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| {{#Wiki_filter:March 15, 2007Mr. Charles D. NaslundSenior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251 | | {{#Wiki_filter:March 15, 2007 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| CALLAWAY PLANT, UNIT 1 - AUTHORIZATION OF RELIEF REQUESTNO. ISI-33 FOR THE SECOND AND THIRD 10-YEAR INSERVICE INSPECTION INTERVALS (TAC NO. MD2033) | | CALLAWAY PLANT, UNIT 1 - AUTHORIZATION OF RELIEF REQUEST NO. ISI-33 FOR THE SECOND AND THIRD 10-YEAR INSERVICE INSPECTION INTERVALS (TAC NO. MD2033) |
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| ==Dear Mr. Naslund:== | | ==Dear Mr. Naslund:== |
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| By letters dated May 18 and December 12, 2006 (ULNRC-05291 and -05351), the UnionElectric Company (the licensee) submitted Relief Request (RR) No. ISI-33, which proposed analternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee proposed using a root mean square error criterion for sizing flaws that is greater than the ASME Code, Section XI, Appendix VIII, Supplements 2 and 10 acceptance criteria forexaminations performed from the inside surface of pressure boundary piping. The request is for the second 10-year inservice inspection (ISI) interval, which ended on December 18, 2005, and the third 10-year ISI interval, which began on December 19, 2005.Based on the enclosed safety evaluation, the Nuclear Regulatory Commission (NRC) staff hasdetermined that (1) the ASME Code-required examination coverage requirements are impractical for the subject weld listed in RR No. ISI-33, and (2) the requested relief from the ASME Code is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Therefore, pursuant to paragraph 50.55a(g)(6)(i) of Title 10 of the Code of Federal Regulations, the NRCstaff grants the relief in RR No. ISI-33 for the second 10-year ISI interval and third 10-year ISI interval at Callaway. All other ASME Code, Section XI, requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-partyreview by the Authorized Nuclear Inservice Inspector.Sincerely,/RA/David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-483 | | By letters dated May 18 and December 12, 2006 (ULNRC-05291 and -05351), the Union Electric Company (the licensee) submitted Relief Request (RR) No. ISI-33, which proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee proposed using a root mean square error criterion for sizing flaws that is greater than the ASME Code, Section XI, Appendix VIII, Supplements 2 and 10 acceptance criteria for examinations performed from the inside surface of pressure boundary piping. The request is for the second 10-year inservice inspection (ISI) interval, which ended on December 18, 2005, and the third 10-year ISI interval, which began on December 19, 2005. |
| | Based on the enclosed safety evaluation, the Nuclear Regulatory Commission (NRC) staff has determined that (1) the ASME Code-required examination coverage requirements are impractical for the subject weld listed in RR No. ISI-33, and (2) the requested relief from the ASME Code is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Therefore, pursuant to paragraph 50.55a(g)(6)(i) of Title 10 of the Code of Federal Regulations, the NRC staff grants the relief in RR No. ISI-33 for the second 10-year ISI interval and third 10-year ISI interval at Callaway. All other ASME Code, Section XI, 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. |
| | Sincerely, |
| | /RA/ |
| | David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483 |
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| ==Enclosure:== | | ==Enclosure:== |
| Safety Evaluation cc w/encl: See next page | | Safety Evaluation cc w/encl: See next page |
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| ML070580333NRR -028 Subject to EditOFFICENRR/LPL4/PMNRR/LPL4/LACPNB/BCOGCNloNRR/LPL4/BCNAMEJDonohewLFeizollahiTChanJCampbellDTerao DATE3/7/073/15/072/7/073/13/073/15/07 June 2006Callaway Plant, Unit 1 cc:Professional Nuclear Consulting, Inc.
| | ML070580333 NRR -028 Subject to Edit OFFICE NRR/LPL4/PM NRR/LPL4/LA CPNB/BC OGC Nlo NRR/LPL4/BC NAME JDonohew LFeizollahi TChan JCampbell DTerao DATE 3/7/07 3/15/07 2/7/07 3/13/07 3/15/07 Callaway Plant, Unit 1 cc: |
| 19041 Raines Drive Derwood, MD 20855John O'Neill, Esq.Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W. | | Professional Nuclear Consulting, Inc. Mr. Dan I. Bolef, President 19041 Raines Drive Kay Drey, Representative Derwood, MD 20855 Board of Directors Coalition for the Environment John ONeill, Esq. 6267 Delmar Boulevard Pillsbury Winthrop Shaw Pittman LLP University City, MO 63130 2300 N. Street, N.W. |
| Washington, D.C. 20037Mr. Keith A. Mills, Supervising EngineerRegional Regulatory Affairs/Safety Analysis AmerenUE P.O. Box 620 Fulton, MO 65251U.S. Nuclear Regulatory CommissionResident Inspector Office | | Washington, D.C. 20037 Mr. Lee Fritz, Presiding Commissioner Callaway County Court House Mr. Keith A. Mills, Supervising Engineer 10 East Fifth Street Regional Regulatory Affairs/Safety Analysis Fulton, MO 65151 AmerenUE P.O. Box 620 Mr. David E. Shafer Fulton, MO 65251 Superintendent, Licensing Regulatory Affairs U.S. Nuclear Regulatory Commission AmerenUE Resident Inspector Office P.O. Box 66149, MC 470 8201 NRC Road St. Louis, MO 63166-6149 Steedman, MO 65077-1302 Manager, Regulatory Affairs Mr. Les H. Kanuckel AmerenUE Manager, Quality Assurance P.O. Box 620 AmerenUE Fulton, MO 65251 P.O. Box 620 Fulton, MO 65251 Mr. Keith G. Henke, Planner Division of Community and Public Health Missouri Public Service Commission Office of Emergency Coordination Governor Office Building 930 Wildwood P.O. Box 570 200 Madison Street Jefferson City, MO 65102 Jefferson City, MO 65102-0360 Certrec Corporation Regional Administrator, Region IV 4200 South Hulen, Suite 630 U.S. Nuclear Regulatory Commission Fort Worth, TX 76109 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Director, Missouri State Emergency Management Agency Mr. H. Floyd Gilzow P.O. Box 116 Deputy Director for Policy Jefferson City, MO 65102-0116 Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839 June 2006 |
