NOC-AE-06002086, Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves

Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves

ML063530358
Person / Time
Site:	South Texas
Issue date:	12/13/2006
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-06002086
Download: ML063530358 (5)

Text

Nuclear Operating Company South Texas Pro/ectElectric GeneratinSStation PO SBx 289 adsworth, Texas 77483 -

December 13, 2006 NOC-AE-06002086 File No.: G25 10CFR50.55a U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves Pursuant to 10 CFR 50.55a(f)(4)(iv), STP Nuclear Operating Company (STPNOC) requests permission to use a Section ISTC-5222 of a later edition of the ASME Code in monitoring check valves at the South Texas Project, Units 1 and 2. ASME OM Code 2001 Edition with 2003 Addenda Appendix II, Check Valve Condition Monitoring Program, describes the condition monitoring approach to be implemented at the South Texas Project following NRC approval. The condition monitoring approach will be applied to all of the check valves presently in the scope of the inservice testing program.

The current code of record for the South Texas Project is the 1987 Edition of the Code for Operation and Maintenance of Nuclear Power Plants through the 1988 Addenda. As an alternative to the testing and examination requirements of section 4.3.2 of the current code of record, STPNOC intends to use the 2001 Edition with 2003 Addenda of the OM Code, Appendix II, which allows the licensee to establish a check valve condition monitoring program. The purpose of this program is both to improve check valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain continued acceptable check valve performance. The attached application provides details justifying approval for use of the 2001 Edition with 2003 Addenda of the OM Code.

STPNOC requests NRC approval by February 14, 2007. The implementation period will extend to December 31, 2008.

Commitments are provided as an attachment.

If there are any questions, please contact either Philip Walker at (361) 972-8392 or me at (361) 972-7867.

'd)W. Rencurrel 7 Vice President, Engineering

& Strategic Projects PLW Attachments: 1) Application to Use ASME OM Code 2001 Edition with 2003 Addenda for Condition Monitoring of Check Valves

2) List of Commitments STI: 32093572 4o"'?

NOC-AE-06002086 Page 2 of 2 cc:

(paper copy)

(electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Richard A. Ratliff Steve Winn Bureau of Radiation Control Christine Jacobs Texas Department of State Health Services Eddy Daniels 1100 West 49th Street Marty Ryan Austin, TX 78756-3189 NRG South Texas LP Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. O. Box 289, Mail Code: MN116 Kevin Polio Wadsworth, TX 77483 City Public Service C. M. Canady C. Kirksey City of Austin City of Austin Electric Utility Department 721 Barton Springs Road Jon C. Wood Austin, TX 78704 Cox Smith Matthews

Attachment NOC-AE-06002086 Page 1 of 2 SOUTH TEXAS PROJECT UNITS 1 & 2 APPLICATION TO USE ASME OM CODE 2001 EDITION WITH 2003 ADDENDA FOR CONDITION MONITORING OF CHECK VALVES

1. ASME CODE COMPONENTS AFFECTED The condition monitoring approach will be applied to the check valves presently in the scope of the inservice testing program.

2. APPLICABLE CODE EDITION AND ADDENDA The current code of record for the South Texas Project is the 1987 Edition of the Code for Operation and Maintenance of Nuclear Power Plants through the 1988 Addenda. Section 4.3.2 identifies check valve testing under the current code of record.

3. PROPOSED SUBSEQUENT CODE EDITION AND ADDENDA Pursuant to 10 CFR 50.55a(f)(4)(iv), STP Nuclear Operating Company (STPNOC) requests permission to use Section ISTC-5222 of the 2001 Edition with 2003 Addenda of the ASME Code in monitoring check valves at the South Texas Project, Unit 1 and 2. ASME OM Code 2001 Edition with 2003 Addenda Appendix II, Check Valve Condition Monitoring Program, describes the condition monitoring approach to be applied. The check valve condition monitoring program of Appendix II is to replace the requirements of sections ISTC-3510, ISTC-3520, ISTC-3540, and ISTC-5221.

4. RELATED REQUIREMENTS There are no other requirements affected by this proposed change.

5. BASIS FOR USING SUBSEQUENT CODE EDITION NUREG-1 482, Revision 1, "Guidelines for Inservice Testing at Nuclear Power Plants," states that the condition monitoring approach identified in Appendix II of the OM Code, with regulatory modifications, is an improvement for check valve testing, and recommends that licensees implement condition monitoring as an alternative to the OM Code. The requirements for a condition monitoring program are identified in an edition of the OM Code later than that currently in effect for the South Texas Project.

The NRC approved use of Appendix II condition monitoring program requirements provided in the 1995 Edition with 1996 and 1997 Addenda of the ASME OM Code with modifications as documented in 10 CFR 50.55a(b)(3)(iv). This was subsequently revised to the 2001 Edition with 2003 Addenda and approved by the NRC with no limitations or modifications (Federal Register 69 FR 58814). The check valve monitoring program requirements in ISTC-5222 and Appendix II of the 2001 Edition with 2003 Addenda of the ASME OM Code are equivalent to the check valve monitoring requirements in 10 CFR 50.55a(b)(3)(iv).

The purpose of this program is both to improve check valve performance and to optimize testing, examination, and preventive maintenance activities in order to maintain continued acceptable check valve performance.

6. IMPLEMENTATION OF UPDATED REQUIREMENTS STPNOC will begin implementing the updated condition monitoring program following approval of this request. Monitoring of these valves is expected to meet the requirements of Appendix II of the OM Code, 2001 Edition with 2003 Addenda, by December 31, 2008. This change to the condition monitoring program is to be applicable for the duration of the current

Attachment NOC-AE-06002086 Page 2 of 2 inspection interval which ends September 24, 2010, for Unit 1 and October 18, 2010, for Unit 2.

All check valves presently in the IST program will be tested in both directions regardless of their safety function under the Appendix II program. Appendix II Criteria will be applied by December 31, 2008.

If the condition monitoring program for a valve or valve group is discontinued, then the testing or examination requirements of the 2001 Edition of the Code with 2003 Addenda, Sections ISTC-3510, ISTC-3520, ISTC-3530, ISTC-3550, and ISTC-5221, shall apply to those affected check valves.

Attachment 2 NOC-AE-06002086 Page 1 of 1 LIST OF COMMITMENTS The following table identifies the actions in this document to which the STP Nuclear Operating Company has committed. Statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Philip Walker at (361) 972-8392.

Commitment Expected CR Action No.

Commitment_ _ Completion Date Appendix II criteria will be applied by December 31, 12/31/2008 06-16412-6 2008.