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| | author name = Terao D | | | author name = Terao D |
| | author affiliation = NRC/NRR/ADRO/DORL/LPLIV | | | author affiliation = NRC/NRR/ADRO/DORL/LPLIV |
| | addressee name = Naslund C D | | | addressee name = Naslund C |
| | addressee affiliation = Union Electric Co | | | addressee affiliation = Union Electric Co |
| | docket = 05000483 | | | docket = 05000483 |
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| =Text= | | =Text= |
| {{#Wiki_filter:January 18, 2007Mr. Charles D. NaslundSenior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251 | | {{#Wiki_filter:January 18, 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 - REQUEST FOR RELIEF NO. ISI-35 FORSECOND 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MD3434) | | CALLAWAY PLANT, UNIT 1 - REQUEST FOR RELIEF NO. ISI-35 FOR SECOND 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MD3434) |
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| ==Dear Mr. Naslund:== | | ==Dear Mr. Naslund:== |
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| By letter dated October 25, 2006 (ULNRC-05183), the Union Electric Company (the licensee)requested relief from certain examination requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., the ASME Code) for the second 10-year inservice inspection (ISI) interval at the Callaway Plant (Callaway). Relief Requests (RRs)ISI-34, ISI-35, ISI-36, ISI-37, SI-38, ISI-39, ISI-40, and ISI-41 were submitted in that letter. This letter addresses RR ISI-35.Based on the attached safety evaluation, the Nuclear Regulatory Commission (NRC) staff hasdetermined that the ASME Code examination coverage requirements are impractical for the subject weld listed in RR ISI-35, and that the proposed inspection provides reasonable assurance of structural integrity. Therefore, granting relief, pursuant to paragraph 50.55a(g)(6)(i) of Title 10 of the Code of Federal Regulations, is authorized by law and will notendanger 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, the NRC staff grants the relief in RR ISI-35 for the second 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, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-483 | | By letter dated October 25, 2006 (ULNRC-05183), the Union Electric Company (the licensee) requested relief from certain examination requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., the ASME Code) for the second 10-year inservice inspection (ISI) interval at the Callaway Plant (Callaway). Relief Requests (RRs) |
| | ISI-34, ISI-35, ISI-36, ISI-37, SI-38, ISI-39, ISI-40, and ISI-41 were submitted in that letter. This letter addresses RR ISI-35. |
| | Based on the attached safety evaluation, the Nuclear Regulatory Commission (NRC) staff has determined that the ASME Code examination coverage requirements are impractical for the subject weld listed in RR ISI-35, and that the proposed inspection provides reasonable assurance of structural integrity. Therefore, granting relief, pursuant to paragraph 50.55a(g)(6)(i) of Title 10 of the Code of Federal Regulations, 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, the NRC staff grants the relief in RR ISI-35 for the second 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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| ML063520318OFFICENRR/LPL4/PMNRR/LPL4/LACVIB/BCOGC-NLO w/commentsNRR/LPL4/BCNAMEJDonohewLFeizollahiMMitchellJRundDTerao DATE12/21/0712/19/0712/12/061/2/071/18/07 June 2006Callaway Plant, Unit 1 cc:Professional Nuclear Consulting, Inc.