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| 8201 NRC Road Steedman, MO 65077-1302Mr. Les H. KanuckelManager, Quality Assurance AmerenUE P.O. Box 620 Fulton, MO 65251Missouri Public Service CommissionGovernor Office Building 200 Madison Street Jefferson City, MO 65102-0360Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005Mr. H. Floyd GilzowDeputy Director for Policy Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176Mr. Rick A. MuenchPresident and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839Mr. Dan I. Bolef, PresidentKay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, MO 63130Mr. Lee Fritz, Presiding CommissionerCallaway County Court House 10 East Fifth Street Fulton, MO 65151Mr. David E. Shafer Superintendent, Licensing Regulatory Affairs AmerenUE P.O. Box 66149, MC 470 St. Louis, MO 63166-6149Manager, Regulatory AffairsAmerenUE P.O. Box 620 Fulton, MO 65251Mr. Keith G. Henke, PlannerDivision of Community and Public Health Office of Emergency Coordination 930 Wildwood P.O. Box 570 Jefferson City, MO 65102Certrec Corporation4200 South Hulen, Suite 630 Fort Worth, TX 76109Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO RELIEF REQUEST NO. ISI-33UNION ELECTRIC COMPANYCALLAWAY PLANT, UNIT 1DOCKET NO. 50-48
| | SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST NO. ISI-33 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 |
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| ==31.0INTRODUCTION== | | ==1.0 INTRODUCTION== |
| By letters dated May 18 and December 12, 2006 (Agencywide Documents Access andManagement System (ADAMS) Accession Nos. ML061460043 and ML063530466, respectively), the Union Electric Company (the licensee) submitted Relief Request (RR)No. ISI-33, which proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee proposed using a root mean square (RMS) error criterion for depth-sizing flaws that is greater than the ASME Code, Section XI, Appendix VIII,Supplements 2 and 10 acceptance criteria for examinations performed from the inside surface of reactor coolant system pressure boundary piping. The licensee's request is for the second 10-year inservice inspection (ISI) interval, which ended on December 18, 2005, and the third 10-year ISI interval, which began on December 19, 2005.
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| ==2.0REGULATORY EVALUATION==
| | By letters dated May 18 and December 12, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML061460043 and ML063530466, respectively), the Union Electric Company (the licensee) submitted Relief Request (RR) |
| In accordance with Paragraph 50.55a(g)(4) of Title 10 of the Code of Federal Regulations(10 CFR), ASME Code Class 1, 2, and 3 components must meet the requirements set forth in ASME Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plants Components,"
| | No. ISI-33, which proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee proposed using a root mean square (RMS) error criterion for depth-sizing flaws that is greater than the ASME Code, Section XI, Appendix VIII, Supplements 2 and 10 acceptance criteria for examinations performed from the inside surface of reactor coolant system pressure boundary piping. The licensees request is for the second 10-year inservice inspection (ISI) interval, which ended on December 18, 2005, and the third 10-year ISI interval, which began on December 19, 2005. |
| to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that all inservice examinations and system pressure tests conducted during the first 10-year interval, and subsequent intervals, comply with the requirements in the latest edition and addenda of ASME Code, Section XI, incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 10-year interval.For Callaway, the licensee stated that the code of record for the second 10-year ISI interval isthe 1989 Edition of Section XI of the ASME Code. For the third 10-year ISI interval, the Code of record is the 1998 Edition through the 2000 Addenda of Section XI of the ASME Code.Alternatives to requirements may be authorized or relief granted by the Nuclear RegulatoryCommission (NRC) pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or 10 CFR 50.55a(g)(6)(i). In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives would provide an acceptable level of safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of 1NRC Safety Evaluation dated April 7, 2004, which the letter authorizing relief request ISI-27, ADAMS Accession No. ML0410005162.quality and safety; or (3) conformance is impractical for the facility. Pursuant to 10 CFR50.55a(g)(4)(iv), ISI items may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to Commission approval. Portions of editions and addenda may be used provided that related requirements of the respective editions and addenda are met.
