|
|
(4 intermediate revisions by the same user not shown) |
Line 2: |
Line 2: |
| | number = ML121150247 | | | number = ML121150247 |
| | issue date = 05/03/2012 | | | issue date = 05/03/2012 |
| | title = Callaway Plant, Unit 1 - Memo to File, Verbal Authorization, Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of Main Steam Isolation Valve Actuator Rupture Disks (TAC ME8319) | | | title = Memo to File, Verbal Authorization, Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of Main Steam Isolation Valve Actuator Rupture Disks |
| | author name = Kalyanam N | | | author name = Kalyanam N |
| | author affiliation = NRC/NRR/DORL/LPLIV | | | author affiliation = NRC/NRR/DORL/LPLIV |
Line 18: |
Line 18: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:May 3, 2012 | | {{#Wiki_filter:May 3, 2012 MEMORANDUM TO: Docket File FROM: N. Kalyanam, Project Manager /RA/ |
| | | Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation |
| MEMORANDUM TO: Docket File FROM: N. Kalyanam, Project Manager /RA/ Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation | |
|
| |
|
| ==SUBJECT:== | | ==SUBJECT:== |
| CALLAWAY PLANT UNIT 1 - VERBAL AUTHORIZATION VR-01, PROPOSED ALTERNATIVE REGARDING ASME OM CODE REPLACEMENT INTERVAL FOR MAIN STEAM ISOLATION VALVE ACTUATOR RUPTURE DISKS (TAC NO. ME8319) | | CALLAWAY PLANT UNIT 1 - VERBAL AUTHORIZATION VR-01, PROPOSED ALTERNATIVE REGARDING ASME OM CODE REPLACEMENT INTERVAL FOR MAIN STEAM ISOLATION VALVE ACTUATOR RUPTURE DISKS (TAC NO. ME8319) |
| By letter dated March 30, 2012, as supplemented by letter dated April 19, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12090A501 and ML121150347, respectively), Union Electric Company, (the licensee) submitted alternative request VR-01 for the Callaway Plant, Unit 1, for U.S. Nuclear Regulatory Commission (NRC) review and approval. | | By letter dated March 30, 2012, as supplemented by letter dated April 19, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12090A501 and ML121150347, respectively), Union Electric Company, (the licensee) submitted alternative request VR-01 for the Callaway Plant, Unit 1, for U.S. Nuclear Regulatory Commission (NRC) review and approval. |
| This request pertains to inservice testing requirements for Main Steam Isolation Valve (MSIV) actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 at Callaway Plant, Unit 1. The licensee requested an alternative from the required replacement frequency requirement of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) Mandatory Appendix I, Paragraph I-1360, "Test Frequency, Class 2 and 3 Nonreclosing Pressure Relief Devices," as required and conditioned by Title 10 of the Code of Federal Regulations Section 50.55a. | | This request pertains to inservice testing requirements for Main Steam Isolation Valve (MSIV) actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 at Callaway Plant, Unit 1. The licensee requested an alternative from the required replacement frequency requirement of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) Mandatory Appendix I, Paragraph I-1360, Test Frequency, Class 2 and 3 Nonreclosing Pressure Relief Devices, as required and conditioned by Title 10 of the Code of Federal Regulations Section 50.55a. |
| Specifically, an alternative was requested for the requirement to replace MSIV actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 every 5 years. Callaway Plant, Unit 1, had originally scheduled the rupture disks replacement during Refueling Outage 18, which began in October 2011. However, the work was removed from the outage scope based on an initial determination that the work could be done with the plant online subsequent to the outage. The rupture disks were scheduled to be replaced online in the spring of 2012 to meet the ASME OM Code requirement. However, the licensee determined that based on the 8-hour Technical Specification (TS) Limiting Conditions for Operations (LCO) and the time needed to replace the rupture disks online, the TS LCO completion time may be exceeded during this replacement activity. Therefore, the rupture disk replacement activity poses elevated risk to continued plant operations if it is performed online. Therefore, the licensee is proposing an alternative to extend the interval for replacing the rupture disks to the next plant outage providing plant conditions to replace the disks (i.e. Mode 4 or 5), but no later than the end of Refueling Outage 19, which is currently scheduled for June 2013. | | Specifically, an alternative was requested for the requirement to replace MSIV actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 every 5 years. Callaway Plant, Unit 1, had originally scheduled the rupture disks replacement during Refueling Outage 18, which began in October 2011. However, the work was removed from the outage scope based on an initial determination that the work could be done with the plant online subsequent to the outage. The rupture disks were scheduled to be replaced online in the spring of 2012 to meet the ASME OM Code requirement. However, the licensee determined that based on the 8-hour Technical Specification (TS) Limiting Conditions for Operations (LCO) and the time needed to replace the rupture disks online, the TS LCO completion time may be exceeded during this replacement activity. Therefore, the rupture disk replacement activity poses elevated risk to continued plant operations if it is performed online. Therefore, the licensee is proposing an alternative to extend the interval for replacing the rupture disks to the next plant outage providing plant conditions to replace the disks (i.e. Mode 4 or 5), but no later than the end of Refueling Outage 19, which is currently scheduled for June 2013. |
| | |
| Extending the replacement date until Refueling Outage 19 will not affect the functionality of the MSIVs and does not introduce any credible failure mechanism that would prevent the rupture disks from rupturing at a pressure needed for the MSIVs to perform their safety-related purpose.