| | ML063520318 OFFICE NRR/LPL4/PM NRR/LPL4/LA CVIB/BC OGC-NLO w/comments NRR/LPL4/BC NAME JDonohew LFeizollahi MMitchell JRund DTerao DATE 12/21/07 12/19/07 12/12/06 1/2/07 1/18/07 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 REGULATIONSECOND 10-YEAR INTERVAL INSERVICE INSPECTIONREQUEST FOR RELIEF NO. ISI-35UNION ELECTRIC COMPANYCALLAWAY PLANT, UNIT 1DOCKET NO. 50-48
| | SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SECOND 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF NO. ISI-35 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 |
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| ==31.0INTRODUCTION== | | ==1.0 INTRODUCTION== |
| By application dated October 25, 2006 (Agencywide Documents Access and ManagementSystem Accession No. ML063050203), Union Electric Company (the licensee) requested relief from certain examination requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., the ASME Code) for the second 10-year inservice inspection (ISI) interval at the Callaway Plant (Callaway). Relief Requests (RRs) ISI-34, ISI-35, ISI-36, ISI-37, ISI-38, ISI-39, ISI-40, and ISI-41 were submitted in the letter. This safety evaluation addresses RR ISI-35.2.0REGULATORY REQUIREMENTSISI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASMECode) Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by paragraph 50.55a(g) of Title 10 of the Code ofFederal Regulation (10 CFR). Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.The regulations require that inservice examination of components and system pressure testsconducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. However, if a licensee determines that conformance with these requirements is impractical, it may request relief from these specific requirements. Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant such relief and may impose alternative requirements as it determines 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 therequirements were imposed on the facility.The licensee stated that the ASME Code of record for the Callaway Plant second 10-yearinterval inservice inspection program is the 1989 Edition with no Addenda of Section XI of the ASME Code.3.0NRC STAFF EVALUATION OF RR NO. ISI-35 3.1Information provided by Licensee The following information was provided by the licensee in the attachment to its applicationdated October 25, 2006, on RR ISI-35.
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| ASME Code ComponentsThe component involved in the relief requests is the residual heat removal (RHR) Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W.ASME Code RequirementsThe applicable ASME Code requirements are the following:*ASME Code, Section XI, IWC-2500-1, Category C-A, Item C1.10 requiresvolumetric examination of essentially 100 percent of the weld length.*ASME Code Case N-460, Alternative Examination Coverage for Class 1 andClass 2 Welds, as an alternative approved for use by the NRC in Regulatory Guide(RG) 1.147, Revision 14, "Inservice Inspection Code Case Acceptability, ASME Section XII, Division 1," states that a reduction in examination coverage due to partgeometry or interference for any ASME Code Class 1 or 2 weld is acceptable provided that the reduction is less than 10 percent (i.e., greater than 90-percent examination coverage is obtained).Licensee's Basis for Relief Request In the attachment to its application for RR ISI-35, the licensee stated the following:The stainless steel flange configuration caused the examination to be single-sided. Theexamination was further obstructed by flange bolting. An additional 45-degree full-vee shear wave examination and a 45-degree half-vee longitudinal wave examination were performed to address the flange side of the weld. Conservatively, however, no credit was taken for the flange side of the weld because single-sided examinations of austenitic welds have not been adequately demonstrated in accordance with the 1The licensee's examination report for weld 2-EEJ01A-SEAM-1-W is not included in this safety evaluationand can be found in the licensee's letter dated October 26, 2006.requirements of ASME [Code] Section XI Appendix VIII. A copy of the examinationreport for the weld is attached.
| | By application dated October 25, 2006 (Agencywide Documents Access and Management System Accession No. ML063050203), Union Electric Company (the licensee) requested relief from certain examination requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., the ASME Code) for the second 10-year inservice inspection (ISI) interval at the Callaway Plant (Callaway). Relief Requests (RRs) ISI-34, ISI-35, ISI-36, ISI-37, ISI-38, ISI-39, ISI-40, and ISI-41 were submitted in the letter. This safety evaluation addresses RR ISI-35. |
| 1There are currently no qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications.Plant modifications or replacement with components designed to allow for completecoverage would be needed to meet the ASME Code requirements. This would impose a considerable burden to Callaway Plant.Licensee's Proposed Alternative Examination (As Stated)In an attachment to its application for RR ISI-35, the licensee stated the following:The best available techniques, similar to those qualified through the industry'sPerformance Demonstration Initiative [PDI] for Supplement 2 with a demonstrated best effort for single-side examination, are used from the accessible side of the weld.3.2NRC Staff's Evaluation The ASME Code, Section XI, requires a volumetric examination of essentially 100 percentof the weld length for the RHR Heat Exchanger A bonnet flange-to-channel weld No. 2-EEJ01A-SEAM-1-W. The volumetric examination by