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| ==3.0TECHNICAL EVALUATION== | | ==2.0 REGULATORY EVALUATION== |
| FOR RR NO. ISI-333.1Affected ComponentsThe licensee stated that the relief request is specific to pipe weld 2-BB-01-F302. | | |
| 3.2Applicable CodeAs stated in the application, for the second 10-year ISI interval, the ISI code of record is the1989 Edition with no Addenda, ASME Code, Section XI, Appendix VIII, Supplement s 2 and 10,Paragraph 3.2(b) (for both supplements) which states that the RMS error for flaw depths estimated by ultrasonic testing (UT) shall not exceed 0.125 inches.For the third 10-year ISI interval, the ISI Code of record is the 1998 Edition with 2000 Addenda,ASME Code, Section XI, Appendix VIII, Supplements 2 and 10, Paragraph 3.2(b).3.3Proposed InspectionThe licensee proposed using the Electric Power Research Institute (EPRI) PerformanceDemonstration Initiative (PDI) program for the implementation of Appendix VIII, Supplement 2in coordination with Supplement 10 1, Paragraph 3.2(b), 0.245-inch RMS criterion in lieu of theASME Code-required 0.125-inch RMS criterion because of the impracticality in the licensee achieving the ASME Code-required criterion. At this time, no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe inside diameter (ID). The licensee would use the qualifications of Appendix VIII, Supplement 10, as administrated by thePDI, as described in its RR ISI-27, which was authorized by NRC in its letter dated April 17, 2004.The difference between the 0.245-inch RMS error and the ASME Code-required 0.125-inchRMS error (i.e., 0.82-inch difference) will be added to the measured flaw size for the purpose of flaw evaluation.3.4Licensee's Basis for ImpracticalityThe licensee's vendor performed a combined Appendix VIII, Supplements 2 and 10 (identifiedin the licensee's submittal of May 18, 2006, as Supplement 14) performance demonstration that 2Summary of Public Meeting Held May 24 and 25, 2005 with EPRI-PDI Representatives,dated September 8, 2005, ADAMS Accession No. ML052580257.did not satisfy the ASME Code-required 0.125-inch RMS depth-sizing error criterion. Thevendor actually demonstrated a 0.245-inch RMS depth-sizing error for the combined Supplements 2 and 10. Currently, no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe ID, and it is, therefore, impractical at this time to require the licensee to meet this criterion.3.5EvaluationThe licensee's ISI code of record for the second 10-year ISI interval is the 1989 Edition with noaddenda. The regulation 10 CFR 50.55a(g)(6)(ii)(C)(2) requires that licensees with the 1989 Edition and earlier editions and addenda ISI code of record use the 1995 Edition with 1996 Addenda of Section XI, Appendix VIII for UT examinations. For the third 10-year ISI interval,the licensee is using the 1998 Edition with 2000 Addenda. The licensee's vendor performed a coordinated Supplements 2 and 10 (licensee's Supplement 14) performance demonstration as implemented by the PDI program.The ASME Code requires that the maximum error for flaw-depth measurements, whencompared to the true flaw depth, must not exceed 0.125-inch RMS error. The nuclear power industry is in the process of qualifying personnel and procedures with a coordinated Appendix VIII, Supplement 2 and Supplement 10 performance demonstration as implementedby the PDI program. However, to date, no personnel or procedure has yet achieved the ASME Code-required 0.125-inch RMS maximum error criterion for performance demonstrations performed from the pipe ID. The difficulties are associated with the surface roughness of the field welds. As licensees perform ID UT examinations, they are taking profilometry measurements which can be used to assess the representativeness of the test specimens used to establish the vendor's RMS error criterion | | In accordance with Paragraph 50.55a(g)(4) of Title 10 of the Code of Federal Regulations (10 CFR), ASME Code Class 1, 2, and 3 components must meet the requirements set forth in ASME Code, Section XI, Rules for Inservice Inspection of Nuclear Power Plants Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that all inservice examinations and system pressure tests conducted during the first 10-year interval, and subsequent intervals, comply with the requirements in the latest edition and addenda of ASME Code, Section XI, incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 10-year interval. |
| : 2. At this time, achieving a 0.125-inch RMS errorcriterion is impractical because no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe ID. The licensee has stated that the vendor has achieved a 0.245-inch RMS error for the coordinated Supplement 2 and Supplement 10 performance demonstrations. The licensee proposed adding the depth-sizing difference between the performance demonstrated error of 0.245-inch and the Code-required error of 0.125-inch to the measured flaw size. Based on its evaluation, the NRC staff finds that compliance with the ASME Code-requiredRMS error criterion is impractical at this time and that adding the difference between the demonstrated depth sizing RMS error and the ASME Code-required depth sizing RMS error when determining acceptance to the standards specified in ASME Code, Section XI, IWB-3500, provides reasonable assurance of structural integrity.3.6ConclusionBased on the above evaluation, the NRC staff concludes that compliance with the ASMECode-required RMS depth-sizing error value is impractical because no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer on the pipe ID, and that the proposed inspection, as implemented by the PDI program in a coordinated performance demonstration, provides reasonable assurance of structural integrity. Therefore, based on its evaluation, theNRC staff concludes that the relief is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest, given the consideration of the burden upon the licensee. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i),
| | For Callaway, the licensee stated that the code of record for the second 10-year ISI interval is the 1989 Edition of Section XI of the ASME Code. For the third 10-year ISI interval, the Code of record is the 1998 Edition through the 2000 Addenda of Section XI of the ASME Code. |
| the relief is granted for Callaway for the second 10-year ISI interval and third 10-year ISI interval for the subject weld.All other requirements of the ASME Code, Section XI, for which relief has not been specificallyrequested remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. Principal Contributor: Don Naujock Date: March 15, 2007}} | | Alternatives to requirements may be authorized or relief granted by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or 10 CFR 50.55a(g)(6)(i). In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives would provide an acceptable level of safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of |
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| | quality and safety; or (3) conformance is impractical for the facility. Pursuant to 10 CFR 50.55a(g)(4)(iv), ISI items may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to Commission approval. Portions of editions and addenda may be used provided that related requirements of the respective editions and addenda are met. |
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| | ==3.0 TECHNICAL EVALUATION== |
| | FOR RR NO. ISI-33 3.1 Affected Components The licensee stated that the relief request is specific to pipe weld 2-BB-01-F302. |
