ML20097G418
| ML20097G418 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/15/1996 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3334, NUDOCS 9602210208 | |
| Download: ML20097G418 (8) | |
Text
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.190l Ondeau Avenue Post Qlhce Box 149 St. Louis. Missouri 63166 314 554 2650 Donald F. SchneII Senior Vice President FsLECTRIC nuscar j$
February 15, 1996 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Mail Station P1-137 Washington, DC 20555-0001 ULNRC-03334 Gentlemen:
DOCKET NUMBER 50-483 CALLAMAY PLANT ASME CODE CASE N-532 I
ASME Section XI Code Case N-532 is titled:
" Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000".
This Code Case (Attachment 1) was approved by
'the American Society of Mechanical Engineers on December 12, 1994.
Code Case N-532 provides an alternative, simplified documentation method for ASME Section XI repairs and replacements.
N-532 also provides an alternative, simplified reporting method for Inservice Inspection examination results.
The alternatives provided by N-532 constitute significant reductions in the administrative burden associated with ASME Section XI repair and inspection activities.
Concurrently, these alternatives increase the usability of reported data by excluding items of negligible plant safety significance.
j One point of clarification is necessary regarding the term " corrective measures" as used in Code Case N-532.
N-532 paragraph 2. 0 (c) states that an
" Owners Activity Report Form OAR-1" shall contain an
" abstract for repairs, replacements and corrective measures performed, which were required due to an item containing a flaw or relevant condition that exceeded (ASME Section XI) acceptance criteria....".
ASME Section XI uses the term " corrective measures" in two different ways.
In its first usage, " corrective measures" refers to ASME-Section XI repair and replacement activities; 41009R I
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I U.S'. Nuclcar R0gulatory Commiccion ULNRC-03334 Page 2 1.e.,
activities on pressure-retaining items which involve metal removal, welding, brazing, or replacement.
In its second usage, " corrective measures" refers to maintenance-type activities not involving Section XI repair or replacement (Ref. IWX-3000).
Examples of maintenance-type corrective measures include but are not limited to tightening bolts, replacing gaskets / packing, cleaning up surface corrosion products and adjusting / realigning component supports.
While maintenance-type corrective measures often serve to bring an item into compliance with ASME Code acceptance criteria, the corrective measures themselves are not ASME Section XI repair or replacement activities.
Maintenance-type corrective measures are not currently reported on ASME Section XI summary reports and are of negligible safety significance.
Union Electric Company considers the term " corrective measures" as used in N-532 to invoke reporting requirements consistent with those currently imposed by ASME Section XI.
Maintenance-type corrective measures will, therefore, be excluded from the OAR-1 Form required by N-532.
NRC Policy Issue letter SECY-94-093 (dated May 10, 1995) documents NRC endorsement of the philosophy embodied in Code Case N-532.
Page 6 of SECY-94-093 states:
"Since the ASME Code is endorsed by NRC regulations (see 10 CFR 50.55a), the NRC will take a proactive role through its representa-tives on the ASME Code Committee to modify code reporting requirements to reduce licensee burden; in particular, the NRC will propose to eliminate the need to submit inservice inspec-tion (ISI) reports to the NRC following each refueling outage (ASME Code Section XI, Article IWA-6000)."
Union Electric Company has been involved in the development and approval of Code Case N-532 through participation in the ASME Code Committee process.
The cost effective alternatives provided by the Code Case gre considered to be reasonable, safe alternatives to curr-T Code requirements.
Cost savings resulting from implementation of this Code Case are estimated at $20,000 per refueling cycle, therefore, this request is considered to be a Cost Beneficial Licensing Action.
l U.S'. Nuclear Rtgulatory Commiccion ULNRC-03334 Page 3 This-request for approval to use Code Case N-532 is submitted in accordance with 10CFR50.55 (a) footnote 6, which states that:
"The use of other Code Cases may be authorized by the Director of the Office of Nuclear
~
-Reactor Regulation upon request pursuant to 10CFR50. 55 (a) (3). "
Pursuant to this requirement, it is requested that the NRC approve ASME Code Case N-532 for use at the Callaway Nuclear Plant.
Approval with the aforementioned clarification of the term " corrective measures", is requested by July 1, 1996 to support the refueling outage scheduled to begin in October 1996.
