ML20281A472
| ML20281A472 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/04/2020 |
| From: | Jennifer Dixon-Herrity Plant Licensing Branch IV |
| To: | Peters K Vistra Operations Company |
| Galvin D | |
| References | |
| EPID L-2020-LLR-0106 | |
| Download: ML20281A472 (8) | |
Text
November 4, 2020 Mr. Ken J. Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC Comanche Peak Nuclear Power Plant 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS NOS. 1 AND 2 -
REQUEST TO USE A PROVISION OF LATER CODE EDITION TO THE REQUIREMENTS OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE FOR OPERATION AND MAINTENANCE AT NUCLEAR POWER PLANTS (EPID L-2020-LLR-0106)
Dear Mr. Peters:
By letter dated August 6, 2020, as twice superseded by letters dated August 19, 2020, and August 31, 2020, Vistra Operations Company LLC (Vistra OpCo, the licensee), submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of a later code edition to certain American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements at Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (Comanche Peak, Units 1 and 2).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.55a(f)(4)(iv), the licensee requested to use a later code edition for inservice testing (IST) items subject to the conditions specified in 10 CFR 50.55a(b). The licensee requested to use Subsection ISTA, General Requirements, paragraph ISTA-9230, Inservice Test and Examination Results, in the 2017 Edition of the ASME OM Code for the remainder of the applicable intervals for the third 10-year IST program for pumps, valves and snubbers in lieu of paragraph ISTA-9230 in the current ASME OM Code of record.
The NRC staff has reviewed the subject request, as set forth in the enclosed safety evaluation, and finds that Vistra OpCo has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(f)(4)(iv). Therefore, the NRC staff approves the use of Subsection ISTA, paragraph ISTA-9230, of the 2017 Edition of the ASME OM Code at Comanche Peak, Units 1 and 2 for the remainder of the applicable intervals for the third 10-year IST program.
If you have any questions, please contact the Project Manager, Dennis Galvin, at 301-415-6256 or Dennis.Galvin@nrc.gov.
Sincerely, Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
Safety Evaluation cc: Listserv Jennifer L.
Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2020.11.04 10:18:38 -05'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE A PROVISION OF A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE FOR OPERATION AND MAINTENANCE OF NUCLEAR POWER PLANTS FOR THIRD 10-YEAR INSERVICE TESTING PROGRAM INTERVAL VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NO. 50-445 AND 50-446
1.0 INTRODUCTION
By letter dated August 6, 2020, as twice superseded by letters dated August 19, 2020, and August 31, 2020, (Agencywide Documents Access and Management System (ADAMS)
Accession Nos. ML20219A520, ML20232D034, and ML20244A337, respectively), Vistra Operations Company, LLC (the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the use of a portion of a later edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (IST) program at Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (Comanche Peak, Units 1 and 2).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.55(f)(4)(iv), Applicable IST Code: Use of later Code editions and addenda, the licensee requested to use a later code edition for IST items subject to the conditions specified in 10 CFR 50.55a(b), Use and condition on the use of standards. The licensee requested to use Subsection ISTA, General Requirements, paragraph ISTA-9230, Inservice Test and Examination Results, in the 2017 Edition of the ASME OM Code for the remainder of the applicable intervals for the third 10-year IST program for pumps, valves and snubbers in lieu of paragraph ISTA-9230 in the current ASME OM Code of Record.
2.0 PROPOSED USE OF LATER ASME OM CODE EDITION 2.1 Components for Which Use of the Later ASME OM Code Edition is Requested The licensee proposed to use ASME OM Code 2017 Edition, Subsection ISTA, paragraph ISTA-9230, for the remainder of the applicable intervals for the third 10-year IST program for the pumps, valves and snubbers within the scope of the IST program atComanche Peak, Units 1 and 2 in lieu of paragraph ISTA-9230 in the current ASME OM Code of Record.
