ML12062A133

ME7902 & ME7903-Approval of RR-2012-001 Use of Later Edition of the ASME OM Code for Check Valve Condition Monitoring Program

ML12062A133
Person / Time
Site:	Susquehanna
Issue date:	03/06/2012
From:	Wilson G A Plant Licensing Branch 1
To:	Rausch T S Susquehanna
Vaidya B K, NRR/DORL/LPL1-1, 415-3308
References
TAC ME7902, TAC ME7903
Download: ML12062A133 (7)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 March 6, 2012 Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603-0467 SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 RE: RELIEF REQUEST NO. 2012-001, REVISION 1, THE USE OF SUBSEQUENT ASME OM CODE EDITION AND ADDENDA APPLICABLE TO SECTION ISTC-S222 AND APPENDIX II CHECK VALVE CONDITION MONITORING PROGRAM (TAC NOS. ME7902 AND ME7903)

Dear Mr. Rausch:

By letter dated January 31, 2012, as supplemented by letter dated February 13, 2012, PPL Susquehanna LLC, Inc. (PPL or the licensee) submitted a request to the U. S. Nuclear Regulatory Commission (NRC) for the use of subsequent American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) requirements at Susquehanna Steam Electric Station, Units 1 and 2. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part SO, Subsection SO.SSa(f)(4)(iv), the licensee requested to apply the requirements of Subsection ISTA (in its entirety), paragraph ISTC-S222, and Mandatory Appendix II (in its entirety) of the 2004 Edition of ASME OM Code through 2006 Addenda for the check valves in the Check Valve Condition Monitoring Program for the remainder of the Third 10-Year Interval for the Inservice Testing Program which began on June 1,2004, and is scheduled to end on May 31,2014, at the Susquehanna Steam Electric Station (SSES), Units 1 and 2, subject to the limitations and modifications listed in 10 CFR SO.SSa(b).

The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR SO.SSa(f)(4)(iv), and is in compliance with the ASME OM Code requirements.

These requirements will be used for check valves at SSES Units 1 and 2, in lieu of the corresponding requirements in the 1998 Edition of ASME OM Code through 2000 Addenda. Therefore, the NRC staff authorizes this request for the remainder of the Third 10-Year Interval for the Inservice Testing Program which began on June 1,2004, and is scheduled to end on May 31, 2014 at the SSES, Units 1 and 2, subject to the limitations and modifications listed in 10 CFR SO.SSa(b).

All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

T. S. Rausch Please contact me at (301) 415-1771, or the Project Manager, Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions.

Sincerely, Chief Plant licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and Safety cc w/encl: Distribution via UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. 2012*001, REVISION 1 REGARDING USE OF LATER EDITION AND ADDENDA FOR INSERVICE TESTING PROGRAM FOR CHECK VALVES PPLSUSQUEHANNA,LLC ALLEGHENY ELECTRIC COOPERATIVE, INC. SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50*387 AND 50-388

1.0 INTRODUCTION

By letter dated January 31,2012 (ML 12031A238) as supplemented later by letter dated February 13,2012 (ML 120440669), PPL Susquehanna, LLC, the licensee, requested approval to use a portion of a later edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code). This request is applicable to the Inservice Testing (1ST) Program at Susquehanna Steam Electric Station (SSES) Units 1 and 2. The licensee requested to apply the requirements of Subsection 1ST A (in its entirety), paragraph ISTC-5222, and Mandatory Appendix II (in its entirety) of the 2004 Edition of ASME OM Code through 2006 Addenda to selected check valves in the SSES 1ST Program in lieu of the corresponding requirements of the 1998 Edition of ASME OM Code through 2000 Addenda. Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Subsection 50.55a(f)(4)(iv), the licensee requested to apply the requirements of Subsection ISTA (in its entirety), paragraph ISTC-5222, and Mandatory Appendix II (in its entirety) of the 2004 Edition of ASME OM Code through 2006 Addenda for the check valves in the Check Valve Condition Monitoring Program for the remainder of the Third 10*Year Interval for the Inservice Testing Program which began on June 1, 2004, and is scheduled to end on May 31, 2014, at the SSES, Units 1 and 2, subject to the limitations and modifications listed in 10 CFR 50.55a(b).

2.0 REGULATORY EVALUATION

The regulations in 10 CFR 50.55a(f), "Inservice testing requirements," requires, in part, that 1ST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) 1ST program intervals in accordance with the specified ASME Code and applicable addenda Enclosure

-2 incorporated by reference in the regulations.

In accordance with 10 CFR SO.SSa(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month 1ST program interval.

In accordance with 10 CFR SO.SSa(f)(4)(iv), 1ST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR SO.SSa(b), subject to NRC approval.

Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," provides guidance for use of later Code editions.