| | 3.2 Applicable Code As stated in the application, for the second 10-year ISI interval, the ISI code of record is the 1989 Edition with no Addenda, ASME Code, Section XI, Appendix VIII, Supplements 2 and 10, Paragraph 3.2(b) (for both supplements) which states that the RMS error for flaw depths estimated by ultrasonic testing (UT) shall not exceed 0.125 inches. |
| | For the third 10-year ISI interval, the ISI Code of record is the 1998 Edition with 2000 Addenda, ASME Code, Section XI, Appendix VIII, Supplements 2 and 10, Paragraph 3.2(b). |
| | 3.3 Proposed Inspection The licensee proposed using the Electric Power Research Institute (EPRI) Performance Demonstration Initiative (PDI) program for the implementation of Appendix VIII, Supplement 2 in coordination with Supplement 101, Paragraph 3.2(b), 0.245-inch RMS criterion in lieu of the ASME Code-required 0.125-inch RMS criterion because of the impracticality in the licensee achieving the ASME Code-required criterion. At this time, no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe inside diameter (ID). The licensee would use the qualifications of Appendix VIII, Supplement 10, as administrated by the PDI, as described in its RR ISI-27, which was authorized by NRC in its letter dated April 17, 2004. |
| | The difference between the 0.245-inch RMS error and the ASME Code-required 0.125-inch RMS error (i.e., 0.82-inch difference) will be added to the measured flaw size for the purpose of flaw evaluation. |
| | 3.4 Licensees Basis for Impracticality The licensees vendor performed a combined Appendix VIII, Supplements 2 and 10 (identified in the licensees submittal of May 18, 2006, as Supplement 14) performance demonstration that 1 |
| | NRC Safety Evaluation dated April 7, 2004, which the letter authorizing relief request ISI-27, ADAMS Accession No. ML0410005162. |
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| | did not satisfy the ASME Code-required 0.125-inch RMS depth-sizing error criterion. The vendor actually demonstrated a 0.245-inch RMS depth-sizing error for the combined Supplements 2 and 10. Currently, no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe ID, and it is, therefore, impractical at this time to require the licensee to meet this criterion. |
| | 3.5 Evaluation The licensees ISI code of record for the second 10-year ISI interval is the 1989 Edition with no addenda. The regulation 10 CFR 50.55a(g)(6)(ii)(C)(2) requires that licensees with the 1989 Edition and earlier editions and addenda ISI code of record use the 1995 Edition with 1996 Addenda of Section XI, Appendix VIII for UT examinations. For the third 10-year ISI interval, the licensee is using the 1998 Edition with 2000 Addenda. The licensees vendor performed a coordinated Supplements 2 and 10 (licensees Supplement 14) performance demonstration as implemented by the PDI program. |
| | The ASME Code requires that the maximum error for flaw-depth measurements, when compared to the true flaw depth, must not exceed 0.125-inch RMS error. The nuclear power industry is in the process of qualifying personnel and procedures with a coordinated Appendix VIII, Supplement 2 and Supplement 10 performance demonstration as implemented by the PDI program. However, to date, no personnel or procedure has yet achieved the ASME Code-required 0.125-inch RMS maximum error criterion for performance demonstrations performed from the pipe ID. The difficulties are associated with the surface roughness of the field welds. As licensees perform ID UT examinations, they are taking profilometry measurements which can be used to assess the representativeness of the test specimens used to establish the vendors RMS error criterion2. At this time, achieving a 0.125-inch RMS error criterion is impractical because no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe ID. The licensee has stated that the vendor has achieved a 0.245-inch RMS error for the coordinated Supplement 2 and Supplement 10 performance demonstrations. The licensee proposed adding the depth-sizing difference between the performance demonstrated error of 0.245-inch and the Code-required error of 0.125-inch to the measured flaw size. |
| | Based on its evaluation, the NRC staff finds that compliance with the ASME Code-required RMS error criterion is impractical at this time and that adding the difference between the demonstrated depth sizing RMS error and the ASME Code-required depth sizing RMS error when determining acceptance to the standards specified in ASME Code, Section XI, IWB-3500, provides reasonable assurance of structural integrity. |
| | 3.6 Conclusion Based on the above evaluation, the NRC staff concludes that compliance with the ASME Code-required RMS depth-sizing error value is impractical because no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer on the pipe ID, and that the proposed inspection, as implemented by the PDI program in a coordinated performance demonstration, 2 |
| | Summary of Public Meeting Held May 24 and 25, 2005 with EPRI-PDI Representatives, dated September 8, 2005, ADAMS Accession No. ML052580257. |
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| | provides reasonable assurance of structural integrity. Therefore, based on its evaluation, the NRC staff concludes that the relief is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest, given the consideration of the burden upon the licensee. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i), |
| | the relief is granted for Callaway for the second 10-year ISI interval and third 10-year ISI interval for the subject weld. |
| | All other requirements of the ASME Code, Section XI, for which relief has not been specifically requested remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. |
| | Principal Contributor: Don Naujock Date: March 15, 2007}} |
Letter Sequence Other |
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MONTHYEARULNRC-05295, Response Update to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors2006-05-30030 May 2006
Response Update to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
Project stage: Request
ULNRC-05293, Revision to Technical Specification 3.5.2, ECCS - Operating, and 3.6.7, Recirculation Fluid Ph Control System.2006-05-30030 May 2006
Revision to Technical Specification 3.5.2, ECCS - Operating, and 3.6.7, Recirculation Fluid Ph Control System.
Project stage: Request
ULNRC-05347, Response to Request for Additional Information Revision to Technical Specification 3.5.2, ECCS - Operating.2006-11-22022 November 2006
Response to Request for Additional Information Revision to Technical Specification 3.5.2, ECCS - Operating.
Project stage: Response to RAI
ULNRC-05351, Response to Request for Additional Information Regarding 10 CFR 50.55a Request ISI-33 (Request for Relief from ASME Section XI Inservice Inspection Qualification Requirements)2006-12-12012 December 2006
Response to Request for Additional Information Regarding 10 CFR 50.55a Request ISI-33 (Request for Relief from ASME Section XI Inservice Inspection Qualification Requirements)
Project stage: Response to RAI
ULNRC-05353, Clarifying Information Regarding Application for License Amendment to Revise Technical Specification 3.6.7, Recirculation Fluid Ph Control System.2006-12-19019 December 2006
Clarifying Information Regarding Application for License Amendment to Revise Technical Specification 3.6.7, Recirculation Fluid Ph Control System.