ultrasonic methodology of this weld was conducted to the extent practical by the licensee using personnel, equipment, and procedures qualified in accordance with ASME Code, Section XI, Appendix VIII. The licenseefound that during the ultrasonic examination of the subject weld essentially 100-percent coverage of the required examination weld length could not be obtained. The ASME Code examination was limited due to the stainless steel flange configuration andflange bolting. As a result, the licensee was only able to perform the examination from the vessel side of the weld. The licensee also performed an additional 45-degree full-vee shear wave examination and a 45-degree half-vee longitudinal wave examination to address theflange side of the weld. The licensee did not take credit for the flange examinations because the single-sided examinations of austenitic welds have not been adequately demonstrated and there are not examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic welds at this time in accordance with the requirements of the ASME Code, Section XI, Appendix VIII. Therefore, the NRC staff determined that in order forthe licensee to obtain essentially 100-percent coverage of the required examination weld length, the RHR Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W would have to be redesigned to allow greater access for scanning and would cause a burden on the
| | 2.0 REGULATORY REQUIREMENTS ISI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by paragraph 50.55a(g) of Title 10 of the Code of Federal Regulation (10 CFR). Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code, Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. |
| | The regulations require that inservice examination of components 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 Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. However, if a licensee determines that conformance with these requirements is impractical, it may request relief from these specific requirements. Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant such relief and may impose alternative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the |
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| licensee. The licensee obtained a composite coverage of 55 percent from the vessel side ofweld No. 2-EEJ01A-SEAM-1-W. Therefore, the NRC staff has determined that the examinations performed would have detected significant patterns of degradation, if any had occurred. The NRC staff has also determined that the volumetric and ASME Code VT-2 visual examinations during system walkdowns performed provide reasonable assurance of structural integrity of the weld.3.3Conclusion Based on the above evaluation, the NRC staff has reviewed the licensee's application forRR ISI-35 and concludes that the ASME Code examination coverage requirements are impractical for RHR Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W for Callaway. Furthermore, based on the coverages obtained, if significant service-induced degradation were occurring, the NRC staff also concludes that there is reasonable assurance that evidence of it would have been detected by the examinations that were performed and that the volumetric examinations performed and VT-2 visual examinations during plant walkdowns provide reasonable assurance of structural integrity of weld 2-EEJ01A-SEAM-1-W.
| | public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. |
| | The licensee stated that the ASME Code of record for the Callaway Plant second 10-year interval inservice inspection program is the 1989 Edition with no Addenda of Section XI of the ASME Code. |
| | 3.0 NRC STAFF EVALUATION OF RR NO. ISI-35 3.1 Information provided by Licensee The following information was provided by the licensee in the attachment to its application dated October 25, 2006, on RR ISI-35. |
| | ASME Code Components The component involved in the relief requests is the residual heat removal (RHR) Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W. |
| | ASME Code Requirements The applicable ASME Code requirements are the following: |
| | * ASME Code, Section XI, IWC-2500-1, Category C-A, Item C1.10 requires volumetric examination of essentially 100 percent of the weld length. |
| | * ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds, as an alternative approved for use by the NRC in Regulatory Guide (RG) 1.147, Revision 14, Inservice Inspection Code Case Acceptability, ASME Section XII, Division 1, states that a reduction in examination coverage due to part geometry or interference for any ASME Code Class 1 or 2 weld is acceptable provided that the reduction is less than 10 percent (i.e., greater than 90-percent examination coverage is obtained). |
| | Licensees Basis for Relief Request In the attachment to its application for RR ISI-35, the licensee stated the following: |
| | The stainless steel flange configuration caused the examination to be single-sided. The examination was further obstructed by flange bolting. An additional 45-degree full-vee shear wave examination and a 45-degree half-vee longitudinal wave examination were performed to address the flange side of the weld. Conservatively, however, no credit was taken for the flange side of the weld because single-sided examinations of austenitic welds have not been adequately demonstrated in accordance with the |
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| ==4.0CONCLUSION== | | requirements of ASME [Code] Section XI Appendix VIII. A copy of the examination report for the weld is attached.1 There are currently no qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications. |