| |
|
| |
|
| | Extending the replacement date until Refueling Outage 19 will not affect the functionality of the MSIVs and does not introduce any credible failure mechanism that would prevent the rupture disks from rupturing at a pressure needed for the MSIVs to perform their safety-related purpose. |
| Conclusion As set forth above, the NRC staff concludes that the proposed alternative described in alternative request VR-01 provides reasonable assurance that the MSIV actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 are operationally ready. | | Conclusion As set forth above, the NRC staff concludes that the proposed alternative described in alternative request VR-01 provides reasonable assurance that the MSIV actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 are operationally ready. |
| Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff provides verbal authorization for the proposed alternatives described in request alternative VR-01 until the next plant outage providing plant conditions to replace the MSIV actuator rupture disks (i.e., Mode 4 or 5), but no later than the end of the Callaway Plant, Unit 1, Refueling Outage 19, which is currently scheduled for June 2013. | | Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff provides verbal authorization for the proposed alternatives described in request alternative VR-01 until the next plant outage providing plant conditions to replace the MSIV actuator rupture disks (i.e., Mode 4 or 5), but no later than the end of the Callaway Plant, Unit 1, Refueling Outage 19, which is currently scheduled for June 2013. |
| | | All other ASME Code requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. |
| All other ASME Code requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. | |
| | |
| The participants in the telephone call were: | | The participants in the telephone call were: |
| NRC Mike Markley, Branch Chief, NRR/DORL/LPL4) | | NRC Mike Markley, Branch Chief, NRR/DORL/LPL4) |
| Tony McMurtray, Branch Chief, NRR/DE/EPTB Bob Wolfgang, NRR/DE/EPTB Zach Hollcraft, R-IV/DRP/RPB-B/ Kaly Kalyanam, NRR/DORL/LPL4 | | Tony McMurtray, Branch Chief, NRR/DE/EPTB Bob Wolfgang, NRR/DE/EPTB Zach Hollcraft, R-IV/DRP/RPB-B/ |
| | | Kaly Kalyanam, NRR/DORL/LPL4 UNION ELECTRIC COMPANY Brian Pae, Main Steam System Engineer Ben Oguejiofor, Inservice Testing Engineer Christine Norman, Mechanical Design Engineer Bryan Sprock, Engineering Fix-It-Now Engineer Tom Elwood, Regulatory Affairs and Licensing Supervisor Docket No. 50-483 |
| UNION ELECTRIC COMPANY Brian Pae, Main Steam System Engineer Ben Oguejiofor, Inservice Testing Engineer Christine Norman, Mechanical Design Engineer Bryan Sprock, Engineering Fix-It-Now Engineer Tom Elwood, Regulatory Affairs and Licensing Supervisor | |
| | |
| Docket No. 50-483 | |
|
| |
|
| ML121150247 *via email OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DE/EPTB/BC NRR/LPL4/BC NRR/LPL4/PM NAME NKalyanam JBurkhardt AMcMurtray* MMarkley NKalyanam DATE 4/25/12 4/25/12 4/23/12 5/3/12 5/3/12}} | | ML121150247 *via email OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DE/EPTB/BC NRR/LPL4/BC NRR/LPL4/PM NAME NKalyanam JBurkhardt AMcMurtray* MMarkley NKalyanam DATE 4/25/12 4/25/12 4/23/12 5/3/12 5/3/12}} |
Letter Sequence Other |
---|
|
|
MONTHYEARULNRC-05844, Facility Operating License NPF-30 10 CFR50.55a Request: Proposed Alternative Regarding ASME OM Code Replacement Interval for Main Steam Isolation Value Actuator Rupture Disks2012-03-30030 March 2012 Facility Operating License NPF-30 10 CFR50.55a Request: Proposed Alternative Regarding ASME OM Code Replacement Interval for Main Steam Isolation Value Actuator Rupture Disks Project stage: Request ML1210105772012-04-0505 April 2012 Request for Additional Information Re E-mail, Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of Main Steam Isolation Valve Actuator Rupture Disks Project stage: RAI ML1210105692012-04-0909 April 2012 Attachment 5 Project stage: Other ML1210105602012-04-0909 April 2012 Attachment 4 Project stage: Other ML1210105572012-04-0909 April 2012 Attachment 3 Project stage: Other ML1210105522012-04-0909 