View source for JAFP-18-0075, Proposed Alternatives to Utilize Code Cases N-878, N-879, and N-880

{{Adams
| number = ML18208A345
| issue date = 07/26/2018
| title = Proposed Alternatives to Utilize Code Cases N-878, N-879, and N-880
| author name = Barstow J
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000220, 05000237, 05000244, 05000249, 05000254, 05000265, 05000277, 05000278, 05000289, 05000317, 05000318, 05000333, 05000352, 05000353, 05000373, 05000374, 05000410, 05000454, 05000455, 05000456, 05000457, 05000461
| license number = DPR-018, DPR-019, DPR-025, DPR-029, DPR-030, DPR-044, DPR-050, DPR-053, DPR-056, DPR-059, DPR-063, DPR-069, NPF-011, NPF-018, NPF-037, NPF-039, NPF-062, NPF-066, NPF-069, NPF-072, NPF-077, NPF-085
| contact person = 
| case reference number = JAFP-18-0075, NMP1L3236, RS-18-096, TMl-18-080
| document type = Letter type:JAFP
| page count = 11
}}

=Text=
{{#Wiki_filter:Exelon Generation ~
200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.55a RS-18-096 NMP1L3236 JAFP-18-0075 TMl-18-080 July 26, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRG Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRG Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRG Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRG Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRG Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRG Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRG Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRG Docket Nos. 50-352 and 50-353

Proposed Alternatives to Utilize Code Case N-878, N-879, and N-880 July 26, 2018 Page2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 N RC Docket Nos. 50-220 and 50-41 O 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 N RC Docket Nos. 50-254 and 50-265 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

==Subject:==
Proposed Alternatives to Utilize Code Cases N-878, N-879, and N-880

==References:==
: 1) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission, "Proposed Alternative to Utilize Code Case N-879," dated May 30, 2018
: 2) Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission, "Proposed Alternative to Utilize Code Cases N-878 and N-880," dated May 30, 2018
: 3) Letter from B. Purnell (U.S. Nuclear Regulatory Commission) to B. Hanson (Exelon Generation Company, LLC), Supplemental Information Needed for Acceptance of Requests to Use ASME Code Cases N-878, N-879, and N-880, dated July 10, 2018 In the Reference 1 and 2 letters, in accordance with 10 CFR 50.55a(z)(2), Exelon Generation Company, LLC (Exelon) requested proposed alternatives to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," on the basis that compliance with the code results in hardship without a compensating increase in quality. Specifically, these proposed alternatives requested the use of: 1) Code Case N-879, "Use of Micro-Alloyed Carbon Steel Bar in Patented Mechanical Joints and Fittings, Classes 1, 2, and 3 Section Ill, Division 1," which would allow the use of a material that does not comply with the limitations on material specifications and grades mandated by ASME Section Ill (Reference 1), and; 2) Code Case N-878 ("Alternative to QA Program Requirements of IWA-4142 Section XI, Division 1") and N-880 ("Alternative to Procurement Requirements of IWA-4143

Proposed Alternatives to Utilize Code Case N-878, N-879, and N-880 July 26, 2018 Page3 for Small Nonstandard Welded Fittings Section XI, Division 1") {Reference 2), which address the procurement of material from a material supplier that does not possess ASME accreditation as a Quality System Certificate Holder or an NPT Certificate Holder.
Upon further review, Exelon is withdrawing the request to utilize Code Case N-879
{Reference 1). As a result, responses to the questions involving Code Case N-879 are not required. If Exelon chooses to resubmit, a pre-submittal meeting will be requested.
With regards to Question 11 provided in Reference 3 for Code Cases N-878 and N-880, the Reference 2 relief request has been revised to request relief in accordance with 10 CFR 50.55a{z){1) and the deletion of Code Case N-879. The justification in the attached revised relief request supports this request.
There are no regulatory commitments contained in this letter.
If you have any questions, please contact Tom Loomis (610) 765-551 O.
Respectfully, James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

==Attachment:==
Revised Proposed Alternative to Utilize Code Cases N-878 and N-880

Proposed Alternatives to Utilize Code Case N-878, N-879, and N-880 July 26, 2018 Page4 cc:     Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - James A. FitzPatrick Nuclear Power Plant NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - Quad Cities Nuclear Power Station NRC Project Manager - R.E. Ginna Nuclear Power Plant NRC Project Manager - Three Mile Island Nuclear Station, Unit 1

Attachment Revised Proposed Alternative to Utilize Code Cases N-878 and N-880

10 CFR 50.55a RELIEF REQUEST Revision 1 (Page 1of6)
Proposed Alternative to Use Code Cases N-878 and N-880 in Accordance with 10 CFR 50.55a(z)(1)
: 1. ASME Code Component(s) Affected:
All ASME Class 1, 2, and 3 stainless-steel piping systems.

