NMP1L3215, Relief Requests Associated with Fifth and Fourth Ten-Year Inservice Testing Intervals - Supplement 1
| ML18100A299 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/10/2018 |
| From: | David Gudger Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMP1L3215 | |
| Download: ML18100A299 (4) | |
Text
Exelon Generation NMP1L3215 April 10, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Units 1 and 2 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.55a Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRG Docket Nos. 50-220 and 50-41 O
Subject:
Relief Requests Associated with Fifth and Fourth Ten-Year lnservice Testing Intervals - Supplement 1
Reference:
Letter from D. P. Helker (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Relief Requests Associated with Fifth and Fourth Ten-Year lnservice Testing Intervals," dated December 20, 2017 (ADAMS Accession No. ML17354A837)
In the Referenced letter, Exelon Generation Company, LLC (Exelon) submitted relief requests for Nine Mile Point Nuclear Station (NMPNS), Units 1 and 2, associated with the fifth and fourth ten-year lnservice Testing (IST) intervals, respectively. Subsequent to the submittal of the Reference letter, Exelon has determined that an additional relief request is needed. This letter provides a supplement to the referenced submittal to include one additional relief request.
American Society of Mechanical Engineers (ASME) has approved Code Case (CC) OMN-13, Performance-Based Requirements for Extending Snubber lnservice Visual Examination Intervals, Revision 2. This CC is unconditionally approved for use in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 2.
However, CC OMN-13, Revision 2, states in the Applicability section that it is applicable to ASME OM Code 1995 Edition through 2011 Addenda. During the fifth and fourth ten-year
!ST/Snubber intervals, which will begin on January 1, 2019, NMPNS will be implementing the ASME Code OM-2012 Edition and proposes to also implement CC OMN-13, Revision 2, for extending the examination interval for snubbers. Since the use of CC OMN-13 is not yet approved for use with the ASME OM Code, 2012 Edition, a relief request is being submitted to allow authorization to use CC OMN-13, Revision 2 at NMPNS for the upcoming Unit 1 fifth interval and Unit 2 fourth interval.
The fifth and fourth ten-year intervals for NMPNS, Units 1 and 2, both will begin on January 1, 2019, and are currently scheduled to conclude on December 31, 2028. We request your approval by December 20, 2018.
Submittal of lnservice Testing Relief Requests, Supplement 1 Docket Nos. 50-220 and 50-41 O April 10, 2018 Page 2 There are no regulatory commitments contained within this letter.
If you have any questions concerning this letter, please contact Mr. David Neff at (267) 533-1132.
Sincerely,
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David T. Gudger Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Relief Request SR-1 Associated with the Fifth Ten-Year Interval for Nine Mile Point Nuclear Station, Unit 1 and the Fourth Ten-Year Interval for Nine Mile Point Nuclear Station, Unit 2 cc:
USNRC Region I, Regional Administrator NRC Senior Resident Inspector - NMP NRC Project Manager, NRA - NMP A. L. Peterson, NYSERDA
EXELON GENERATION COMPANY, LLC SNUBBER PROGRAM - RELIEF REQUEST Nine Mile Point Nuclear Station, Units 1 and 2 Proposed Alternative in Accordance with 1 O CFR 50.55a(z)(1)
SR Snubber Inspection and Testing
- 1.
ASME Code Component(s) Affected All snubbers within the scope of the NMPNS Unit 1 and Unit 2 Snubber Program.
- 2.
Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) 2012 Edition with no Addenda.
- 3.
Applicable Code Requirement
ISTA-3130, Application of Code Cases, subparagraph (b), states, "Code Cases shall be applicable to the edition and addenda specified in the test plan."
- 4.
Reason for Request
Pursuant to 1 O CFR 50.55a, Codes and standards, paragraph (z)(1 ), an alternative is proposed to ISTA-3130(b) requirements for implementing Code Case (CC) OMN-13, Performance-Based Requirements for Extending Snubber lnservice Visual Examination Intervals at L WR Power Plants, Revision 2. The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety.
ISTA-3130(b) states, "Code Cases shall be applicable to the edition and addenda specified in the test plan." ASME has approved CC OMN-13, Revision 2. This CC is unconditionally approved for use in Regulatory Guide (AG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 2. The NMPNS code of record for the 5th interval for Unit 1 and the 4th interval for Unit 2 is the ASME OM-2012 Edition. However, CC OMN-13, Revision 2, states in the Applicability section that it is applicable to ASME OM Code 1995 Edition through 2011 Addenda. NMPNS will be implementing the ASME Code OM-2012 Edition and proposes to also implement CC OMN-13, Revision 2, for extending the examination interval for snubbers.
NMPNS has used CC OMN-13, Revision 0, during the previous lnservice Inspection (ISi) ten-year intervals for both Units 1 and 2 and proposes to continue with Revision 2 of this CC for the subsequent Snubber IST ten-year interval. Based on the required update of the ISi program and 1 OCFR50.55a(b)(3)(v), OM Condition: Snubbers ISTD, item (B), requirements for snubbers are moving from Section XI to the OM Code and hence this CC OMN-13 request is associated with the next Snubber IST ten-year interval.
- 5.
Proposed Alternative and Basis for Use The proposed alternative to ISTA-3130(b) is requested to implement this CC since the CC Applicability statement covers only the 1995 Edition through the 2011 Addenda and ISTA-3130(b) requires applicability to the edition specified in the test plan, which will be the ASME OM-2012 Edition. A review of the 2012 Edition of the OM Code and CC OMN-13, Revision 2, confirmed that there are no changes in the applicable Code sections referenced within the CC when comparing the 2011 Addenda to the 2012 Edition.
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EXELON GENERATION COMPANY, LLC SNUBBER PROGRAM - RELIEF REQUEST Nine Mile Point Nuclear Station, Units 1 and 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
SR Snubber Inspection and Testing RG 1.192, Revision 2, Table 1, Acceptable OM Code Cases, lists CC OMN-13, Revision 2 (2012 Edition) as acceptable to the NRC for application in a licensee's IST program without conditions.
Using the provisions of this request as an alternative to the requirements of ISTA-3130(b) will provide adequate detection of observable snubber degradation and, along with the testing and service life monitoring requirements of Subsection ISTD, will continue to provide reasonable assurance of the operational readiness of NMPNS snubbers. Therefore, the proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(z)(1 ).
- 6.
Duration of Proposed Alternative The proposed alternative, upon approval, shall be utilized during the 5th 10-year interval for Unit 1 and the 4th 10-year interval for Unit 2, which begin January 1, 2019, and are currently scheduled to end on December 31, 2028.
- 7.
Precedent None.
- 8.
References
- 1. Code Case OMN-13, Performance-Based Requirements for Extending Snubber Jnservice Visual Examination Intervals, Revision 2.
- 2. RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 2, dated March 2017; published January 2018 (ML16321A337).
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