April 2012 Attachment 2 Project stage: Other ML1210105382012-04-0909 April 2012 Attachment 1 Project stage: Other ML1210105182012-04-0909 April 2012 Email Licensee Responses to Request for Additional Information Regarding Relief Request, Main Steam Isolation Valve Actuator Rupture Disks Replacement Interval Project stage: Response to RAI ML1210104882012-04-10010 April 2012 Request for Additional Information Email to the Licensee, Relief Request Main Steam Isolation Valve Actuator Rupture Disks Replacement Interval Project stage: RAI ML1211502472012-05-0303 May 2012 Memo to File, Verbal Authorization, Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of Main Steam Isolation Valve Actuator Rupture Disks Project stage: Other ML12220A2322012-08-0909 August 2012 Request for Additional Information, Verbal Authorization of Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of MSIV Actuator Rupture Disks Project stage: RAI ULNRC-05905, Response to NRC Request for Additional Information Regarding 10 CFR 50.55a Request: Proposed Alternative to ASME OM Code Replacement Interval for Main Steam Isolation Valve Actuator Rupture Disks2012-09-10010 September 2012 Response to NRC Request for Additional Information Regarding 10 CFR 50.55a Request: Proposed Alternative to ASME OM Code Replacement Interval for Main Steam Isolation Valve Actuator Rupture Disks Project stage: Response to RAI ML12258A0452012-09-18018 September 2012 Relief Request VR-01 from Requirements of ASME OM Code, Mandatory Appendix I, One-time Extension for 5-Year Replacement Interval, from 4/11/12 to 6/2013, Main Steam Isolation Valve Actuator Rupture Disks Project stage: Other 2012-04-09
[Table View] |
|
---|
Category:Memoranda
MONTHYEARML22147A0932022-06-0606 June 2022 2021 Annual Assessment Public Meeting Summary ML22034A3932022-02-16016 February 2022 Calendar Year 2021 Security Baseline Completion Memo ML21216A2002021-08-11011 August 2021 Summary of Public Webinar with Ameren Missouri to Discuss the Nuclear Regulatory Commission 2020 Annual Assessment of Callaway Plant Docket No. 50-483 ML21111A0372021-05-0303 May 2021 Inspection Manual Chapter 0375 Recommendation for Callaway Plant ML18173A0082018-06-20020 June 2018 Cancelling Numerous Inspection Report Numbers ML17170A3202017-06-20020 June 2017 Safety Evaluation Input - for Ameren Missouri Request to Amend Callaway Plant, Unit 1, Technical Specification 5.6.5, Core Operating Limits Report - ML16197A0102016-08-22022 August 2016 Staff Observations of Testing for Generic Safety Issue 191 During a June 28 to June 30, 2016 Trip to the Alden Test Facility for Performance Contracting Inc. Strainer Tests ML16091A1522016-03-31031 March 2016 Request to Review and Update Guidance in National Fire Protection Association (NFPA) 805 Frequently Asked Question (FAQ) 07-0040 ML15139A4842015-06-0202 June 2015 Staff Review of Callaway Plant Unit 1 Physical Security Plan Revision 12 for the Verification of ASM (EA-13-237) Incorporation (TAC No. L25009) ML14310A8362015-02-0909 February 2015 NRC Staff Evaluation of Final Rule for Continued Storage of Spent Nuclear Fuel for the License Renewal Environmental Review for Callaway, Unit 1 ML14177A5952014-07-0808 July 2014 Summary of Telephone Conference Call Held on February 12, 2014, Between the U.S. Nuclear Regulatory Commission and Union Electric Company (Ameren Missouri), Concerning Requests for Additional Information Pertaining to the Callaway Plant, Un ML14183A0212014-07-0101 July 2014 License Renewal Application ML14121A5532014-06-18018 June 2014 November 25, 2013, Summary of Telephone Conference Call Held Between NRC and Union Electric Co., (Ameren Missouri), Concerning Requests for Additional Information Pertaining to Callaway, Unit 1, License Renewal Application ML14121A1062014-05-12012 May 2014 Advisory Committee on Reactor Safeguards Review of the Callaway Nuclear Plant License Renewal Application - Safety Evaluation Report ML14112A2762014-05-0707 May 2014 Summary of Public Meetings to Discuss Draft Supplement 51 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Callaway Plant, Unit 1 ML14104A8932014-04-23023 April 2014 U.S. Nuclear