ULNRC-05620, Clarification Regarding Application of ASME Code Relief Request Approved for Callaway

Clarification Regarding Application of ASME Code Relief Request Approved for Callaway

ML091260775
Person / Time
Site:	Callaway
Issue date:	05/01/2009
From:	Sandbothe S AmerenUE, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05620
Download: ML091260775 (6)

Text

AmerenUf PO Box 620 Callaway Plant Fulton, MO 65251 May 1, 2009 ULNRC-05620 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

~r¿ 10 CFR 50.55a wAmeren Ladies and Gentlemen:

UE DOCKET NUMBER 50-483 CALLA WAY PLANT UNIT 1 UNION ELECTRC CO.

FACILITY OPERATING LICENSE NPF-30 CLARIFICATION REGARDING APPLICATION OF ASME CODE RELIEF REOUEST APPROVED FOR CALLA WAY In a series of letters submitted by Union Electric Company (AmerenUE) during the 2002-2004 timetfame, AmerenUE requested relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) to allow Class 2 pipe welds at Callaway to be examined using a qualified ultrasonic testing (UT) exaination instead of the ASME Code-required radiographic testing (RT) examination. The performance ofUT examinations (in lieu ofRT examinations) is an alternative to the non-destructive examination requirements of Subarticle NC-5200 of Section of the ASME Code, as applicable to pipe welds in sections of the main steam and main feedwater systems at Callaway.

AmerenUE's original request was submitted by letter dated October 17,2002 per Reference 1 identified in the attachment to this letter. (All references idenitifed in this letter are listed in the attachment to this letter.) Shortly after the NRC received the relief request, a request for additional information (RA) was transmitted to Callaway wherein the NRC staff noted that a specific scope of applicable welds must be identified in the relief request. AmerenUE's request was for welds anticipated to be made for piping replacements in the main steam and feedwater systems. The piping replaceents were expected to be needed due to planned modifications but also as determined by Callaway's flow accelerated corrosion (F AC) monitoring program for Class 2 piping in these systems. In response to the RA a specific list was incorporated into the relief request in which the subject welds were identified by the existing weld numbers along with descriptions of their locations within the subject a subsidiary of Ameren Corporation

ULNRC-05620 May 1, 2009 Page 2 piping. The revised relief request was submitted by letter dated October 30, 2002 (Reference 2). Subsequently, the need to augment the list of applicable welds was identified, and thus, a revised relief request was submitted by AmerenUE letter dated Februar 13,2003 (Reference 3). NRC approval of the relief request was obtained via the NRC's letter dated July 1, 2003 (Reference 4).

In 2004, the need to augment the list of applicable welds was again identified. This was identified, in particular, during Callaway's refueling outage (Refuel 13) conducted that year. A revised relief request was therefore submitted by letter dated May 7,2004 (Reference 5). The NRC promptly approved the request via a letter dated May 19, 2004 (Reference 6) in support of the refueling outage.

Finally, by leter dated November 18,2004 (Reference 7), AmerenUE noted that the second 10-year ISI interval for Callaway would be ending in December 2005, and that replacement of main feedwater and main steam piping would be occurng in the early part of the third 10-year intervaL. AmerenUE thus requested that the subjec relief request be approved for the remainder of the second 10-year interval as well as the forthcoming third 1O-year interval. The revised relief request was subsequently approved per the NRC's letter dated May 19,2005 (Reference 8). This approved version of the relief request is stil in effect today.

As noted above, the first revision of the relief request was done to identify and incorporate a specific scope of applicable welds (in response to the NRC' s 2003 RA. Specifically, the applicable welds were (and continue to be) listed in a table contained in the approved relief request document (i.e., in Table 1) in which each weld is identified by the existing weld number along with a brief description of the weld location within the Class 2 piping. A note is included in the table in which it is stated that the weld numbers are the current weld numbers. This note was included in light of the expectation that different weld numbers would be assigned for the new welds to be made at or near the same locations when the associated pipe sections are replaced.

At present, plans are being finalized for the next refueling outage to be conducted at Callaway (Spring 2010). In particular, more pipe sections are to be replaced in the main feedwater system, based on determinations made from the F AC program. The subject relief request is expected to be utilized so that UT examinations may be performed in lieu ofRT examinations for the replacement pipe welds, as intended.

