RA-13-094, Proposed Alternative to Utilize Code Case N-649, Alternative Requirements for IWE-5240 Visual Examination Section XI, Division 1
| ML13270A060 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Byron, Limerick, Clinton, Quad Cities, LaSalle |
| Issue date: | 09/25/2013 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LG-13-114, RA-13-094, RS-13-238 | |
| Download: ML13270A060 (6) | |
Text
10 CFR 50.55a LG-13-114 RA-13-094 RS-13-238 September 25, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265
U. S. Nuclear Regulatory Commission Proposed Alternative to Utilize Code N-649 September 2013 Page 2
Subject:
Proposed Alternative to Utilize Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination Section XI, Division 1" In accordance with 10 CFR 50.55a(a)(3)(i), Exelon Generation Company, LLC (Exelon) is requesting a proposed alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," associated with the Containment In service Inspection programs. Specifically, this proposed alternative concerns the use of Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination Section XI, Division 1."
There are no commitments contained in this submittal.
We request your review and approval of this fleet request by September 25, 2014.
Should you have any questions concerning this letter, please contact Mr. Tom Loomis at 610-765-5510.
Respectfully, James Barstow Director- Licensing and Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Proposed Alternative to Utilize Code Case N-649 cc: Regional Administrator- NRC Region I Regional Administrator- NRC Region Ill NRC Senior Resident Inspector- Byron Station NRC Senior Resident Inspector- Clinton Power Station NRC Senior Resident Inspector- Dresden Nuclear Power Station NRC Senior Resident Inspector- LaSalle County Station NRC Senior Resident Inspector- Limerick Generating Station NRC Senior Resident Inspector- Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector- Peach Bottom Atomic Power Station NRC Senior Resident Inspector- Quad Cities Nuclear Power Station NRC Project Manager- Byron Station NRC Project Manager- Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - LaSalle County Station NRC Project Manager- Limerick Generating Station NRC Project Manager- Oyster Creek Nuclear Generating Station NRC Project Manager- Peach Bottom Atomic Power Station NRC Project Manager- Quad Cities Nuclear Power Station
Attachment Proposed Alternative to Utilize Code Case N-649
10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 1 of 3)
Request to Use Code Case N-649 in Accordance with 10 CFR 50.55a(a)(3)(i)
- 1. ASME Code Component(s) Affected:
Code Class: MC
Reference:
ASME Code Case N-649 and IWE-5240 Examination Category: N/A Item Number: N/A
==
Description:==
Applicability of ASME Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination Section XI, Division 1" Component Number: Various
2. Applicable Code Edition and Addenda
PLANT INTERVAL EDITION START END Byron Station, Second 2001 Edition, through 2003 January 16, 2006 July 15, 2016 Units 1 and 2 Addenda Clinton Power Station, Second 2001 Edition, through 2003 September 10, 2008 September 9, Unit 1 Addenda 2018 Dresden Nuclear Power Second 2001 Edition, through 2003 September 9, 2008 September 8, Station, Units 2 and 3 Addenda 2018 LaSalle County Stations, Second 2001 Edition, through 2003 October 1, 2007 September 30, Units 1 and 2 Addenda 2017 Limerick Generating Second 2001 Edition, through 2003 February 1, 2007 January 31, 2017 Station, Units 1 and 2 Addenda Oyster Creek Nuclear Second 2001 Edition, through 2003 September 10, 2009 September 9, Generating Station Addenda 2019 Peach Bottom Atomic Second 2001 Edition, through 2003 November 5, 2008 November 4, 2018 Power Station, Addenda Units 2 and 3 Quad Cities Nuclear Second 2001 Edition, through 2003 September 9, 2008 September 8, Power Station, Addenda 2018 Units 1 and 2
3. Applicable Code Requirement
ASME Section XI, Paragraph IWE-5240, .. Visual Examination, .. requires that a detailed visual examination (IWE-231 0) be performed during an IWE-5220 required pressure test on areas affected by repair/replacement activities.
10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 2 of 3)
ASME Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination Section XI, Division 1,"allows for a VT-3, VT-1, general visual or detailed visual examination depending on the timing of the pressure test.
4. Reason for Request
Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.
ASME Section XI, paragraph IWE-5240 requires that a detailed visual examination of repaired areas be completed during a post repair pressure test performed subsequent to IWE repairs. Integrated leakage rate tests (ILRT) required by 10 CFR 50, Appendix J are often performed following repairs in order to fulfill the post repair testing requirement. However, the IWE-5240 visual examination cannot be performed because the containment liners/shell are inaccessible during the post repair pressure tests (i.e., personnel are not able to be inside the containment during the ILRT).
In recognition of the inability to perform visual examinations of containment liners/shells during the post repair pressure test required by Paragraph IWE-5240, ASME Code Case N-649 was issued to allow the visual examination to be performed during or after the pressure test on the areas affected by the repair/replacement activity. ASME Section XI did not address this inability in the Code until the 2004 Edition through the 2006 Addenda was issued; therefore, ASME Code Case N-649 is needed when using the 2001 Edition through the 2003 Addenda of ASME Section XI, which is applicable to the plants listed in Section 2 of this relief request.
The .. Applicability Index for Section XI Cases .. states that ASME Code Case N-649 is applicable up to and including the 1998 Edition with the 2000 Addenda of ASME Section XI; however, the code of record for the plants listed in Section 2 of this relief request is the 2001 Edition through the 2003 Addenda thus necessitating the need for this relief request. The Edition/Addenda referenced in the Code Case text itself also ends at the 1998 Edition with the 2000 Addenda. However, the requirements of Paragraph IWE-5240 are identical in both the 1998 Edition through the 2000 Addenda and the 2001 Edition through the 2003 Addenda.
Therefore, it is concluded that the proposed alternative provides an acceptable level of quality and safety.
- 5. Proposed Alternative and Basis for Use:
The nuclear plants listed in Section 2 of this attachment request that the applicability of ASME Code Case N-649 be extended to the 2001 Edition through 2003 Addenda for use during the station's Second Containment lSI interval. NRC Regulatory Guide 1.147, Revision 16, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1,"lists ASME Code Case N-649 as acceptable for use with no conditions or limitations. No technical changes are being made to the Code Case.
- 6. Duration of Proposed Alternative:
Relief is requested for the remaining duration of the second containment 10-year lnservice Inspection intervals for the plants listed in Section 2 of this relief request.
10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 3 of 3)
- 7. Precedent:
- 1) A similar relief request to extend the applicability of Code Case N-649 was approved for the Three Mile Island Nuclear Station, Unit 1 (NRC Safety Evaluation Report dated July 20, 2011 - ADAMS Accession ML111730475).
- 2) A similar relief request to extend the applicability of Code Case N-649 was approved for the Braidwood Station, Units 1 and 2 (NRC Safety Evaluation Report dated September 4, 2013 - ADAMS Accession ML13246A019).