Regulatory Commission Staff'S Spot- Check Review of Ameren Missouri'S 100 Percent Ownership Interest in Callaway Energy Center, Docket No. 50-483, on April 8, 2014- Finding of No Potential Issue ML14087A2102014-04-0808 April 2014 Summary of 3/25/14 Verbal Relief Telephone Conference, Relief Request I3R-16, Temporary Non-Code Repair of the Train a Component Cooling Water Heat Exchanger to Control ESW Leakage, Third 10-Year Inservice Inspection Interval ML14035A5752014-03-25025 March 2014 January 28, 2014, Summary of Telephone Conference Call Held Between NRC and Union Electric Company (Ameren Missouri), Pertaining to the Callaway Plant Unit 1, LRA ML13246A3072013-09-0909 September 2013 Memorandum to File - Verbal Authorization of Relief Request PR-07, Testing Frequency for Pumps and Valves, Third 10-year Inservice Testing Interval ML13126A3202013-05-0707 May 2013 Summary of Telephone Conference, Verbal Authorization of Relief Request I3R-14. Proposed Alternative to ASME Code Requirements for Leakage Testing of RPV Head Flange Leakoff Lines, Third 10-Year ISI Interval. ML13059A8002013-03-11011 March 2013 Summary of Telephone Call Held on 11/5/12, Between NRC and Union Electric Company, Regarding Request for Clarification of Responses to the SAMA RAI Concerning Callaway Plant, Unit 1, LRA ML12298A4282012-10-26026 October 2012 Notice of Preapplication Meeting with Union Electric Company to Discuss Callaway Plant, Unit 1, License Amendment Request to Change Licensing Basis and Analysis of Integrated Head Assembly Consistent with Regulatory Guide 1.61 Revision 1 ML12292A1212012-10-22022 October 2012 Updated ETE Quarterly Report for Q4 2012 ML12262A3112012-10-0202 October 2012 Summary of Telephone Conference Call Held on September 14, 2012, Between NRC and Union Electric Company, Concerning the SAMA RAI for the Callaway Plant, Unit 1, LRA ML12234A5232012-08-24024 August 2012 Quarterly Report of Activity Related to Updated Evacuation Time Estimates ML12227A3472012-08-14014 August 2012 8/29/2012 Notice of Preapplication Meeting with Union Electric Company to Discuss Request for New Technical Specification Related to Class 1E Electrical Equipment Air Conditioning System at Callaway Plant, Unit 1 ML12227A3492012-08-14014 August 2012 8/29/2012 Notice of Preapplication Meeting with Union Electric Company to Discuss Request to Revise Technical Specification 3.7.9, Ultimate Heat Sink SR 3.7.9.1 and 3.7.9.2 at Callaway Plant, Unit 1 ML12167A5082012-06-15015 June 2012 Letter to the Honorable Jeannette Mott Oxford Related to the 10/21/2003, Shutdown at Callaway Plant ML1211502472012-05-0303 May 2012 Memo to File, Verbal Authorization, Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of Main Steam Isolation Valve Actuator Rupture Disks ML12089A0992012-04-11011 April 2012 Summary of Public Scoping Meetings Conducted Related to the Review of the Callaway Plant, Unit 1 License Renewal Application ML12041A4792012-02-24024 February 2012 03/14/2012-Notice of Forthcoming Meeting to Discuss the License Renewal Process and Environmental Scoping for Callaway Plant, Unit 1 ML12027A0202012-01-27027 January 2012 Acceptance of License Renewal Application, Callaway Plant Unit 1 ML1200300872011-12-29029 December 2011 Forthcoming Meeting with Petitioner Requesting Action Under 10 CFR 2.206 Regarding Blocking P-4/Low Tavg Feedwater Isolation Signal at Callaway Plant, Unit 1 ML1136304032011-12-29029 December 2011 Correction Notice of Forthcoming Meeting with Petitioner Requesting Action Under 10 CFR 2.206 ML1131200872011-11-16016 November 2011 Verbal Authorization Memorandum, Relief Request 13R-13, Alternative to Requirements for Performance of Second Successive Exam of C Cold Leg Safe-End to Elbow Weld, Third 10-Year Inservice Inspection ML11192A2362011-07-12012 July 2011 Notice of Closed Meeting with Callaway to Discuss Lessons Learned from the Recent Triennial Force-On-Force Exercise at the Callaway Nuclear Power Plant IR 05000483/20110072011-06-27027 June 2011 IR 05000483-11-007, on 03/21-05/13/11, Callaway Plant, Special Inspection for Turbine-driven Auxiliary Feedwater Pump Bearing Degradation