| Therefore, based on the above evaluation for RR No. ISI-35, relief is granted by theCommission, pursuant to 10 CFR 50.55a(g)(6)(i), on the basis that the ASME Code-required examination is impractical, for the second 10-year ISI interval for Callaway and that the proposed inspection provides reasonable assurance of structural integrity. The NRC staff has also determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) for RR No. ISI-35 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. All other ASME Code, Section XI, requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.Principal Contributor: Tom McLellan Date: January 18, 2007}} | | Plant modifications or replacement with components designed to allow for complete coverage would be needed to meet the ASME Code requirements. This would impose a considerable burden to Callaway Plant. |
| | Licensees Proposed Alternative Examination (As Stated) |
| | In an attachment to its application for RR ISI-35, the licensee stated the following: |
| | The best available techniques, similar to those qualified through the industry's Performance Demonstration Initiative [PDI] for Supplement 2 with a demonstrated best effort for single-side examination, are used from the accessible side of the weld. |
| | 3.2 NRC Staffs Evaluation The ASME Code, Section XI, requires a volumetric examination of essentially 100 percent of the weld length for the RHR Heat Exchanger A bonnet flange-to-channel weld No. 2-EEJ01A-SEAM-1-W. The volumetric examination by ultrasonic methodology of this weld was conducted to the extent practical by the licensee using personnel, equipment, and procedures qualified in accordance with ASME Code, Section XI, Appendix VIII. The licensee found that during the ultrasonic examination of the subject weld essentially 100-percent coverage of the required examination weld length could not be obtained. |
| | The ASME Code examination was limited due to the stainless steel flange configuration and flange bolting. As a result, the licensee was only able to perform the examination from the vessel side of the weld. The licensee also performed an additional 45-degree full-vee shear wave examination and a 45-degree half-vee longitudinal wave examination to address the flange side of the weld. The licensee did not take credit for the flange examinations because the single-sided examinations of austenitic welds have not been adequately demonstrated and there are not examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic welds at this time in accordance with the requirements of the ASME Code, Section XI, Appendix VIII. Therefore, the NRC staff determined that in order for the licensee to obtain essentially 100-percent coverage of the required examination weld length, the RHR Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W would have to be redesigned to allow greater access for scanning and would cause a burden on the licensee. |
| | 1 The licensees examination report for weld 2-EEJ01A-SEAM-1-W is not included in this safety evaluation and can be found in the licensees letter dated October 26, 2006. |
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| | The licensee obtained a composite coverage of 55 percent from the vessel side of weld No. 2-EEJ01A-SEAM-1-W. Therefore, the NRC staff has determined that the examinations performed would have detected significant patterns of degradation, if any had occurred. The NRC staff has also determined that the volumetric and ASME Code VT-2 visual examinations during system walkdowns performed provide reasonable assurance of structural integrity of the weld. |
| | 3.3 Conclusion Based on the above evaluation, the NRC staff has reviewed the licensee's application for RR ISI-35 and concludes that the ASME Code examination coverage requirements are impractical for RHR Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W for Callaway. Furthermore, based on the coverages obtained, if significant service-induced degradation were occurring, the NRC staff also concludes that there is reasonable assurance that evidence of it would have been detected by the examinations that were performed and that the volumetric examinations performed and VT-2 visual examinations during plant walkdowns provide reasonable assurance of structural integrity of weld 2-EEJ01A-SEAM-1-W. |
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| | ==4.0 CONCLUSION== |
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| | Therefore, based on the above evaluation for RR No. ISI-35, relief is granted by the Commission, pursuant to 10 CFR 50.55a(g)(6)(i), on the basis that the ASME Code-required examination is impractical, for the second 10-year ISI interval for Callaway and that the proposed inspection provides reasonable assurance of structural integrity. The NRC staff has also determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) for RR No. ISI-35 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. All other ASME Code, Section XI, requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector. |
| | Principal Contributor: Tom McLellan Date: January 18, 2007}} |
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Category:Code Relief or Alternative
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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
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ML14239A0972014-09-0404 September 2014
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ML13246A3042013-08-30030 August 2013
Verbal Authorization Email, Relief Request PR-07, Testing Frequency for Pumps and Valves, Third 10-year Inservice Testing Interval
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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]