2.2 Current Code Requirement With respect to this request, the current ASME OM Code requirement applicable to the pumps, valves, and snubbers within the scope of the IST program at Comanche Peak, Units 1 and 2 is Subsection ISTA, paragraph ISTA-9230, in the ASME OM Code, 2004 Edition through the 2006 Addenda.
The following is a detailed comparison of the ISTA-9230 requirements in the ASME OM Code, 2004 Edition through 2006 Addenda, and ASME OM Code, 2017 Edition (differences are highlighted in bold with underlined italics or cross-out markings).
ASME OM Code, 2004 Edition thru 2006 Addenda, ISTA-9230, Inservice Test and Examination Results.
ASME OM Code, 2017 Edition, ISTA-9230, Inservice Test and Examination Results.
The results of tests and examinations shall be documented and shall include the following, as a minimum:
(a) equipment identification (b) date of test or examination (c) reason for test or examination (e.g., post maintenance, routine inservice test or examination, establishing reference values, etc.)
(d) test or examination procedure used (e) identification of test equipment used (f) calibration records (g) values of measured parameters (h) comparison with allowable ranges of test and examination values, and analysis of deviations (i) requirement for corrective action (j) printed (or typed) name and signature of the person(s) responsible for conducting and analyzing the test and examination The results of tests and examinations shall be documented and shall include the following, as a minimum:
(a) component [equipment] identification (b) date of test or examination (c) reason for test or examination (e.g., post maintenance, routine inservice test or examination, establishing reference values, etc.)
(d) test or examination procedure used (e) identification of test equipment used (f) calibration records, or traceability to calibration records (g) values of measured parameters (h) comparison with allowable ranges of test and examination values, and analysis of deviations (i) requirement for corrective action (j) documentation of the person(s) responsible for conducting and analyzing the test or examination per the Owners QA program [printed (or typed) name and signature of the person(s) responsible for conducting and analyzing the test and examination]
2.3 Current Code Edition and Addenda of Record The ASME OM Code of Record for the third 10-year IST program at Comanche Peak, Units 1 and 2 is the 2004 Edition and 2006 Addenda of the ASME OM Code as incorporated by reference in 10 CFR 50.55a.
2.4 Later OM Code Edition (or Specific Sections) Requested for Use The licensee requests the use of Subsection ISTA, paragraph ISTA-9230, in the 2017 Edition of the ASME OM Code as incorporated by reference in 10 CFR 50.55a at Comanche Peak, Units 1 and 2.
2.5 Duration of the Use of the Later Code Edition and Addenda The licensee requests the use of Subsection ISTA, paragraph ISTA-9230, of the ASME OM Code, 2017 Edition, as a replacement for paragraph ISTA-9230 in its current Code of Record for the remainder of the intervals for pumps, valves, and snubbers for the third 10-year IST program at Comanche Peak, Unit 1 and 2. The duration of this request as applicable to the pumps, valves, and snubbers within the scope of the IST program at Comanche Peak, Units 1 and 2 is shown in the table below.
Third 10-Year IST Program Intervals ASME OM Code of Record Interval Start (Note 1)
Interval End (Note 1)
Pumps and Valves 2004 Edition and 2006 Addenda August 3, 2013 August 2, 2023 Snubbers 2004 Edition and 2006 addenda April 19, 2012 April 19, 2022 Note 1: The licensee indicated that corrective action has been initiated to align the snubber 10-year interval with the pump and valve 10-year interval in the fourth 10-Year IST program interval update.
3.0 REGULATORY EVALUATION
The regulation in 10 CFR 50.55a(f)(4)(iv) states that:
Inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (a)(1)(iv) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to NRC approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.
Given that 10 CFR 50.55(f)(4)(iv) permits the NRC staff to approve the use of subsequent ASME OM Code editions and addenda that have been incorporated by reference in 10 CFR 50.55a, the NRC staff finds that, subject to the following technical evaluation, a licensee may request the use of a later edition and addenda of the ASME OM Code (or portions thereof) that have been incorporated by reference in 10 CFR 50.55a. Further, the NRC staff has the regulatory authority to approve the use of a later edition and addenda (or portions thereof) of the ASME OM Code where incorporated by reference in 10 CFR 50.55a.