ML1113202252011-05-12012 May 2011 Notice of Preapplication Meeting with Union Electric Company to Discuss Callaway Plant, Unit 1's Amendment Request to Adopt Risk-informed, Performance-Based Alternative Described in National Fire Protection Association Standard (NFPA) 805 ML1136103072011-05-0404 May 2011 CW-2011-06-Public Forms ML1109501212011-04-0505 April 2011 Notice of Meeting to Discuss NRC Reactor Oversight Process Annual Assessment of Callaway Plant ML1104001662011-02-22022 February 2011 Summary of Meeting with Union Electric Company to Discuss Licensee'S Planned Responses to Staff Requests for Additional Information Callaway Plant'S Request to Revise TS 3.3.2, ESFAS Instrumentation Functions ML1101204702011-01-12012 January 2011 Notice of Meeting with Union Electric Company to Discuss Licensee'S Planned Responses to Staff Requests for Additional Information Callaway Plant'S Request to Revise TS 3.3.2, ESFAS Instrumentation Functions ML1030202792010-11-0505 November 2010 Notice of Meeting with Union Electric Company to Discuss Licensee'S Planned Responses to Staff Requests for Additional Information Related to Callaway Plant'S Request to Revise TS 3.3.2, ESFAS Instrumentation Functions ML11363A1132010-08-0505 August 2010 Memo from M. Markley, NRR to M. Kotzalas, EDO on G20100476/EDATS: OEDO-2010-0609 - Briefing Package for Drop-In Visit by Union Electric Company Official with NRC Staff on August 13, 2010, for Callaway Plant ML1009105332010-04-0505 April 2010 U.S. Nuclear Regulatory Commission Staff Review of the Department of Homeland Security Consultation Reports ML0929300152009-10-20020 October 2009 Revised Notice of Meeting with Union Electric Company and Wolf Creek Nuclear Operating Company to Discuss NRC Requests for Additional Information on Generic Letter 2004-02 ML0928003162009-10-16016 October 2009 Notice of Meeting with Union Electric Company and Wolf Creek Nuclear Operating Company to Discuss NRC Requests for Additional Information on Generic Letter 2004-02 Sent 7/31/0209 and 8/27/2009, Respectively ML0924605592009-09-0404 September 2009 Notice of Meeting with Union Electric Company to Discuss a Proposed Risk Informed Change to Callaway, Unit 1, Technical Specifications ML0920306202009-07-31031 July 2009 Notice of Forthcoming Conference Call with Union Electric Company and Wolf Creek Nuclear Operating Company Re Draft Requests for Additional Information on Generic Letter 2004-02 for Callaway Plant and Wolf Creek Creek Generating Station ML0916801682009-06-17017 June 2009 Charter for Special Inspection Involving the Failure of the Turbine Driven Auxiliary Feedwater Pump to Start at the Callaway Plant 2022-06-06
[Table view] Category:Code Relief or Alternative
MONTHYEARML20225A2922020-08-12012 August 2020 Request to Use a Portion of a Later Edition of the ASME B&PV Code, Section XI ML19079A1482019-04-0101 April 2019 Request for Alternative I4R-05 to Reactor Vessel Nozzle Weld Examination Frequency Requirements (EPID L-2018-LLR-0051 ML18313A0692018-11-26026 November 2018 Request for Relief I4R-01 Related to the Inservice Inspection Program for Class 3 Buried High Density Polyethylene Piping ULNRC-06420, Request 14R-05 for Relief from Requirements of ASME Code Case N-770-2 Regarding Inspection Intervals for Reactor Vessel Nozzle Dissimilar Metal Welds2018-04-0909 April 2018 Request 14R-05 for Relief from Requirements of ASME Code Case N-770-2 Regarding Inspection Intervals for Reactor Vessel Nozzle Dissimilar Metal Welds ML17262A7002017-10-0303 October 2017 Request for Alternative I4R-04 Applicable to the Fourth 10-Year Inspection Program Interval ML17254A1202017-09-25025 September 2017 Request for Alternative No. PR-07 from the Requirements of the ASME Code for the Fourth 10-Year Inservice Testing Interval ML17058A4432017-03-0606 March 2017 Request for Alternative I4R-03 Applicable to the Fourth 10-Year Inservice Inspection Program Interval ML16223A7122016-08-30030 August 2016 Relief Request No. 13R-08 from Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds, for Piping Welds, Third 10-Year Inservice Inspection Interval ML16055A4642016-03-17017 March 2016 Relief