===2. Applicable Code Edition and Addenda===
PLANT           INTERVAL          EDITION                 START               END Braidwood Station, Units   Fourth        2013 Edition         August 29, 2018     July 28, 2028 1and2                                                October 17, 2018  October 16, 2028 Byron Station,        Fourth  2007 Edition, through 2008   July 16, 2016   January 15, 2026 Units 1 and 2                        Addenda Calvert Cliffs Nuclear    Fourth        2004 Edition         October 10, 2009    June 30, 2019 Power Plant, Units 1 and 2
Clinton Power Station,     Third        2004 Edition            July 1, 2010     June 30, 2020 Unit 1 Dresden Nuclear Power       Fifth  2007 Edition, through 2008 January 20, 2013  January 19, 2023 Station, Units 2 and 3                     Addenda James A. FitzPatrick       Fifth 2007 Edition, through 2008  August 1, 2017     June 15, 2027 Nuclear Power Plant                       Addenda LaSalle County Stations,   Fourth  2007 Edition, through 2008  October 1, 2017 September 30, 2027 Units 1 and 2                         Addenda Limerick Generating      Fourth  2007 Edition, through 2008 February 1, 2017  January 31, 2027 Station, Units 1 and 2                    Addenda Nine Mile Point Nuclear   Fourth         2004 Edition         August23,2009     August 22, 2019 Station, Unit 1 Nine Mile Point Nuclear     Fifth        2013 Edition         August 23, 2019   August22,2029 Station, Unit 1 Nine Mile Point Nuclear    Third         2004 Edition           April 5, 2008   August22,2018 Station, Unit 2 Nine Mile Point Nuclear    Fourth        2013 Edition         August 23, 2018   August22,2028 Station, Unit 2 Peach Bottom Atomic       Fourth 2001 Edition, through 2003 November 5, 2008 December 31, 2018 Power Station, Units 2                     Addenda and 3

10 CFR 50.55a RELIEF REQUEST Revision 1 (Page 2 of 6)
PLANT           INTERVAL          EDITION                START               END Peach Bottom Atomic       Fifth        2013 Edition         January 1, 2019  December 31, 2028 Power Station, Units 2 and 3 Quad Cities Nuclear      Fifth  2007 Edition, through 2008   April 2, 2013     April 1, 2023 Power Station, Units 1                    Addenda and2 R. E. Ginna Nuclear      Fifth        2004 Edition         January 1, 201 O December 31, 2019 Power Plant Three Mile Island Nuclear   Fourth        2004 Edition          April 20, 2011    April 19, 2022 Station, Unit 1
: 3. Applicable Code Requirements:
Code Case N-878 ("Alternative to QA Program Requirements of IWA-4142 Section XI, Division 1")
ASME Code, Section XI, IWA-4142 of the 2001 Edition with the 2003 Addenda, the 2004 Edition, the 2007 Edition with 2008 Addenda, and the 2013 Edition, provide requirements for procurement of materials to be used in repair/replacement activities.
Code Case N-880 ("Alternative to Procurement Requirements of IWA-4143 for Small Nonstandard Welded Fittings Section XI, Division 1")
ASME Code, Section XI, IWA-4142 and IWA-4143, of the 2001 Edition with the 2003 Addenda, the 2004 Edition, the 2007 Edition with 2008 Addenda, and the 2013 Edition, provide requirements for procurement of materials by the Owner, and fabrication of non-Code-stamped parts by the Owner, when the Construction Code is Section Ill, to be used in repair/replacement activities.

===4. Reason for Request===
In accordance with 10 CFR 50.55a(z)(1 ), Exelon Generation Company, LLC (Exelon) is requesting proposed alternatives from the ASME Section XI, IWA-4200 requirements for compliance with Section Ill, NA-3700 or NCA-3800, as applicable, for procurement of nonstandard, nonwelded, proprietary pipe fittings larger than NPS 1 or Reactor Coolant System (RCS) makeup capacity, supplied as material, installed in Section XI repair/replacement activities in applications where the Construction Code is ASME Section Ill Winter 1973 addenda or later. Section XI, IWA-4142.1 of the 2007 Edition or later, specifies alternative procurement requirements for the Owner, but these alternatives may not be used by a non-ASME-accredited contracted Repair/Replacement Organization.
Section XI permits use of these fittings in ASME 831.1, 831.7, or pre-Winter 1973 applications.