Project stage: Request
ML0705206142007-02-21021 February 2007
Tech Spec Pages for Amendment 180 Regarding Replacing Containment Sump Trash Racks and Screens with Strainers and Relocate the Containment Ph Control System from Current Location
Project stage: Acceptance Review
ML0634200472007-02-21021 February 2007
License Amendment 180 Regarding Replacing Containment Sump Trash Racks and Screens with Strainers and Relocate the Containment Ph Control System from Current Location
Project stage: Approval
ML0705803332007-03-15015 March 2007
Authorization of Relief Request No. ISI-33 for Second 10-Year and Third 10-Year ISI Interval
Project stage: Other
ML0708710142007-03-29029 March 2007
Correction to Authorization of Relief Request No. ISI-33 for the Second and Third 10-Year Inservice Inspection Intervals
Project stage: Other
ML0710103542007-04-18018 April 2007
Correction to Amendment No. 180 Replacing Containment Sump Trash Racks and Screens with Strainers and Relocate Containment Ph Control System from Current Location
Project stage: Other
2006-05-30
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Category:Code Relief or Alternative
MONTHYEARML24225A1012024-08-13013 August 2024
Authorization and Safety Evaluation for Alternative Request C3R-01
ML24052A3662024-02-26026 February 2024
Regulatory Audit Plan in Support of Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections
ML20225A2922020-08-12012 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)
2024-08-13
[Table view]
Category:Letter
MONTHYEARIR 05000483/20240032024-10-23023 October 2024
Integrated Inspection Report 05000483/2024003
IR 05000483/20240132024-10-21021 October 2024
Design Basis Assurance Inspection (Programs) Inspection Report 05000483/2024013
IR 05000483/20244012024-10-0909 October 2024
Material Control and Accounting Program Inspection Report 05000483/2024401 Public
ULNRC-06901, Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter)2024-10-0101 October 2024
Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter)
ML24247A3042024-09-11011 September 2024
Regulatory Audit Questions for License Renewal Commitments 34 and 35 (EPID L-2024-LRO-0009) - Non-Proprietary
IR 05000483/20244032024-08-28028 August 2024
Security Baseline Inspection 05000483-2024-403
IR 05000483/20240052024-08-14014 August 2024
Updated Inspection Plan for Callaway Plant (Report 05000483/2024005)
IR 05000483/20253012024-08-0505 August 2024
Notification of NRC Initial Operator Licensing Examination 05000483/2025301
ML24212A2822024-08-0202 August 2024
Regulatory Audit Summary Concerning Review of Request No. C3R-01 for Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections
IR 05000483/20240022024-07-18018 July 2024
And Independent Spent Fuel Storage Installation Integrated Inspection Report 05000483/2024002 and 07201045/2024001
ML24185A1032024-07-16016 July 2024
2024 Biennial Problem Identification and Resolution Inspection Report
ULNRC-06891, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00052024-06-26026 June 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0005
ULNRC-06892, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00062024-06-26026 June 2024
Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0006
ULNRC-06884, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00022024-06-12012 June 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0002
ULNRC-06885, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00032024-06-12012 June 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0003
ULNRC-06886, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00042024-06-12012 June 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0004
ML24144A0492024-06-11011 June 2024
Requests for Relief from ASME OM Code Pump and Valve Testing Requirements for Fifth 120-Month Inservice Testing Interval
ML24158A5222024-06-0606 June 2024
Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition (LDCN 24-0008)
ML24178A1132024-06-0606 June 2024
Ameren Missouris Intent to Adopt Revision 1 to Amendment 0 of Certificate of Compliance No. 1040 as Applicable to the ISFSI at the Callaway Plant Site
ML24143A1632024-05-23023 May 2024
Independent Spent Fuel Storage Installation Registration of Dry Spent Storage Canister HGMPC0001
ML24137A2342024-05-16016 May 2024
Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Storage Canister HGMPC0011
ULNRC-06882, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00122024-05-16016 May 2024
Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0012
ML24122A1502024-05-0707 May 2024
Audit Plan to Support Review of Steam Generator License Renewal Response to Commitment Nos 34 and 35
IR 05000483/20244022024-05-0606 May 2024
Security Baseline Inspection Report 05000483/2024402 (Full Report)
ULNRC-06877, Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 252024-05-0606 May 2024
Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 25
ULNRC-06856, CFR 50.59 and 10 CFR 72.48 Summary Report2024-05-0101 May 2024
CFR 50.59 and 10 CFR 72.48 Summary Report
IR 05000483/20240112024-05-0101 May 2024
NRC Post-Approval Site Inspection for License Renewal (Phase 2) Report 05000483/2024011
ULNRC-06869, Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report2024-04-30030 April 2024
Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report
ML24122A1132024-04-30030 April 2024
Submittal of Callaway, Unit 1, 2023 Annual Radioactive Effluent Release Report
ULNRC-06876, Registration of Dry Spent Fuel Storage Canister HGMPC00102024-04-25025 April 2024
Registration of Dry Spent Fuel Storage Canister HGMPC0010
ULNRC-06866, Submittal of Cycle 26 Commitment Change Summary Report2024-04-17017 April 2024
Submittal of Cycle 26 Commitment Change Summary Report
ULNRC-06871, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00072024-04-17017 April 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0007
ULNRC-06872, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00082024-04-17017 April 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0008
ML24108A1082024-04-17017 April 2024
Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0009
IR 05000483/20240012024-04-16016 April 2024
Integrated Inspection Report 05000483/2024001
IR 05000483/20244042024-04-0909 April 2024
Cyber Security Inspection Report 05000483/2024404
ML24088A3212024-04-0101 April 2024
Notification of Commercial Grade Dedication Inspection (05000483/2024013) and Request for Information
ML24086A5132024-03-26026 March 2024
CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions
ULNRC-06863, Submittal of Annual Exposure Report for 20232024-03-20020 March 2024