Requests 13R-09 (Steam Generator Tubesheet Weld), 13R-11 (Pressurizer Welds) from Code Case N-460 and 13R-18 (SG Weld), from Appendix Viii Requirements, Third 10-Year Inservice Inspection Interval (CAC MF6735-MF6737) ML16027A1582016-01-29029 January 2016 Relief Request I4R-02 from Requirements of ASME Code Section XI, Table IWF-2500-1 for 100% Visual Examination of Class 1 Supports, Fourth 10-Year Inservice Inspection Interval ML15064A1252015-05-12012 May 2015 Request for Relief I4R-01 from ASME Code Requirements for Replacement of Class 3 Essential Service Water Buried Piping with High Density Polyethylene Piping, for the Fourth 10-year Inservice Testing Interval ML15035A1482015-02-10010 February 2015 Relief Request 13R-17, Proposed Alternative to ASME Code, Section XI Requirements, Which Extends Reactor Vessel Inservice Inspection Frequency from 10 to 20 Years, Third 10-Year Interval ML14239A0972014-09-0404 September 2014 Request for Relief I3R-15, ASME Code Class 1 Pressure-Retaining Piping/Components Leakage Testing at Full Pressure, Third 10-Year Inservice Inspection Interval ML14234A4512014-09-0404 September 2014 Relief Request I3R-16, Temporary Non-Code Repair of the Train a Component Cooling Water Heat Exchanger to Control ESW Leakage, Third 10-Year Inservice Inspection Interval ML14178A7692014-07-15015 July 2014 Requests for Relief PR-01, PR-02, PR-03, PR-04, and PR-06 (PR-05 Withdrawn), ASME OM Code Cases for Group a and B Pumps for Fourth 10-Year Inservice Testing Interval ML14027A0572014-01-29029 January 2014 Relief Request PR-07, Testing Frequency for Pumps and Valves, Third 10-year Inservice Testing Interval ML13246A3042013-08-30030 August 2013 Verbal Authorization Email, Relief Request PR-07, Testing Frequency for Pumps and Valves, Third 10-year Inservice Testing Interval ML13126A3202013-05-0707 May 2013 Summary of Telephone Conference, Verbal Authorization of Relief Request I3R-14. Proposed Alternative to ASME Code Requirements for Leakage Testing of RPV Head Flange Leakoff Lines, Third 10-Year ISI Interval. ML12258A0452012-09-18018 September 2012 Relief Request VR-01 from Requirements of ASME OM Code, Mandatory Appendix I, One-time Extension for 5-Year Replacement Interval, from 4/11/12 to 6/2013, Main Steam Isolation Valve Actuator Rupture Disks ML1211502472012-05-0303 May 2012 Memo to File, Verbal Authorization, Relief Request VR-01 from Requirements of ASME OM Code Mandatory Appendix I, One-time Extension Replacement of Main Steam Isolation Valve Actuator Rupture Disks ML1201907482012-02-16016 February 2012 Relief Request 13R-13, Alternative to ASME Code Section XI Requirements for Performance of Second Successive Exam of C Cold Leg Safe-End to Elbow Weld, Third 10-Year Inservice Inspection ML0831002882008-11-0707 November 2008 Relief Request 13R-10 Approved on October 31, 2008, for Third 10-Year Inservice Inspection Interval for Use of Polyethylene Pipe in Lieu of Carbon Steel Pipe in Buried Essential Service Water Piping System ML0818406062008-07-0303 July 2008 Approval of Second Extension Request for Corrective Actions GL 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors. ML0731114422007-12-10010 December 2007 Correction to Authorization of Relief Request ISI-39 for the Second 10-Year Inservice Inspection Interval ML0729803972007-10-30030 October 2007 Relief Request ISI-38, Reactor Pressure Vessel Inlet Safe-End to-Elbow Welds Proposed Alternative Examination for Second 10-Year Inservice Inspection Interval ML0724000922007-09-17017 September 2007 Issuance of Relief Requests (Rrs) ISI-36, ISI-37, and ISI-38 for Second Year Inservice Inspection (ISI) Interval ML0725504882007-08-30030 August 2007 10 CFR 50.55a Request: Proposed Alternative to ASME Section Xi Requirements for Replacement of Class 3 Buried Piping ML0715203292007-07-10010 July 2007 Request for Alternatives for Application of Structural Weld Overlays to Pressurizer Dissimilar Metal Nozzle Welds for Third 10-Year Inservice Inspection Program Interval ML0705803332007-03-15015 March 2007 Authorization of Relief Request No. ISI-33 for Second 10-Year and Third 10-Year ISI Interval