ML25338A350
| ML25338A350 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/04/2025 |
| From: | Bayer R Wolf Creek |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 001276 | |
| Download: ML25338A350 (0) | |
Text
P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Robert J. Bayer Vice President Engineering December 4, 2025 001276 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Docket No. 50-482: 10 CFR 50.55a Request to Use a Provision of a Later Edition of ASME OM Code for Motor Operated Valve Testing Commissioners and Staff:
In accordance with 10 CFR 50.55a(f)(4)(iv), Applicable IST Code: Use of later Code editions and addenda, and consistent with the guidance provided in Regulatory Issue Summary (RIS) 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI, (ADAMS Accession No. ML042090436), Wolf Creek Nuclear Operating Corporation (WCNOC) requests U.S. Nuclear Regulatory Commission (NRC) approval to use a provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV),
Operation and Maintenance (OM) Code.
Specifically, WCNOC requests approval to use Appendix III of ASME OM Code, 2022 Edition, which addresses motor operated valve (MOV) testing. The code of record for the upcoming Inservice Testing (IST) interval at the Wolf Creek Generation Station (WCGS) will be the 2020 Edition of the ASME OM Code.
If approved, WCNOC will incorporate Appendix III from the 2022 Edition in its entirety, subject to the limitations and conditions outlined in 10 CFR 50.55a(b)(3)(ii), OM condition: Motor-Operated Valve (MOV) testing.
A formal request is included in the attachment to this letter.
To support incorporating Appendix III from the later 2022 ASME OM Code into the upcoming IST interval, WCNOC requests approval by March 6, 2026.
This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4015 or Dustin Hamman at (620) 364-4204.
Sincerely, Robert J. Bayer RJB/nwl
001276 Page 2 of 2
Attachment:
Proposed Use of Subsequent ASME Code Editions and Addenda In Accordance with 10 CFR 50.55a(f)(4)(iv) cc:
A. N. Agrawal (NRC), w/a S. S. Lee (NRC), w/a J. D. Monninger (NRC), w/a Senior Resident Inspector (NRC), w/a WCNOC Licensing Correspondence ET 25-001276, w/a
Attachment to 001276 Page 1 of 4 Proposed Use of Subsequent ASME Code Editions and Addenda In Accordance with 10 CFR 50.55a(f)(4)(iv)
Attachment to 001276 Page 2 of 4 Proposed Use of Subsequent ASME Code Editions and Addenda In Accordance with 10 CFR 50.55a(f)(4)(iv)
In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (f)(4)(iv) and the guidance provided in Reference 1, Wolf Creek Nuclear Operating Corporation (WCNOC) requests NRC approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) of Nuclear Power Plant Code at the Wolf Creek Generating Station (WCGS).
Specifically, WCNOC requests approval to use Division 1, Mandatory Appendix III, Preservice and Inservice Testing of Active Electric Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants, in its entirety, as presented in the 2022 Edition of the ASME OM Code.
1.
ASME Code Component(s) Affected All Active Electric Motor-Operated Valve Assemblies in the Inservice Testing (IST) Program.
2.
Requested Date for Approval Approval requested by March 6, 2026, to support entry into the WCGSs Fifth IST Interval.
3. Applicable Code Edition and Addenda
WCNOC requests approval to use Appendix III of ASME OM Code, 2022 Edition, which addresses active motor operated valve (MOV) testing for the duration of the upcoming IST interval.
The code of record for the upcoming Fifth IST Interval at the WCGS will be the 2020 Edition of the ASME OM Code. While WCNOC letter 001174 (Reference 2) informed the NRC that the Fourth IST Interval is being extended to no later than September 3, 2026, WCNOC may opt to begin the Fifth IST Interval prior to September 4, 2026.
- 4. Proposed Subsequent Code Edition and Addenda (or Portion)
WCNOC is in the process of preparing to enter the Fifth Inservice Testing Interval, which per 10 CFR 50.55a(f)(4)(ii) must comply with the requirements of the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv), no more than 18 months before the start of the code of record interval. Eighteen months prior to the original start date of the Fifth Interval, the latest code of record listed in 10 CFR 50.55a(a)(1)(iv) was the 2020 Edition of the ASME OM Code.
Since preparations for the Fifth IST Interval began, 10 CFR 50.55a(a)(1)(iv)(C)(4) has been amended to include by reference the 2022 Edition of the ASME Code. The 2022 Edition of the ASME Code contains a number of revisions to Mandatory Appendix III. Specifically, those revisions made to section III-9200, Documentation of Analysis and Evaluation of Data, are viewed by WCNOC to be an improvement such that a benefit is seen in the adoption of the complete Mandatory Appendix III as presented in the 2022 Edition.
Therefore, to take advantage of these enhancements, pursuant to 10 CFR 50.55a(f)(4)(iv), WCNOC requests permission to utilize ASME OM Code, Mandatory Appendix III from the 2022 Edition in its entirety in lieu of the 2020 Edition.
Attachment to 001276 Page 3 of 4
- 5. Related Requirements 10 CFR 50.55a(f)(4)(iv) states:
"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."
Appendix III from the 2022 Edition removes ambiguity contained in the 2020 version related to independent verification for MOV testing in III-9200 Documentation of Analysis and Evaluation of Data. The terminology independent verification is used in a different manner in the nuclear industry within plant operating procedures compared to the context intended by the OM Code.
The 2022 Edition of III-9200 removed the ambiguous terminology and states more clearly:
Test analysis per III-6200 and evaluations per III-6300 shall be verified by individuals qualified through the Owners qualification requirements. Those analyses and evaluations shall include signatures with dates.
If approved, WCNOC will incorporate Appendix III from the 2022 Edition in its entirety, subject to the limitations and conditions outlined in 10 CFR 50.55a(b)(3)(ii), OM condition: Motor-Operated Valve (MOV) testing. As noted in the Federal Register (89 FR 70449) August 30, 2024 Final Rule with a September 30, 2024 effective date, the NRC modified §50.55a(b)(3)(ii) by removing conditions (A), (B), and (C) where licensees are implementing the 2022 Edition of the ASME OM Code as incorporated by reference in §50.55a, because Appendix III, Preservice and Inservice Testing of Active Electric MOV Assemblies in Water-Cooled Reactor Nuclear Power Plants, to the 2022 Edition of the ASME OM Code appropriately incorporates the requirements specified in those conditions.
Since WCNOC will incorporate the 2022 Edition of Appendix III in its entirety, use of the newer edition will not result in a reduction in requirements.
- 6. Duration of Proposed Request The duration of this request will be utilized for the entire Fifth IST Interval. Upon approval, WCNOC will incorporate the proposed request into appropriate IST program procedures.
- 7. Precedents By letter dated August 6, 2020 (ML20219A520), as twice superseded by letters dated August 19, 2020 (ML20232D034), and August 31, 2020 (ML20244A337), Vistra Operations Company LLC, submitted a request to the NRC for the use of a later code edition to certain ASME OM Code requirements at Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2. An NRC safety evaluation report approving this request was published on November 4, 2020 (ML20281A472).
- 8. References
- 1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004 (ML042090436).
Attachment to 001276 Page 4 of 4
- 2. WCNOC letter 001174, Docket No. 50-482: Notification of Extension to the Fourth Ten-Year Interval of the Inservice Testing Program, dated September 3, 2025 (ML25246C420).