Submittal of Annual Exposure Report for 2023
ML24079A1622024-03-19019 March 2024
Re Nuclear Property Insurance Reporting
ML24066A1932024-03-0707 March 2024
2024 Callaway Plant Notification of Biennial Problem Identification and Resolution Inspection and Request for Information
ULNRC-06852, Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 262024-03-0505 March 2024
Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 26
IR 05000483/20230062024-02-28028 February 2024
Annual Assessment Letter for Callaway Plant Report 05000483/2023006
ML24052A3662024-02-26026 February 2024
Regulatory Audit Plan in Support of Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections
IR 05000483/20230022024-02-21021 February 2024
Amended Integrated Inspection Report 05000483/2023002
ULNRC-06858, Completion of License Renewal Activities Prior to Entering the Period of Extended Operation2024-02-21021 February 2024
Completion of License Renewal Activities Prior to Entering the Period of Extended Operation
ML24036A1712024-02-20020 February 2024
Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0079 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting))
ULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024
Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717
ML24008A0552024-01-19019 January 2024
Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code (EPID L-2023-LLR- 0061)
IR 05000483/20230042024-01-19019 January 2024
– Integrated Inspection Report 05000483/2023004
2024-09-11
[Table view]
Category:Safety Evaluation
MONTHYEARML23353A1712024-01-18018 January 2024
Issuance of Amendment No. 237 to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6
ML23347A1212024-01-11011 January 2024
Issuance of Amendment No. 236 to Adopt TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Volume Values to Licensee Control EPID L-2023-LLA-0046)
ML23234A1522023-10-0505 October 2023
Exemption from the Requirements of 10 CFR Part 50, Section 50.46, and Appendix K Regarding Use of M5 Cladding Material (EPID L-2022-LLE-0030) (Letter)
ML23240A3692023-10-0505 October 2023
Issuance of Amendment No. 235 to Revise Technical Specifications to Use of Framatome Gaia Fuel (EPID L-2022-LLA-0150) (Non-Proprietary)
ML23228A0252023-09-25025 September 2023
Issuance of Amendment No. 234 to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies
ML23261C3852023-09-25025 September 2023
Safety Evaluation for Operating Quality Assurance Manual Revision 36A
ML23166B0882023-09-20020 September 2023
Issuance of Amendment No. 233 for Adoption of Alternative Source Term and Revision of Technical Specifications
ML22361A0702023-02-24024 February 2023
Issuance of Amendment No. 231 for Revision to Radiological Emergency Response Plan Regarding Response and Notification Goals
ML23019A1752023-01-30030 January 2023
Issuance of Amendment No. 230 to Revise Technical Specifications to Adopt TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections
ML22301A0072022-12-0202 December 2022
Issuance of Amendment No. 229 to Revise Technical Specifications to Adopt TSTF-505, Revision 2, and TSTF-439, Revision 2
ML22220A1302022-10-21021 October 2022
Exemptions from the Requirements of 10 CFR 50.46 and 10 CFR Part 50 Appendix a, General Design Criteria 35, 38, and 41 (EPID L-2021-LLE-0021) (Cover Letter)
ML22220A1322022-10-21021 October 2022
Issuance of Amendment No. 228 Re; Revise Technical Specifications to Address Generic Safety Isusue-191 and Respond to Generic Letter 2004-02 Using Risk-Informed Approach
ML22053A2832022-04-0707 April 2022
Issuance of Amendment No. 227 Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler TSTF-529, Revision 4, Clarify Use and Application Rules
ML21344A0052021-12-29029 December 2021
Issuance of Amendment No. 226 Regarding Adoption of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Plants
ML21053A1262021-03-24024 March 2021
Issuance of Amendment No. 225 to Revise Technical Specification Administrative Control 5.3.1 to Remove Details Specified for the Qualification of Certain Positions within the Unit Staff
ML20218A4102020-11-0303 November 2020
Issuance of Amendment No. 224 Performance Based Method Alternative for Thermal Insulation Material
ML20246G5702020-10-16016 October 2020
Issuance of Amendment No. 223 One-Time Deferral of the Steam Generator Tube Inspections
ML20230A3872020-08-31031 August 2020
Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI
ML20216A6812020-08-0606 August 2020
Operating Quality Assurance Manual Change Revision 34B (EPID L-2020-LLQ-0004 (COVID-19))
ML20141L7452020-06-0808 June 2020
Operating Quality Assurance Manual Change Revision 34A
ML20107H9782020-04-20020 April 2020
COVID-19 Relief Request CC-01 Containment Tendon Inspection
ML19283C4812019-12-0606 December 2019
Issuance of Amendment No. 221 Main Turbine Control Slave Relay Testing
ML19158A2902019-07-30030 July 2019
Issuance of Amendment No. 220 Regarding Emergency Action Level Scheme Changes
ML19073A0012019-04-18018 April 2019
Issuance of Amendment No. 219 to Add New Technical Specification 3.7.20, Class 1E Electrical Equipment Air Conditioning (A/C) System
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
ML18124A0262018-05-30030 May 2018
Issuance of Amendment No. 218 FSAR Revision Compliance with Regulatory Guide 1.106 Regarding MOV Thermal Overload Protection
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
ML17236A0822017-09-15015 September 2017
Issuance of Amendment No. 217 Replacement of Methodology in Technical Specification 5.6.5, Core Operating Limits Report (Colr),
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 -
ML17058A4432017-03-0606 March 2017
Request for Alternative I4R-03 Applicable to the Fourth 10-Year Inservice Inspection Program Interval
ML17010A3322017-02-0202 February 2017
Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
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
ML16089A1672016-04-0101 April 2016
Review and Approval of Quality Assurance Plan Change Per Nuclear Energy Institute (NEI) 14-05A, Revision 1
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)
ML16020A5162016-02-29029 February 2016
Issuance of Amendment No. 216, Revise Technical Specification (TS) 2.1.1.1 and TS 5.6.5, to Remove Uncertainties from Departure from Nucleate Boiling Ratio Safety Limit and Adopt WCAP-14565-P-A Methodology
ML15324A1142016-02-0202 February 2016
Issuance of Amendment No. 215, Adopt Technical Specification Task Force (TSTF) Traveler TSTF-510, Revision 2, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection
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
ML15328A0592016-01-28028 January 2016
Issuance of Amendment No. 214, Request to Revise Operating License Condition Related to Cyber Security Plan Milestone 8 Full Implementation Date
ML15258A5102015-10-28028 October 2015
Issuance of Amendment No. 213, Adopt Technical Specification Task Force Traveler TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation
ML15251A4932015-10-0707 October 2015
Issuance of Amendment No. 212, Request to Upgrade the Emergency Action Level Scheme by Adopting Nuclear Energy Institute NEI 99-01, Revision 6
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
ML15064A0282015-03-31031 March 2015
Issuance of Amendment No. 211, Request to Revise Final Safety Analysis Report Standard Plant Section 3.6 for High Density Polyethylene (Hdpe) Crack Exclusion
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
ML14350B2392015-01-20020 January 2015
Issuance of Amendment No. 210, Revise Technical Specification LCO 3.4.12, Cold Overpressure Mitigation System (Coms), to Clarify No Limitation on Normal Charging Pump Use During Modes 4-6
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
ML14175A3902014-07-0101 July 2014
Issuance of Amendment No. 209, Adoption of Technical Specification Task Force Change Traveler TSTF-522-A, Revision 0, Revise Ventilation System to Operate for 10 Hours Per Month, Using CLIIP
ML14027A0572014-01-29029 January 2014
Relief Request PR-07, Testing Frequency for Pumps and Valves, Third 10-year Inservice Testing Interval
2024-01-18
[Table view] |
Text
March 15, 2007 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - AUTHORIZATION OF RELIEF REQUEST NO. ISI-33 FOR THE SECOND AND THIRD 10-YEAR INSERVICE INSPECTION INTERVALS (TAC NO. MD2033)
Dear Mr. Naslund:
By letters dated May 18 and December 12, 2006 (ULNRC-05291 and -05351), the Union Electric Company (the licensee) submitted Relief Request (RR) No. ISI-33, which proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee proposed using a root mean square error criterion for sizing flaws that is greater than the ASME Code,Section XI, Appendix VIII, Supplements 2 and 10 acceptance criteria for examinations performed from the inside surface of pressure boundary piping. The request is for the second 10-year inservice inspection (ISI) interval, which ended on December 18, 2005, and the third 10-year ISI interval, which began on December 19, 2005.
Based on the enclosed safety evaluation, the Nuclear Regulatory Commission (NRC) staff has determined that (1) the ASME Code-required examination coverage requirements are impractical for the subject weld listed in RR No. ISI-33, and (2) the requested relief from the ASME Code is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Therefore, pursuant to paragraph 50.55a(g)(6)(i) of Title 10 of the Code of Federal Regulations, the NRC staff grants the relief in RR No. ISI-33 for the second 10-year ISI interval and third 10-year ISI interval at Callaway. All other ASME Code,Section XI, 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.
Sincerely,
/RA/
David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosure:
Safety Evaluation cc w/encl: See next page
ML070580333 NRR -028 Subject to Edit OFFICE NRR/LPL4/PM NRR/LPL4/LA CPNB/BC OGC Nlo NRR/LPL4/BC NAME JDonohew LFeizollahi TChan JCampbell DTerao DATE 3/7/07 3/15/07 2/7/07 3/13/07 3/15/07 Callaway Plant, Unit 1 cc:
Professional Nuclear Consulting, Inc. Mr. Dan I. Bolef, President 19041 Raines Drive Kay Drey, Representative Derwood, MD 20855 Board of Directors Coalition for the Environment John ONeill, Esq. 6267 Delmar Boulevard Pillsbury Winthrop Shaw Pittman LLP University City, MO 63130 2300 N. Street, N.W.
Washington, D.C. 20037 Mr. Lee Fritz, Presiding Commissioner Callaway County Court House Mr. Keith A. Mills, Supervising Engineer 10 East Fifth Street Regional Regulatory Affairs/Safety Analysis Fulton, MO 65151 AmerenUE P.O. Box 620 Mr. David E. Shafer Fulton, MO 65251 Superintendent, Licensing Regulatory Affairs U.S. Nuclear Regulatory Commission AmerenUE Resident Inspector Office P.O. Box 66149, MC 470 8201 NRC Road St. Louis, MO 63166-6149 Steedman, MO 65077-1302 Manager, Regulatory Affairs Mr. Les H. Kanuckel AmerenUE Manager, Quality Assurance P.O. Box 620 AmerenUE Fulton, MO 65251 P.O. Box 620 Fulton, MO 65251 Mr. Keith G. Henke, Planner Division of Community and Public Health Missouri Public Service Commission Office of Emergency Coordination Governor Office Building 930 Wildwood P.O. Box 570 200 Madison Street Jefferson City, MO 65102 Jefferson City, MO 65102-0360 Certrec Corporation Regional Administrator, Region IV 4200 South Hulen, Suite 630 U.S. Nuclear Regulatory Commission Fort Worth, TX 76109 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Director, Missouri State Emergency Management Agency Mr. H. Floyd Gilzow P.O. Box 116 Deputy Director for Policy Jefferson City, MO 65102-0116 Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839 June 2006
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO RELIEF REQUEST NO. ISI-33 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By letters dated May 18 and December 12, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML061460043 and ML063530466, respectively), the Union Electric Company (the licensee) submitted Relief Request (RR)
No. ISI-33, which proposed an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (the ASME Code) at the Callaway Plant, Unit 1. Specifically, the licensee proposed using a root mean square (RMS) error criterion for depth-sizing flaws that is greater than the ASME Code,Section XI, Appendix VIII, Supplements 2 and 10 acceptance criteria for examinations performed from the inside surface of reactor coolant system pressure boundary piping. The licensees request is for the second 10-year inservice inspection (ISI) interval, which ended on December 18, 2005, and the third 10-year ISI interval, which began on December 19, 2005.
2.0 REGULATORY EVALUATION
In accordance with Paragraph 50.55a(g)(4) of Title 10 of the Code of Federal Regulations (10 CFR), ASME Code Class 1, 2, and 3 components must meet the requirements set forth in ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plants Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that all inservice examinations and system pressure tests conducted during the first 10-year interval, and subsequent intervals, comply with the requirements in the latest edition and addenda of ASME Code,Section XI, incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 10-year interval.