ML0635203182007-01-18018 January 2007 Request for Relief No. ISI-35 for Second 10-year Inservice Inspection Interval ML0700303362007-01-18018 January 2007 Relief Request ISI-41 for the Second 10-year Inservice Inspection Interval ML0630604782006-12-0707 December 2006 Relief Request 13R-04 for the Third 10-Year Interval Inservice Inspection ML0629302822006-11-17017 November 2006 Relief Requests I3R-05 and I3R-06 for the Third Inservice Inspection Interval ULNRC-05183, Requests for Relief from ASME Section XI Code Inservice Examination Requirements2006-10-25025 October 2006 Requests for Relief from ASME Section XI Code Inservice Examination Requirements ML0614301312006-06-15015 June 2006 Relief, Third 10-Year Interval Inservice Inspection Program Relief Request I3R-02 ML0520802152005-08-18018 August 2005 Relief, Use a Subsequent Edition of ASME Code Examinations for the Third Inservice Inspection Interval ML0515302072005-06-22022 June 2005 6/22/05 Callaway, Unit 1 - Relief Requests ISI-24,ISI-25 and ISI-26 of the Second 10-Year Inservice Inspection (ISI) Interval (Tacs. MC4435 and MC4436) ML0507601292005-05-19019 May 2005 Relief, Request for Relief from Certain ASME Code Examinations for the Second Inservice Inspection Interval ULNRC-05092, Revision to Approve Request for Relief from ASME Section III Requirements Regarding Non-destructive Examination of Welds Performed Under Site Repair/Replacement Program2004-11-18018 November 2004 Revision to Approve Request for Relief from ASME Section III Requirements Regarding Non-destructive Examination of Welds Performed Under Site Repair/Replacement Program ULNRC-05049, Union Electric Company Callaway Plant Request for Relief from ASME Section XI Code Inservice Examination Requirements2004-09-0303 September 2004 Union Electric Company Callaway Plant Request for Relief from ASME Section XI Code Inservice Examination Requirements ML0414100712004-05-19019 May 2004 Relief, ASME Code Requirements on the Use of Weld Overlay Reinforcement to Restore Wall Thickness of ASME Class 2 Carbon Steel Main Feedwater Piping. ML0414100352004-05-19019 May 2004 Relief, Second Ten-Year Interval Inservice Inspection Program Relief Request to Use an Alternative Examination Method ULNRC-04993, Revision of Request for Relief from ASME Section XI Requirements in Order to Temporarily Restore Wall Thickness of ASME Class 2 Carbon Steel Main Feedwater Piping by Weld Overlay Reinforcement2004-05-0707 May 2004 Revision of Request for Relief from ASME Section XI Requirements in Order to Temporarily Restore Wall Thickness of ASME Class 2 Carbon Steel Main Feedwater Piping by Weld Overlay Reinforcement ML0409806642004-04-0707 April 2004 4/7/04 Callaway Plant - Request for Relief from ASME Code Requirements on the Use of Weld Overlay Reinforcement to Restore Wall Thickness of ASME Class 2 Carbon Steel Main Feedwater Piping ULNRC-04879, Requests for Relief Regarding Implementation of ASME Section XI Appendix VII Requirements2003-08-14014 August 2003 Requests for Relief Regarding Implementation of ASME Section XI Appendix VII Requirements ML0318305352003-07-0101 July 2003 Second Ten-Year Interval Inservice Inspection Program Relief Request to Use an Alternative Examination Method (Tac. MB6534) ML0134602652002-01-30030 January 2002 Relief, Application of Risk-Informed Inservice Inspection Program for the American Society of Mechanical Engineers Boilers and Pressure Vessel Code Class 1 and 2 TAC No MB1205) 2020-08-12
[Table view] |
Text
May 3, 2012 MEMORANDUM TO: Docket File FROM: N. Kalyanam, Project Manager /RA/
Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
CALLAWAY PLANT UNIT 1 - VERBAL AUTHORIZATION VR-01, PROPOSED ALTERNATIVE REGARDING ASME OM CODE REPLACEMENT INTERVAL FOR MAIN STEAM ISOLATION VALVE ACTUATOR RUPTURE DISKS (TAC NO. ME8319)
By letter dated March 30, 2012, as supplemented by letter dated April 19, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12090A501 and ML121150347, respectively), Union Electric Company, (the licensee) submitted alternative request VR-01 for the Callaway Plant, Unit 1, for U.S. Nuclear Regulatory Commission (NRC) review and approval.