Category:Letter
MONTHYEARULNRC-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
IR 05000483/20230042024-01-19019 January 2024
Integrated Inspection Report 05000483/2023004
ML24008A0552024-01-19019 January 2024
Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code (EPID L-2023-LLR- 0061)
ML23353A1712024-01-18018 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
ML23317A0012024-01-12012 January 2024
Audit Summary Regarding LAR to Clarify Support System Requirements for the Residual Heat Removal 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)
ML24011A1492024-01-11011 January 2024
Notification of Post-Approval Site Inspection for License Renewal and Request for Information (05000483/2024011)
ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)2023-12-21021 December 2023
Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)
ULNRC-06849, License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds2023-12-20020 December 2023
License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds
ML23346A0392023-12-14014 December 2023
Supplemental Information Needed for Acceptance of Requested Licensing Action Request for Relief from Requirements of ASME Code, Section Xl, Examination and Testing Unbonded Post-Tensioning System
ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification2023-12-0707 December 2023
Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification
05000483/LER-2023-001, Submittal of LER 2023-001-00 for Callaway, Unit 1, Inoperable Instrument Tunnel Sump Level Indication Resulted in Condition Prohibited by Technical Specifications2023-11-29029 November 2023
Submittal of LER 2023-001-00 for Callaway, Unit 1, Inoperable Instrument Tunnel Sump Level Indication Resulted in Condition Prohibited by Technical Specifications
ULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2023-11-20020 November 2023
Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)
IR 05000483/20230102023-11-15015 November 2023
NRC License Renewal Phase 1 Inspection Report 05000483 2023010
IR 05000483/20233012023-11-0909 November 2023
NRC Examination Report 05000483-2023301
ML23311A2082023-11-0909 November 2023
Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV
ML23297A2502023-11-0606 November 2023
Individual Notice of Consideration of Issuance of Amendment to Renewed Facility Operating License, Proposed No Significant Hazards Consideration Determination and Opportunity for a Hearing (EPID L-2022-LLA-0176) - Letter
IR 05000483/20240122023-10-24024 October 2023
Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection (05000483/2024012)
ML23293A2652023-10-24024 October 2023
3rd Quarter 2023 Integrated Inspection Report
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)
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)
ML23305A0942023-10-0202 October 2023
10-CW-2023-09 Post-Exam Submittal
ML23270B9662023-09-27027 September 2023
10 CFR 50.55a(z)(I) Request for Relief from ASME OM Code Pump and Valve Testing Requirements for Fifth 120-Month Inservice Testing Interval
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
ML23206A1992023-09-15015 September 2023
Regulatory Audit Summary Regarding License Amendment and Regulatory Exemptions Request for Fuel Transition to Framatome Gaia Fuel (Epids L-2022-LLA-0150 and L-2022-LLE-0030)
IR 05000483/20234012023-09-13013 September 2023
NRC Security Baseline Inspection Report 05000483/2023401
ML23240A7572023-08-31031 August 2023
NRC Initial Operator Licensing Examination Approval 05000483/2023301
IR 05000483/20230052023-08-23023 August 2023
Updated Inspection Plan for Callaway Nuclear Power Plant, Unit 1 (Report 05000483/2023005) - Mid Cycle Letter 2023
ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023
Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A
ML23219A1392023-08-15015 August 2023
Request for Withholding Information from Public Disclosure
ULNRC-06830, Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak2023-08-15015 August 2023
Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak
ML23215A1972023-08-0303 August 2023
Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002)
ULNRC-06223, Minor Correction to License Amendment Request 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 (LDCN 2020-0004)2023-07-25025 July 2023
Minor Correction to License Amendment Request 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 (LDCN 2020-0004)
ULNRC-06799, Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023
Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications
IR 05000483/20230022023-07-10010 July 2023
Integrated Inspection Report 05000483/2023002
ML23174A1272023-06-23023 June 2023
Cw FFD Document Request List 2023
ML23171A9942023-06-22022 June 2023
Acceptance of Request for Approval of Operating Quality Assurance Manual Revision 36a
ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023
Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)
IR 05000483/20230112023-06-15015 June 2023
Comprehensive Engineering Team Inspection (CETI) Inspection Report 05000483/2023011
ULNRC-06822, Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a2023-06-14014 June 2023
Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a
ML23158A1462023-06-13013 June 2023
Notification of Post-Approval Site Inspection for License Renewal and Request for Information Inspection (05000483/2023010)
ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a2023-06-0505 June 2023
Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a
ULNRC-06818, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .2023-06-0505 June 2023
Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .
ML23093A0952023-05-10010 May 2023
Issuance of Amendment No. 232 Regarding Technical Specification Changes for Spent Fuel Storage
ULNRC-06816, Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)2023-05-0909 May 2023
Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)
ML23129A7942023-05-0909 May 2023
Post-Audit Supplement to License Amendment Request and Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (Iepid L-2022-LLA-0150 and EPID L-2022-LLE-0030)
ML23122A3172023-05-0808 May 2023
Review of the Spring 2022 Steam Generator Tube Inservice Inspections
ML23118A3492023-05-0808 May 2023
Request for Withholding Information from Public Disclosure
2024-01-29
[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
January 18, 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 - REQUEST FOR RELIEF NO. ISI-35 FOR SECOND 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MD3434)
Dear Mr. Naslund:
By letter dated October 25, 2006 (ULNRC-05183), the Union Electric Company (the licensee) requested relief from certain examination requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., the ASME Code) for the second 10-year inservice inspection (ISI) interval at the Callaway Plant (Callaway). Relief Requests (RRs)
ISI-34, ISI-35, ISI-36, ISI-37, SI-38, ISI-39, ISI-40, and ISI-41 were submitted in that letter. This letter addresses RR ISI-35.
Based on the attached safety evaluation, the Nuclear Regulatory Commission (NRC) staff has determined that the ASME Code examination coverage requirements are impractical for the subject weld listed in RR ISI-35, and that the proposed inspection provides reasonable assurance of structural integrity. Therefore, granting relief, pursuant to paragraph 50.55a(g)(6)(i) of Title 10 of the Code of Federal Regulations, 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, the NRC staff grants the relief in RR ISI-35 for the second 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
ML063520318 OFFICE NRR/LPL4/PM NRR/LPL4/LA CVIB/BC OGC-NLO w/comments NRR/LPL4/BC NAME JDonohew LFeizollahi MMitchell JRund DTerao DATE 12/21/07 12/19/07 12/12/06 1/2/07 1/18/07 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 SECOND 10-YEAR INTERVAL INSERVICE INSPECTION REQUEST FOR RELIEF NO. ISI-35 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By application dated October 25, 2006 (Agencywide Documents Access and Management System Accession No. ML063050203), Union Electric Company (the licensee) requested relief from certain examination requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (i.e., the ASME Code) for the second 10-year inservice inspection (ISI) interval at the Callaway Plant (Callaway). Relief Requests (RRs) ISI-34, ISI-35, ISI-36, ISI-37, ISI-38, ISI-39, ISI-40, and ISI-41 were submitted in the letter. This safety evaluation addresses RR ISI-35.
2.0 REGULATORY REQUIREMENTS ISI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1, 2, and 3 components is performed in accordance with Section XI of the ASME Code and applicable addenda as required by paragraph 50.55a(g) of Title 10 of the Code of Federal Regulation (10 CFR). Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The regulations require that inservice examination of components 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 Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. However, if a licensee determines that conformance with these requirements is impractical, it may request relief from these specific requirements. Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant such relief and may impose alternative requirements as it determines 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.
The licensee stated that the ASME Code of record for the Callaway Plant second 10-year interval inservice inspection program is the 1989 Edition with no Addenda of Section XI of the ASME Code.
3.0 NRC STAFF EVALUATION OF RR NO. ISI-35 3.1 Information provided by Licensee The following information was provided by the licensee in the attachment to its application dated October 25, 2006, on RR ISI-35.
ASME Code Components The component involved in the relief requests is the residual heat removal (RHR) Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W.
ASME Code Requirements The applicable ASME Code requirements are the following:
- ASME Code,Section XI, IWC-2500-1, Category C-A, Item C1.10 requires volumetric examination of essentially 100 percent of the weld length.
- ASME Code Case N-460, Alternative Examination Coverage for Class 1 and Class 2 Welds, as an alternative approved for use by the NRC in Regulatory Guide (RG) 1.147, Revision 14, Inservice Inspection Code Case Acceptability, ASME Section XII, Division 1, states that a reduction in examination coverage due to part geometry or interference for any ASME Code Class 1 or 2 weld is acceptable provided that the reduction is less than 10 percent (i.e., greater than 90-percent examination coverage is obtained).