10 CFR 50.55a RELIEF REQUEST Revision 1 (Page 3 of 6)
In accordance with 10 CFR 50.55a(z)(1 ), Exelon is requesting proposed alternatives from the ASME Section XI, IWA-4200 requirements for compliance with Section Ill, NA-8000 or NCA-8000, as applicable, for fabrication of nonstandard, proprietary welded pipe fittings larger than NPS 1 or RCS makeup capacity up to NPS 2, installed in Section XI repair/replacement activities in applications where the Construction Code is ASME Section 111 1971 edition or later. Section XI, IWA-4143 permits fabrication of welded fittings at the Owner's facilities, but does not permit such fabrication to be performed in a facility owned by a Repair/Replacement Organization or other contractor or supplier.
Both Cases Exelon is requesting to use nonstandard, proprietary, welded or nonwelded pipe fittings in applications requiring compliance with ASME Section Ill, without having to comply with the administrative requirements imposed by ASME Section XI, IWA-4142, IWA-4143, and IWA-4200.
Nonstandard, proprietary welded or nonwelded pipe fittings can be proven, by testing, to comply with Section Ill design requirements. Exelon has a supplier of such fittings that does not possess ASME accreditation as a Quality System Certificate Holder or an NPT Certificate Holder. Exelon cannot find any supplier of equivalent products that possesses the accreditation required by ASME Section Ill. However, these products can be verified as having an acceptable level of safety by complying with the provisions specified in ASME Cases N-878 and N-880.
Exelon is currently permitted by ASME Section XI to install the following:
: 1. Welded or nonwelded fittings produced by a non-ASME-accredited supplier in safety-related applications in ASME 831.1 or 831.7 Class I, II, or Ill piping systems (IWA-4221 ).
: 2. Welded or nonwelded fittings produced by a non-ASME accredited supplier in Class 1 systems no larger than NPS 1 and no larger than RCS makeup capacity (IWA-4131).
: 3. Welded or nonwelded fittings produced by this supplier in Class 2 or 3 systems NPS 1 or smaller (IWA-4131).
: 4. Nonwelded fittings produced by a non-ASME accredited supplier in ASME Section Ill Class 1, 2, and 3 piping systems as permitted by the reference code year.
: 5. Nonwelded fittings NPS 2 and smaller produced by this supplier in ASME Section Ill Class 1, 2, and 3 piping systems, provided Exelon verifies material conformance with the reference code year.
: 6. Nonwelded fittings larger than NPS 2 produced by a non-ASME-accredited supplier in ASME Section Ill Class 1, 2, and 3 piping systems, with additional material testing by Exelon as permitted by the reference code year.

10 CFR 50.55a RELIEF REQUEST Revision 1 (Page 4 of 6)
: 7. Welded fittings fabricated by a non-ASME-accredited supplier in Class 2 and 3 piping systems in plants with construction permits issued before the NRC made Section Ill compliance and Code Symbol Stamping of Class 2 and 3 systems mandatory in 10 CFR 50.55a on May 14, 1984 (49 FR 9711) (IWA-4221 and 10 CFR 50.55a).
Exelon is not currently permitted by ASME Section XI to install the following:
: 1. Nonwelded fittings larger than NPS 1, or RCS makeup capacity, fabricated by a non-ASME-accredited supplier, and purchased by a contractor without ASME accreditation without additional material testing by Exelon, in Section Ill, Class 1, 2, and 3 piping systems certified to the Section Ill Winter 1973 Addenda or later.
: 2. Welded fittings larger than NPS 1, or RCS makeup capacity, fabricated by a non-ASME accredited supplier in Section Ill, Class 1, 2, and 3 piping systems certified to the Section Ill 1971 Edition or later.
These two Cases will expand Exelon's ability to use these proprietary fittings in sizes larger than NPS 1, or RCS makeup capacity, in Section Ill, Class 1, 2, and 3 systems.
Most piping fabrication and installation joints have been traditionally fabricated by welding.
Installation of pipe and piping subassemblies by mechanical means can save significant amounts of time, money, critical path time, and radiation exposure to plant personnel and installation and examination contractors. In systems containing radioactive materials, or in systems near irradiated components, personnel can be subjected to significant amounts of radiation during preparation for welding, welding, and nondestructive examination (NOE) of welds. Most of this exposure can be eliminated by use of mechanical connections. The amount of time to which mechanical installation personnel are exposed is a fraction of the time to which a welder or a nondestructive examiner would be exposed. Without installation welds, there is no associated installation NOE.
: 5. Proposed Alternative and Basis for Use:
Exelon proposes to implement the requirements of ASME Code Cases N-878 for procurement of nonstandard, nonwelded, proprietary pipe fittings larger than NPS 1, or RCS makeup capacity, supplied as material, and N-880 for procurement of nonstandard, proprietary welded pipe fittings larger than NPS 1, or RCS makeup capacity, up to NPS 2.
ASME Section XI requires the fittings to be designed in accordance with the original Construction Code, which, for these applications, is ASME Section Ill. These fittings are typically designed in accordance with ASME Section Ill, NB-3671.7, "Sleeve Coupled and Other Patented Joints," using the option of prototype testing. Alternatively, NC/N0-3671.7 may be used for Class 2 or 3 fittings, as applicable.
Reconciliation and use of editions and addenda of ASME Section Ill will be in accordance with ASME Section XI, IWA-4220, and only editions and addenda of ASME Section Ill that have been accepted by 10 CFR 50.55a may be used. The Code of Record for the specific 10-year ISi interval at each nuclear unit as identified under Section 2 above, will be used when applying