This request pertains to inservice testing requirements for Main Steam Isolation Valve (MSIV) actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 at Callaway Plant, Unit 1. The licensee requested an alternative from the required replacement frequency requirement of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) Mandatory Appendix I, Paragraph I-1360, Test Frequency, Class 2 and 3 Nonreclosing Pressure Relief Devices, as required and conditioned by Title 10 of the Code of Federal Regulations Section 50.55a.
Specifically, an alternative was requested for the requirement to replace MSIV actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 every 5 years. Callaway Plant, Unit 1, had originally scheduled the rupture disks replacement during Refueling Outage 18, which began in October 2011. However, the work was removed from the outage scope based on an initial determination that the work could be done with the plant online subsequent to the outage. The rupture disks were scheduled to be replaced online in the spring of 2012 to meet the ASME OM Code requirement. However, the licensee determined that based on the 8-hour Technical Specification (TS) Limiting Conditions for Operations (LCO) and the time needed to replace the rupture disks online, the TS LCO completion time may be exceeded during this replacement activity. Therefore, the rupture disk replacement activity poses elevated risk to continued plant operations if it is performed online. Therefore, the licensee is proposing an alternative to extend the interval for replacing the rupture disks to the next plant outage providing plant conditions to replace the disks (i.e. Mode 4 or 5), but no later than the end of Refueling Outage 19, which is currently scheduled for June 2013.
Extending the replacement date until Refueling Outage 19 will not affect the functionality of the MSIVs and does not introduce any credible failure mechanism that would prevent the rupture disks from rupturing at a pressure needed for the MSIVs to perform their safety-related purpose.
Conclusion As set forth above, the NRC staff concludes that the proposed alternative described in alternative request VR-01 provides reasonable assurance that the MSIV actuator rupture disks ABPSE0001, ABPSE0002, ABPSE0003, and ABPSE0004 are operationally ready.
Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii), and is in compliance with the ASME OM Code requirements. Therefore, the NRC staff provides verbal authorization for the proposed alternatives described in request alternative VR-01 until the next plant outage providing plant conditions to replace the MSIV actuator rupture disks (i.e., Mode 4 or 5), but no later than the end of the Callaway Plant, Unit 1, Refueling Outage 19, which is currently scheduled for June 2013.
All other ASME Code requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
The participants in the telephone call were:
NRC Mike Markley, Branch Chief, NRR/DORL/LPL4)
Tony McMurtray, Branch Chief, NRR/DE/EPTB Bob Wolfgang, NRR/DE/EPTB Zach Hollcraft, R-IV/DRP/RPB-B/
Kaly Kalyanam, NRR/DORL/LPL4 UNION ELECTRIC COMPANY Brian Pae, Main Steam System Engineer Ben Oguejiofor, Inservice Testing Engineer Christine Norman, Mechanical Design Engineer Bryan Sprock, Engineering Fix-It-Now Engineer Tom Elwood, Regulatory Affairs and Licensing Supervisor Docket No. 50-483
ML121150247 *via email OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DE/EPTB/BC NRR/LPL4/BC NRR/LPL4/PM NAME NKalyanam JBurkhardt AMcMurtray* MMarkley NKalyanam DATE 4/25/12 4/25/12 4/23/12 5/3/12 5/3/12