3 Very truly yours,
//
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Y
pf/
Donald F.
Schnell CDN/sid Attachment l
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cc:
T. A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.
Washington, D.C.
20037-M. H. Fletcher Professional Nuclear Consulting, Inc.
l
'19041 Raines Drive Derwood, MD 20855-2432 l
L. Joe Callan Regional Administrator i
U.S. Nuclear Regulatory Commission Region'IV 611 Ryan Plaza Drive-Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S.
Regulatory Commission RR#1 Steedman, MO 65077 Kristine M. Thomas (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 1
11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 a
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CASE N-532 CASES OF ASME BOILER AND PRESStlRE VESSEL CODE 4
i Approval Date: December 12,1994 a
I See Numeric Index for expiration and any rooffirrnation dates.
Case N 532.
(c) The completed Form NIS-2A shall be main.
Alternative Requirements to Repair and tained by the Owner.
. Replacement Documentation Requirements and (f) The Owner shall maintain an index of Repair /
Inservice Summary Report Preparation and Replacement Plans in accordance with IWA-6340.
~ Submission as Required by IWA 4000 and IWA-The index shall identify the identification number 60008 required by (b) above and the inspection interval and Section XI, Division 1 period during which each repair or replacement was completed.
Inquiry: What alternatives may be used to the re-2.0 OWNER'S ACTISTIY REPORT quirements of IWA-4910(d) and IWA 6210(e) for PREPARATION AND SUBMITTAL completion of Form NIS-2 following repair or re-placement, and tWA 6210(c) and (d), IWA-6220, An OWNER'S ACTIVITY REPORT FORM IWA-6230(b), (c), and (d), and IWA-6240(b) for OAR 1 shall be prepared and certified upon com-preparation and submittal of the inservice summary pletion of each refueling outage. Each Form OAR-report and Form NIS 17 1 prepared during-an inspection period shall be sub-mitted following the end of the inspection period.
]
Reply: It is the opinion c the Committee that as Each Form OAR 1 shall contain the following:
an alternative to the requirements of IWA 4910(d),
(a) Abstract of applicable examinations and tests IWA-6210(c), (d), and (c), IWA 6220, IWA-6230(b),
with the information and format of Table 1.
(c), and (d), and IWA 6240(b), the following provi-(b) A listing of item (s) with flaws or relevant con-sions may be used. This Case shall be utilized at least ditions that required evaluation to determine ac-until the end of the inspection petiod in which it was ceptability for continued senice, whether or not the invoked.
flaw or relevant condition was discovered during a scheduled examination or test. The listing shall pro-1.0 CERTIFICATION OF THE REPAIR OR vide the information in the format of Table 2.
REPLACEMENT (c) Abstract for repairs, replacements and correc.
(a) The Owner's Repair / Replacement Program tive measures performed, which were required due shall identify use of this Case.
to an item conuning a flaw or relevant condition 1
(b) A Repair / Replacement Plan shall be prepared that exceeded IWB 3000, IWC 3000, (WD-3000, in accordance with IWA-4140', and shall be given a IWE-3000, IWF-3000, or IWL-3000 acceptance cri-unique identification number, teria; even though the discovery of the flaw or rete-
)
(c) Upon completion of all required activities as-vant condition that necessitated the repair, replace-i sociated with the Repair / Replacement Plan, the ment or corrective measure, may not have resulted Owner shall prepare a REPAIR / REPLACEMENT from an examination or test required by this Division.
CERTIFICATION RECORD, FORM NIS-2A.
If acceptance criteria for a particular item is not j
(d) Form NIS 2A shall be presented to the specified in this Division, the provisions of IWA.
inspector for certification.
3100(b) shall be used to dete:Tnine which repairs,
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replacements, and corrective measures are required to be included in the abstract.The abstract shall pro-JAll references to IWA-4000 and !WA 6000 used in this Case refer
. to the 1992 Edition.
vide the information in the format of Table 3.
1061 1
CASE fcontinued)
N-532 CASES OF ASME BOILER AND PRESSURE VESSEL CODE FORM NIS 2A REPAIR / REPLACEMENT CERTIFICATION RECORD OWNER'S CERTIFICATE OF CONFORMANCE I certify that the represent by Repair / Replacement repen or reoiscement Plan number conforms to the requirements of Section xt.