10 CFR 50.55a RELIEF REQUEST Revision 1 (Page 5 of 6) the various IWA paragraphs of Section XI, unless specific regulatory relief to use other editions or addenda is approved.
All other ASME Section XI requirements for which relief was not specifically requested and authorized by the NRC Staff will remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.
Case N-878 requires that non-welded fittings be supplied in accordance with the provisions of Section XI, IWA-4142.1 (b)(4) or (5), except that the activities will be performed by a Repair/Replacement Organization qualified by the Owner in accordance with 10 CFR 50, Appendix B. These provisions are already permitted if applied by Exelon, rather than being subcontracted to an Exelon-approved Repair/Replacement Organization. These provisions are already permitted for the more than approximately 50% of U.S. nuclear plants built before Section Ill became mandatory for new piping systems, even when implemented by a non-ASME-accredited Repair/Replacement Organization. They are also currently permitted for piping smaller than NPS 1 and RCS makeup capacity. Because Exelon will control approval of the Repair/Replacement Organization that will apply these provisions, Exelon can and will ensure that 10 CFR 50, Appendix B Quality Assurance Program requirements are met for the supply of these fittings. Exelon will also ensure that the materials, design, fabrication, installation, and testing of these fittings complies fully with ASME Section Ill, as required by ASME Section XI.
Case N-880 imposes the same requirements as Case N-878, as well as additional requirements, over and above those of Case N-878, because, in the case of Case N-880, the fittings within the scope of Case N-878 are welded to standard pipe fittings. These standard fittings are permitted by all Editions and Addenda of Section Ill. As with Case N-878, these activities are currently permitted for U.S. nuclear plants built before Section Ill became mandatory for new piping systems, even when implemented by a non-ASME-accredited contractor. They are also currently permitted for piping smaller than NPS 1 and RCS makeup capacity. Because Exelon will control approval of the contractor that will apply these provisions, Exelon can and will ensure that 10 CFR 50, Appendix B Quality Assurance Program requirements are met for the supply of these fittings. Exelon will also ensure that the materials, design, installation, and testing of these fittings complies fully with ASME Section Ill, as required by ASME Section XI. Because the fitting-to-fitting welds will be made by a non-ASME-accredited fabricator, Exelon will perform additional verification, as prescribed by Case N-880, to ensure the quality of these welds. Exelon, or a Repair/Replacement Organization qualified by Exelon in accordance with 10 CFR 50 Appendix B, will verify the quality of the materials, the welding procedure and performance qualifications, the weld joint fit-up, the production welding, and all nondestructive examination required by Section Ill or the piping system Design Specifications. For fittings manufactured in accordance with Case N-880, ANll surveillance and monitoring of the materials, welding, and nondestructive examination will also be provided, consistent with the requirements of ASME Section XI that would apply if these welds were made by the Owner or Repair/Replacement Organization at the nuclear power plant site. The quality will therefore be consistent with all requirements that would be applied if the fitting-to-fitting welds were made at the plant, as currently permitted by ASME Section XI.
Accordingly, the proposed alternative to utilize Code Cases N-878 and N-880 will provide an acceptable level of quality and safety in accordance with 10 CFR, 50.55a(z)(1 ).

10 CFR 50.55a RELIEF REQUEST Revision 1 (Page 6 of 6)
Code Cases N-878 and N-880 were approved by the ASME Board on Nuclear Codes and Standards on April 18, 2017 and July 25, 2017, respectively. They have not yet been incorporated into NRC Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1," and thus are not available for application at nuclear power plants without specific NRC approval. Therefore, Exelon requests use of the alternative procurement requirements described in these Cases via this relief request.
: 6. Duration of Proposed Alternative:
The proposed alternative is for use of the Cases for the remainder of each plant's 10-year inspection interval as specified in Section 2 and for the remainder of the plant's life.
: 7. Precedent:
None}}