Licensees Basis for Relief Request In the attachment to its application for RR ISI-35, the licensee stated the following:
The stainless steel flange configuration caused the examination to be single-sided. The examination was further obstructed by flange bolting. An additional 45-degree full-vee shear wave examination and a 45-degree half-vee longitudinal wave examination were performed to address the flange side of the weld. Conservatively, however, no credit was taken for the flange side of the weld because single-sided examinations of austenitic welds have not been adequately demonstrated in accordance with the
requirements of ASME [Code] Section XI Appendix VIII. A copy of the examination report for the weld is attached.1 There are currently no qualified single-side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic welds. Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications.
Plant modifications or replacement with components designed to allow for complete coverage would be needed to meet the ASME Code requirements. This would impose a considerable burden to Callaway Plant.
Licensees Proposed Alternative Examination (As Stated)
In an attachment to its application for RR ISI-35, the licensee stated the following:
The best available techniques, similar to those qualified through the industry's Performance Demonstration Initiative [PDI] for Supplement 2 with a demonstrated best effort for single-side examination, are used from the accessible side of the weld.
3.2 NRC Staffs Evaluation The ASME Code,Section XI, requires a volumetric examination of essentially 100 percent of the weld length for the RHR Heat Exchanger A bonnet flange-to-channel weld No. 2-EEJ01A-SEAM-1-W. The volumetric examination by ultrasonic methodology of this weld was conducted to the extent practical by the licensee using personnel, equipment, and procedures qualified in accordance with ASME Code,Section XI, Appendix VIII. The licensee found that during the ultrasonic examination of the subject weld essentially 100-percent coverage of the required examination weld length could not be obtained.
The ASME Code examination was limited due to the stainless steel flange configuration and flange bolting. As a result, the licensee was only able to perform the examination from the vessel side of the weld. The licensee also performed an additional 45-degree full-vee shear wave examination and a 45-degree half-vee longitudinal wave examination to address the flange side of the weld. The licensee did not take credit for the flange examinations because the single-sided examinations of austenitic welds have not been adequately demonstrated and there are not examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic welds at this time in accordance with the requirements of the ASME Code,Section XI, Appendix VIII. Therefore, the NRC staff determined that in order for the licensee to obtain essentially 100-percent coverage of the required examination weld length, the RHR Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W would have to be redesigned to allow greater access for scanning and would cause a burden on the licensee.
1 The licensees examination report for weld 2-EEJ01A-SEAM-1-W is not included in this safety evaluation and can be found in the licensees letter dated October 26, 2006.
The licensee obtained a composite coverage of 55 percent from the vessel side of weld No. 2-EEJ01A-SEAM-1-W. Therefore, the NRC staff has determined that the examinations performed would have detected significant patterns of degradation, if any had occurred. The NRC staff has also determined that the volumetric and ASME Code VT-2 visual examinations during system walkdowns performed provide reasonable assurance of structural integrity of the weld.
3.3 Conclusion Based on the above evaluation, the NRC staff has reviewed the licensee's application for RR ISI-35 and concludes that the ASME Code examination coverage requirements are impractical for RHR Heat Exchanger A bonnet flange-to-channel weld 2-EEJ01A-SEAM-1-W for Callaway. Furthermore, based on the coverages obtained, if significant service-induced degradation were occurring, the NRC staff also concludes that there is reasonable assurance that evidence of it would have been detected by the examinations that were performed and that the volumetric examinations performed and VT-2 visual examinations during plant walkdowns provide reasonable assurance of structural integrity of weld 2-EEJ01A-SEAM-1-W.
4.0 CONCLUSION
Therefore, based on the above evaluation for RR No. ISI-35, relief is granted by the Commission, pursuant to 10 CFR 50.55a(g)(6)(i), on the basis that the ASME Code-required examination is impractical, for the second 10-year ISI interval for Callaway and that the proposed inspection provides reasonable assurance of structural integrity. The NRC staff has also determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(i) for RR No. ISI-35 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. All other ASME Code,Section XI, requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Tom McLellan Date: January 18, 2007