The new welds wil have different weld numbers than those currently identified in the approved relief request, though the new welds wil be at or near the same locations.

In light of any concerns or questions regarding the applicability or scope of the relief request with respect to these welds, it is AmerenUE's position that the subject welds are within the existing scope of the relief request such that no new or revised relief request is needed. This is consistent with the understanding that new weld numbers assigned as a result of piping replacements would not be identical to the existing weld numbers for welds on currently installed piping.

ULNRC-05620 May 1, 2009 Page 3 Although it may be assumed that the above was understood when the NRC prepared and issued its Safety Evaluation for the subject relief request, it was felt that this should be clarfied and discussed with the NRC. Consequently, this issue was discussed via several telephone conversations with the NRC Senor Project Manager for Callaway in April 2009. From those discussions it was suggested that AmerenUE submit a clarfication letter explaining the issue, i.e., why no revision of the relief request is needed. This letter is submitted accordingly, for information only.

No new commitments are identified in this letter. Please contact Scott Maglio at 573-676-8719 or Tom Elwood at 573-676-6479 for any questions you may have concerning this matter.

~Ak Sincerely, Scott Sandbothe Manager, Regulatory Afairs TBE/nls Attachment

ULNRC-05620 May 1, 2009 Page 4 cc: Mr. Elmo E. Collns, Jr.

Regional Administrator US. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Offce US. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thaani (2 copies)

Senior Projec Maager, Callaway Plant Offce of Nuclear Reaor Regulation U S. Nuclear Regulatory Commission Mail Stop 0-8G i 4 Washington, DC 20555-2738

ULNRC-05620 May i, 2009 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Cert reives ALL attchmts as long as they ar non-seguds an may be publicly disclose.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

A C. Heflin F. M. Diya T. E. Herrann L. S. Sandbothe S. A. Malio S. L. Gallagher T. L. Woodward (NSRB)

L. M. Belsky (NSRB)

T. B. Elwood C. R. Kiefer

1. A. Dought Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU Mr. Scott Bauer (palo Verde)

Mr. Stan Ketelsen (pG&E)

Mr. Wayne Harrson (STPNOC)

Mr. John O'Neil (pilsbur Winthrop Shaw Pittman LLP)

Missouri Public Servce Commission

Attachment to ULNRC-05620 References

1. AmerenUE Letter ULNRC-04760, "Request for Relief From ASME Secton III Requirements Regarding Non-Destructive Examination of Welds Performed Under Site Replacement Program" dated October 17, 2002

2. AmerenUE Leter ULNRC-04768, "Revision to Request for Relief From ASME Section il Requirements Regarding Non-Destructive Examination of Welds Perormed Under Site Repair/Replacement Program (T AC No. MB6534)," dated October 30, 2002

3. AmerenUE Letter ULNRC-04807, "Revision to Request for Relief From ASME Section il Requirements Regarding Non-Destrctive Examination of Welds Performed Under Site Repair/Replacement Program (TAC No. MB6534)," dated Februar 13, 2003

4. NRC Letter from Stephen Dembek to Gar L. Radolph, "Callaway Plant, Unit 1

- Second T en- Year Interval Inservice Inspection Program Relief Request to Use an Alternative Examination Method (T AC No. MB6534)," dated July 1, 2003

5. AmerenUE Letter ULNRC-04997, "Revision to Request for Relief From ASME Section il Requirements Regarding Non-Destructive Examination of Welds Performed Under Site Repai/Replacement Program," dated May 7,2004

6. NRC Leer from Stephen Dembek to Gar L. Randolph, "Callaway Plant, Unit 1

- Second Ten-Year Interval Inservice Inspection Program Relief Request to Use an Alternative Examination Method (TAC No. MC3087)," dated May 19,2004

7. AmerenUE Letter ULNRC-05092, "Revision to Approved Request for Relief From ASME Section III Requirements Regarding Non-Destructive Examination of Welds Performed Under Site Repair/Replacement Program," dated November 18,2004

8. NRC Letter from Robert A. Gramm to Charles D. Naslund, "Callaway Plant, Unit 1 - Request for Relief from Certain ASME Code Examinations for the Second and Third Inservice Inspection Intervals (TAC No. MC5379)," dated May 19, 2005