 Edition through 2008 Addenda will permit the use of Appendix VIII Performance Demonstration Initiative (POI) techniques to be used for components to which Appendix VIII is not applicable. The approval of the 2007 Edition through the 2008 Addenda of the ASME B&PV Code for use was first announced in the Federal Register on June 21, 2011 (i.e., 76 FR 36232).

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI August 10, 2017 Page 2 This request was previously approved for the Exelon fleet in the Referenced letter. Revisions to the original submittal are identified with revision bars.

There are no regulatory commitments contained in this letter. Exelon requests your review and approval of this multiple site request by February 1, 2018.

If you have any questions, please contact Tom Loomis (610) 765-5510.

Respectfully, 4,;1-r L Jr-: ~

James Barstow {)

Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv) cc: Regional Administrator - NRC Region I N RC Senior Resident Inspector - Calvert Cliffs NRC Senior Resident Inspector - Nine Mile Point NRC Senior Resident Inspector - R. E. Ginna NRC Project Manager - Calvert Cliffs NRC Project Manager - Nine Mile Point NRC Project Manager - R. E. Ginna

Attachment Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI In Accordance with 10 CFR 50.55a(g)(4)(iv)

(Page 1 of 3)

In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv) and the guidance provided in Reference 1, Exelon Generation Company, LLC (Exelon) requests NRC approval to use specific provisions of a later edition and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for the plants identified in Section 2 of this letter. Currently, ASME Section XI, IWA-2232 of the 2004 Edition of Section XI requires that ultrasonic (UT) examinations be conducted in accordance with Mandatory Appendix I. The 2004 Edition of Mandatory Appendix I, I-2000 requires the performance of ultrasonic examinations in accordance with Appendix III, Appendix VIII, or Section V, Article 4, without substitution. In lieu of the 2004 Edition of Mandatory Appendix I, I-2000 Exelon requests the use of Mandatory Appendix I, I-2600 ("Appendix VIII Examination") from the 2007 Edition through the 2008 Addenda of the ASME B&PV Code,Section XI. This provision states:

a) For components to which Appendix VIII is not applicable, examination procedures, personnel, and equipment qualified in accordance with Appendix VIII may be applied, provided such components, materials, sizes, and shapes are within the scope of the qualified examination procedure.

(b) Examination coverage shall be in accordance with I-3000.

(c) No other I-1000 or I-2000 requirements apply.

Exelon will implement I-2600 from the 2007 Edition through the 2008 Addenda of the ASME B&PV Code. This new provision permits the use of Appendix VIII Performance Demonstration Initiative (PDI) techniques for components to which Appendix VIII is not mandatory.

The 2007 Edition through the 2008 Addenda of the ASME B&PV Code was approved for use in Federal Register 76 FR 36232, dated Tuesday, June 21, 2011, and remains approved in 10 CFR 50.55a(a)(1)(ii)(C)(48) and 10 CFR 50.55a(a)(1)(ii)(C)(49).

Industry experience has demonstrated that use of Appendix VIII techniques for detection and characterization of flaws is equal to or surpasses the requirements of the ASME Code,Section XI, Appendix III or Section V, Article 4.

1. ASME Code Component(s) Affected:

This change may be applied to examinations where the alternative conditions of I-2600 are applicable.

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI In Accordance with 10 CFR 50.55a(g)(4)(iv)

(Page 2 of 3)

2. Applicable Code Edition and Addenda

PLANT INTERVAL EDITION START END Nine Mile Point Nuclear Power August 22, 2019 Fourth 2004 Edition August 23, 2009 Station, Unit 1 Nine Mile Point Nuclear Power Third 2004 Edition April 5, 2008 June 15, 2018 Station, Unit 2 Calvert Cliffs Nuclear Power Plant, Fourth 2004 Edition October 10, 2009 June 30, 2019 Units 1 and 2 R. E. Ginna Nuclear Power Plant Fifth 2004 Edition January 1, 2010 December 31, 2019

3. Proposed Subsequent Code Edition and Addenda (or Portion):

Exelon requests the use of Mandatory Appendix I, I-2600 from the 2007 Edition through the 2008 Addenda of the ASME B&PV Code,Section XI for the remainder of the intervals specified in Section 2.

4. Related Requirements:

10 CFR 50.55a(g)(4)(iv) states:

"Inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (a) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met."

10 CFR 50.55a(b)(2) incorporated by reference Section XI, Division 1, of the ASME B&PV Code, 2007 Edition through the 2008 Addenda as approved in Reference 2. There are no limitations or modifications in 10 CFR 50.55a(b)(2) related to Mandatory Appendix I, I-2600

("Appendix VIII Examination") for the 2007 though 2008 Addenda of Section XI.

In addition, the I-3000 Examination Coverage requirements listed in the ASME 2007 Edition with the 2008 Addenda will be utilized in conjunction with the components examined in accordance with I-2600.

5. Duration of Proposed Request:

This provision will be used for the remainder of the intervals specified in Section 2.

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI In Accordance with 10 CFR 50.55a(g)(4)(iv)

(Page 3 of 3)

6.

References:

1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl," dated July 28, 2004

2. Federal Register 76 FR 36232, dated Tuesday, June 21, 2011

3. Letter from J. Zimmerman (U.S. Nuclear Regulatory Commission) to M. Pacilio (Exelon Generation Company, LLC), Request to Use a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components" (TAC Nos. ME7286, ME7287, ME7288, ME7289, ME7290, ME7291, ME7292, ME7293, ME7294, ME7295, ME7296, ME7297, ME7298, ME7299, ME7300, ME7301, ME7302), date March 29, 2012 (ML120820266)