RS-19-113, Relief Request 14-RS-1 to Use Code Case OMN-13
| ML19345F139 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/11/2019 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-19-113 | |
| Download: ML19345F139 (3) | |
Text
Exelon Generation RS-19-113 December 11, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Relief Request 14-RS-1 to Use Code Case OMN-13 4300 Winfield Road Warrenville, IL 60555 630 65 7 2000 Office 10 CFR 50.55a In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (z)(1 ), Exelon Generation Company, LLC (EGC) requests NRC approval of the attached relief request for Clinton Power Station (CPS), Unit 1. The fourth interval of the CPS, Unit 1, lnservice Test (IST) program will comply with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (i.e., OM Code), 2012 Edition.
ASME has approved Code Case (CC) OMN-13, "Performance-Based Requirements for Extending Snubber lnservice Visual Examination Interval at LWR Power Plants," Revision 2.
This CC is unconditionally approved for use in Regulatory Guide (RG) 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," Revision 2. However, CC OMN-13, Revision 2, states in the Applicability section that it is applicable to ASME OM Code 1995 Edition through 2011 Addenda. The attached relief request proposes use of CC OMN-13, Revision 2, for snubbers.
EGC requests approval of the proposed relief request by December 11, 2020.
There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.
Attachments: 10 CFR 50.55a Relief Request 14-RS-1 to Use Code Case OMN-13 cc:
NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Clinton Power Station
ATTACHMENT 10 CFR 50.55a Relief Request I4-RS-1 to Use Code Case OMN-13 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Page 1
- 1.
ASME Code Component(s) Affected Component Numbers:
All snubbers within the scope of the Clinton Power Station (CPS), Unit 1, Snubber Program
==
Description:==
Alternative Requirements for Extending Snubber Inservice Visual Examination Intervals Code Class:
1, 2, 3, MC, and Non-Safety Related Snubbers that are Important to Safety Examination Category:
ISTD-4200 Drawing Numbers:
Various
- 2.
Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME), "Code for Operation and Maintenance of Nuclear Power Plants," 2012 Edition with no Addenda (ASME OM Code-2012).
- 3.
Applicable Code Requirements ISTA-3130, Application of Code Cases, subparagraph (b), states, "Code Cases shall be applicable to the edition and addenda specified in the test plan."
- 4.
Reason for Request
In accordance with 10 CFR 50.55a, "Codes and Standards," paragraph (z)(1), an alternative is proposed to ISTA-3130(b) requirements for implementing Code Case (CC)
OMN-13, "Performance-Based Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants," Revision 2 (i.e., Reference 1). The basis of the request is that the proposed alternative would provide an acceptable level of quality and safety.
ISTA-3130(b) states, "Code Cases shall be applicable to the edition and addenda specified in the test plan." ASME has approved CC OMN-13, Revision 2. This CC is unconditionally approved for use in Regulatory Guide (RG) 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," Revision 2 (i.e., Reference 2). The CPS code of record for the fourth ten-year Inservice Test (IST) interval is the ASME OM-2012 Edition. However, CC OMN-13, Revision 2, states in the Applicability section that it is applicable to ASME OM Code 1995 Edition through 2011 Addenda. CPS will be implementing the ASME OM-2012 Edition and also proposes to implement CC OMN-13, Revision 2, for snubbers.
CPS used CC OMN-13, Revision 0, during the previous ten-year Inservice Inspection (ISI) interval and proposes to continue with Revision 2 of this CC for the subsequent ten-year IST interval. Based on the required update of the ISI program and 10 CFR 50.55a(b)(3)(v),
ATTACHMENT 10 CFR 50.55a Relief Request I4-RS-1 to Use Code Case OMN-13 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Page 2 OM Condition: Snubbers ISTD, item (B), the requirements for snubbers are moving from ASME Section XI to the OM Code; therefore, this CC OMN-13 request is associated with the next Snubber ten-year IST interval.
- 5.
Proposed Alternative and Basis for Use The proposed alternative to ISTA-3130(b) is requested to implement this CC since the CC Applicability statement covers only the 1995 Edition through the 2011 Addenda and ISTA-3130(b) requires applicability to the edition specified in the test plan, which would be the ASME OM-2012 Edition. A review of the 2012 Edition of the OM Code and CC OMN-13, Revision 2, confirmed that there are no changes in the applicable Code sections referenced within the CC when comparing the 2011 Addenda to the 2012 Edition.
RG 1.192, Revision 2, Table 1, "Acceptable OM Code Cases," lists CC OMN-13, Revision 2 (2012 Edition) as acceptable to the NRC for application in a licensee's IST program without conditions.
Using the provisions of this request as an alternative to the requirements of ISTA-3130(b) will provide adequate detection of observable snubber degradation and, along with the testing and service life monitoring requirements of Subsection ISTD, will continue to provide reasonable assurance of the operational readiness of CPS snubbers. Therefore, the proposed alternative provides an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).
- 6.
Duration of Proposed Alternative This request, upon approval, will be applied to the CPS fourth 10-year IST interval, which begins on July 1, 2020, and is scheduled to end on June 30, 2030.
- 7.
Precedent In Reference 3, the NRC authorized a relief request associated with snubber examinations for Braidwood Station.
- 8.
References
- 1. Code Case OMN-13, "Performance-Based Requirements for Extending Snubber Inservice Visual Examination Interval at LWR Power Plants," Revision 2
- 2. NRC Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability, ASME OM Code," Revision 2
- 3. Letter from L. M. Regner (U.S. NRC) to B. C. Hanson (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 - Proposed Alternative to the Requirements of the American Society of Mechanical Engineers Code (EPID L-2019-LLR-0007),"
dated September 9, 2019