For Callaway, the licensee stated that the code of record for the second 10-year ISI interval is the 1989 Edition of Section XI of the ASME Code. For the third 10-year ISI interval, the Code of record is the 1998 Edition through the 2000 Addenda of Section XI of the ASME Code.
Alternatives to requirements may be authorized or relief granted by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or 10 CFR 50.55a(g)(6)(i). In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives would provide an acceptable level of safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of
quality and safety; or (3) conformance is impractical for the facility. Pursuant to 10 CFR 50.55a(g)(4)(iv), ISI items may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein, and subject to Commission approval. Portions of editions and addenda may be used provided that related requirements of the respective editions and addenda are met.
3.0 TECHNICAL EVALUATION
FOR RR NO. ISI-33 3.1 Affected Components The licensee stated that the relief request is specific to pipe weld 2-BB-01-F302.
3.2 Applicable Code As stated in the application, for the second 10-year ISI interval, the ISI code of record is the 1989 Edition with no Addenda, ASME Code,Section XI, Appendix VIII, Supplements 2 and 10, Paragraph 3.2(b) (for both supplements) which states that the RMS error for flaw depths estimated by ultrasonic testing (UT) shall not exceed 0.125 inches.
For the third 10-year ISI interval, the ISI Code of record is the 1998 Edition with 2000 Addenda, ASME Code,Section XI, Appendix VIII, Supplements 2 and 10, Paragraph 3.2(b).
3.3 Proposed Inspection The licensee proposed using the Electric Power Research Institute (EPRI) Performance Demonstration Initiative (PDI) program for the implementation of Appendix VIII, Supplement 2 in coordination with Supplement 101, Paragraph 3.2(b), 0.245-inch RMS criterion in lieu of the ASME Code-required 0.125-inch RMS criterion because of the impracticality in the licensee achieving the ASME Code-required criterion. At this time, no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe inside diameter (ID). The licensee would use the qualifications of Appendix VIII, Supplement 10, as administrated by the PDI, as described in its RR ISI-27, which was authorized by NRC in its letter dated April 17, 2004.
The difference between the 0.245-inch RMS error and the ASME Code-required 0.125-inch RMS error (i.e., 0.82-inch difference) will be added to the measured flaw size for the purpose of flaw evaluation.
3.4 Licensees Basis for Impracticality The licensees vendor performed a combined Appendix VIII, Supplements 2 and 10 (identified in the licensees submittal of May 18, 2006, as Supplement 14) performance demonstration that 1
NRC Safety Evaluation dated April 7, 2004, which the letter authorizing relief request ISI-27, ADAMS Accession No. ML0410005162.
did not satisfy the ASME Code-required 0.125-inch RMS depth-sizing error criterion. The vendor actually demonstrated a 0.245-inch RMS depth-sizing error for the combined Supplements 2 and 10. Currently, no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe ID, and it is, therefore, impractical at this time to require the licensee to meet this criterion.
3.5 Evaluation The licensees ISI code of record for the second 10-year ISI interval is the 1989 Edition with no addenda. The regulation 10 CFR 50.55a(g)(6)(ii)(C)(2) requires that licensees with the 1989 Edition and earlier editions and addenda ISI code of record use the 1995 Edition with 1996 Addenda of Section XI, Appendix VIII for UT examinations. For the third 10-year ISI interval, the licensee is using the 1998 Edition with 2000 Addenda. The licensees vendor performed a coordinated Supplements 2 and 10 (licensees Supplement 14) performance demonstration as implemented by the PDI program.
The ASME Code requires that the maximum error for flaw-depth measurements, when compared to the true flaw depth, must not exceed 0.125-inch RMS error. The nuclear power industry is in the process of qualifying personnel and procedures with a coordinated Appendix VIII, Supplement 2 and Supplement 10 performance demonstration as implemented by the PDI program. However, to date, no personnel or procedure has yet achieved the ASME Code-required 0.125-inch RMS maximum error criterion for performance demonstrations performed from the pipe ID. The difficulties are associated with the surface roughness of the field welds. As licensees perform ID UT examinations, they are taking profilometry measurements which can be used to assess the representativeness of the test specimens used to establish the vendors RMS error criterion2. At this time, achieving a 0.125-inch RMS error criterion is impractical because no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer applied on the pipe ID. The licensee has stated that the vendor has achieved a 0.245-inch RMS error for the coordinated Supplement 2 and Supplement 10 performance demonstrations. The licensee proposed adding the depth-sizing difference between the performance demonstrated error of 0.245-inch and the Code-required error of 0.125-inch to the measured flaw size.
Based on its evaluation, the NRC staff finds that compliance with the ASME Code-required RMS error criterion is impractical at this time and that adding the difference between the demonstrated depth sizing RMS error and the ASME Code-required depth sizing RMS error when determining acceptance to the standards specified in ASME Code,Section XI, IWB-3500, provides reasonable assurance of structural integrity.
3.6 Conclusion Based on the above evaluation, the NRC staff concludes that compliance with the ASME Code-required RMS depth-sizing error value is impractical because no vendor has been able to achieve the 0.125-inch RMS criterion with the transducer on the pipe ID, and that the proposed inspection, as implemented by the PDI program in a coordinated performance demonstration, 2
Summary of Public Meeting Held May 24 and 25, 2005 with EPRI-PDI Representatives, dated September 8, 2005, ADAMS Accession No. ML052580257.
provides reasonable assurance of structural integrity. Therefore, based on its evaluation, the NRC staff concludes that the relief is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest, given the consideration of the burden upon the licensee. Therefore, pursuant to 10 CFR 50.55a(g)(6)(i),
the relief is granted for Callaway for the second 10-year ISI interval and third 10-year ISI interval for the subject weld.
All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Don Naujock Date: March 15, 2007