Type Code Symbol Stamp Certifieste of Authorization No.
Empiration Date Date Signed Caner or Owners Des.gnee. Title CERTIFICATE OF INSERVICE INSPECTION
- 1. the undersigned, holding a valid commission issued by the National Board of Beeler and Pressure VesselInspectors and of the State or Province of and employed by have inspected tne items described,in Repair /Reptacement Plan number during the pened to and state that I
to the best of my knowledge and belief the Owner has performed att the activities described in the Repair / Replacement Plan in accordance with the recuirements of Section XI.
By signing this certrficate neither the inspector nor his employer makes any warranty, empressed or implied. concerning the activities described in the RepairiReplacement Pf an. Furthermore, neither the insoector nor his empiover shall be liaDie in i
any manner for any personai injury or property demage or loss of any kind arising from or connected with this inspection.
i Commissions Nationsi Boa <d 4 eeocace, and Endorsements f
lespector's Stenstwo Date This form (E00126) reay be octained from the Order Dept ASME. 22 Law Onve, Box 2300. Fairfield. NJ 07007 2300.
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CASE (continued)
N-532 CASES OF ASME 80lLER AND PRESStlRE VESSEL CODE i
FORM OAR 1 OWNER'S ACTIVITY REPORT Meport Number Owner tsieme eng age.ees er owner Plant theme one Adeses of P' eat unet No.
Comenorcist service care Refweimg outa9e no.
is etensacies a
Current iespection intervas Ost. tae. See am. aimer, Current sespection seriod Oss 2ae 3rei Edition and Addenda of Section 31 appiscab*e to the mapection plan Date sad revis.on of inspection pien Edition and Addeaos of Section xi aposicense to repairs and replacements. sf different teen the irsspection peeri CERTIFICATE OF CONFORMANCE i
1 certrfy that the statereents inade in this owner s Activity Aeport are correct. and that the esammations. tests. repaws.
l repiscaments. eveuanons ano correa ve measures represented ev this report conform to the reavicemerits of section xi.
Esowetion Dere Ceri ficate of Autnerisation No.
le sothseeies esie s or,ed Owner er Owaee s Designee tee CERTIFICATE OF INSERVICE INSPECTION I, tne u dersigned. holdmg a valid commession issued Dy the Nationai Soord of Boiler sac Pressure Vesse' laspectors and n
of tes State of P*ovmco of and empioved by have inspected the Nerns to and state that descnbed in this Owner's activity Aeport. dormg the per od s eport in accordance with the to the best of my snowsedge and beleef. tP.e Owner has performed ail scirvities represented t.
requirements of $4ction XL 0 Cafe aetther the lespector nor h+s emplover meses any we'ranty eG'essed of emptied. Concerneg the Sy signeeg this cert taaminatices. tests, repaire repiacements, evaluatter's and Corrective measgres described en s report. Pwrtherrnare. neither the iespector not his empiower snaii De liaDie in 46V manner for any personal infury or property oamage or a loss of eMV kind arising kom of connected *ita te s sospectson 1
l commiss or's heioam to** Sere hevw=e. ene taeorumeries
.seeoor e s.eamure Date This form 1E001271may De cotamed from the Oroer Dept. ASME. 22 Law Orive, Boe 2300. Fairf'oid. NJ 07007 2300-1 1063
CASF (continued)
N-532 CASES OF ASME BOILER AND PRESSt'RE VESSEL CODE TABLE 1 ABSTRACT OF EXAMINATIONS AND TESTS Total Total Total Total Examinations Examinations Examinatloa?
Examinations Credited (%) To Examination Required for Credited for Credited (%)
Date for The Category The Interval This Period For The Period Interval Remarks TABLE 2 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRED EVALUATION FOR CONTINUED SERVICE Flaw Flaw or Relevant Condition Found Examination item item Characterization During Scheduled Section XI Category Number Description
(!WA 3300)
Examination or Test (Yes or No)
TABLE 3 ABSTRACT OF REPA!RS, REPLACEMENTS, OR CORRECTIVE MEASURES REQUIRED FOR CONTINUED SERVICE Flaw or Relevant Condition Found
- Repair, During Scheduied Replacement,Section XI Repair /
Code or Corrective item Description Examination or Date Replacement Class Measure Description of Work Test (Yes/No)
Complete Plan Number i
1064