4.0 NRC TECHNICAL EVALUATION As previously stated in Section 3.0 of this safety evaluation, prior to approving the use of a subsequent edition and addenda of the ASME OM Code under 10 CFR 50.55a(f)(4)(iv), the NRC staff must find that (1) the proposed subsequent edition and addenda are incorporated by reference in 10 CFR 50.55a(a); (2) the licensee has identified any conditions listed in 10 CFR 50.55a(b) appropriate to the request and will comply with those conditions; (3) the licensee has requested approval to use the subsequent edition and addenda; and (4) if only portions of the edition or addenda are to be used, all related requirements of the respective edition or addenda are met. If these criteria are met, the NRC staff finds the use of the subsequent edition and addenda of the ASME OM Code to be acceptable.
4.1 Incorporation by Reference In evaluating the first criterion, 10 CFR 50.55a(a) lists the specific editions and addenda of the ASME OM Code incorporated by reference in 10 CFR 50.55a. In its submittal, the licensee requests the use of Subsection ISTA, paragraph ISTA-9230, of the 2017 Edition of the ASME OM Code, which is included in the list of editions and addenda incorporated by reference in 10 CFR 50.55a. Therefore, the NRC finds that the first criterion has been satisfied.
4.2 Subject to Conditions Listed in 10 CFR 50.55a(b)
In evaluating the second criterion, the NRC staff finds that 10 CFR 50.55a(b) contains no conditions relevant to this request. Therefore, the NRC staff finds that the second criterion has been satisfied.
4.3 Requesting Commission Approval In evaluating the third criterion, the licensee's request dated August 31, 2020, constitutes a request to the Commission for approval to use a subsequent edition/addendum of the ASME OM Code. Therefore, the NRC staff finds that the third criterion has been satisfied.
4.4 All Related Requirements In evaluating the fourth criterion, the licensee has identified the requirements in the 2017 Edition of the ASME OM Code related to the specific section of the ASME OM Code edition requested for use. The licensee states that from the 2004 Edition through the 2006 Addenda to the 2017 Edition of the ASME OM Code, there have been no significant changes to the IST program requirements related to Subsection ISTA, paragraph ISTA-9230, for pumps, valves, or snubbers at Comanche Peak, Units 1 and 2. The paragraph ISTA-9230 changes are considered to be enhancements in the inservice test and examination results document requirements. The NRC staff finds that the licensee has demonstrated that the requirements related to the use of Subsection ISTA, paragraph ISTA-9230, of the 2017 Edition of the ASME OM Code will be met. Therefore, the NRC staff finds that the fourth criterion has been satisfied.
4.5 Summary Based on the review above, the NRC staff finds that the licensee has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(f)(4)(iv).
5.0 CONCLUSION
As set forth above, the NRC staff finds that the licensee in its request dated August 31, 2020, has adequately addressed all of the regulatory requirements in 10 CFR 50.55a(f)(4)(iv).
Therefore, the NRC staff concludes that the use of Subsection ISTA, paragraph ISTA-9230, of the 2017 Edition of the ASME OM Code is acceptable for pumps, valves and snubbers. The NRC staff approves the use of Subsection ISTA, paragraph ISTA-9230, of the 2017 Edition of the ASME OM Code at Comanche Units 1 and 2 for the remainder of the applicable intervals for the third 10-year IST program.
Principal Contributor: Gurjendra Bedi Date: November 4, 2020
- via e-mail OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DEX/EMIB/BC*
NAME DGalvin PBlechman ABuford DATE 10/22/2020 10/22/2020 9/30/2020 OFFICE NRR/DORL/LPL4/BC NAME JDixon-Herrity DATE 11/4/2020