3.0 TECHNICAL

EVALUATION

3.1 Licensee's

Request 2012-001 The SSES Units 1 and 2 third 10-year 1ST interval began on June 1, 2004. The applicable Code of Record for SSES Units 1 and 2 is the ASME OM Code, 1998 Edition through 2000 Addenda. This Code requires, in part, that valves in the scope of the 1ST Program as specified in 1100(a) shall be tested in accordance with the applicable requirements of Subsection ISTC. For check valves, as an alternative to the testing requirements of ISTC, ISTC-S222 allows the owner to implement a check valve condition monitoring program in accordance with the requirements of Mandatory Appendix II. The requirements of Mandatory Appendix II may be applied to any valve or group of valves up to and including the entire 1ST Program check valve population.

Any valves not included in the condition monitoring program are required to be tested in accordance with the applicable Subsection ISTC requirements.

In addition, the following requirements must be complied with by owners choosing to use Mandatory Appendix II of the 1998 Edition of OM Code: (1) Paragraph 10 CFR SO.SSa(b)(3)(iv)(A):

Valve opening and closing functions must be demonstrated when flow testing or examination methods (nonintrusive, or disassembly and inspection) are used. (2) Paragraph 10 CFR SO.SSa(b)(3)(iv)(B):

The initial interval for tests and associated examinations may not exceed two fuel cycles or 3 years, whichever is longer; any extension of this interval may not exceed one fuel cycle per extension with the maximum interval not to exceed 10 years; trending and evaluation of existing data must be used to reduce or extend the time interval between tests. (3) Paragraph 10 CFR SO.SSa(b){3){iv)(D):

The applicable provisions of subsection ISTC must be implemented if the Appendix II condition monitoring program is discontinued.

The licensee requested approval to use the corresponding portions of the 2004 Edition of the ASME OM Code through 2006 Addenda related to establishment of a check valve condition monitoring program. These portions include: Subsection ISTA which specifies general requirements for the 1ST Program including the scope of components to be tested;

-3 ISTC-S222 which allows the owner to implement at his discretion a check valve condition monitoring program in accordance with the requirements of Mandatory Appendix II; and Mandatory Appendix II which specifies the requirements for implementation of a check valve condition monitoring program. Unlike the version of Mandatory Appendix II contained in the 1998 Edition of OM Code, the version contained in the 2004 Edition of OM Code has no further requirements specified by 10 CFR SO.SSa(b)(3)(iv), as all of the previously specified requirements were subsequently incorporated into the later Code. The licensee proposes to apply the requirements noted above, to selected check valves in the scope of the SSES 1ST Program. A list of check valves selected for the condition monitoring program will be maintained in the respective Unit 1 or Unit 21ST Program Plans. Federal Register Notice dated June 21, 2011 (76 FR 36232), incorporated the 2004 Edition of ASME OM Code including Addenda through 2006, by reference in 10 CFR SO.SSa(b), subject to the limitations and modifications imposed by 10 CFR SO.SSa(b)(3).

Regulations in 10 CFR SO.SSa(b)(3) do not impose any additional limitations or modifications on the use of Mandatory Appendix II and the related requirements of Subsection ISTC. Note: Regulation in paragraph 10 CFR SO.SSa(b)(3)(i) does impose a limitation related to quality assurance as specified by OM Code Subsection 1ST A. However, this limitation is applicable to all licensees and all OM Code editions and is not specifically related to the implementation of a check valve condition monitoring program. 3.2 NRC Staff Evaluation The licensee has requested approval to apply the requirements of Subsection 1ST A (in its entirety), paragraph ISTC-S222, and Mandatory Appendix II (in its entirety) of the 2004 Edition of ASME OM Code through 2006 Addenda to selected check valves in the SSES 1ST Program. These requirements will be used for various check valves at SSES, in lieu of the corresponding requirements of the 1998 Edition of ASME OM Code through 2000 Addenda. The NRC staff has determined that there are no further limitations or modifications imposed by 10 CFR SO.SSa(b)(3) on the use of these portions of the 2004 Edition of the ASME OM Code through 2006 Addenda. Additionally, the NRC staff has not identified any additional related requirements in the 2004 Edition of the OM Code through 2006 Addenda that need to be met in order to implement the requested portions.

Therefore, use of Subsection ISTA (in its entirety), paragraph ISTC-S222, and Mandatory Appendix II (in its entirety) from the 2004 Edition of the ASME OM Code through 2006 Addenda for selected check valves at SSES Units 1 and 2, is acceptable.

4.0 CONCLUSION

As set forth above, the NRC staff determines that the licensee's request to apply the requirements of Subsection ISTA (in its entirety), paragraph ISTC-S222, and Mandatory Appendix II (in its entirety), using the 2004 Edition of ASME OM Code through 2006 Addenda for various check valves in the SSES 1ST Program, for the remainder of the third 10-year 1ST interval, is acceptable.

These requirements will be used for check valves at SSES Units 1 and 2, in lieu of the corresponding requirements in the 1998 Edition of ASME OM Code through 2000 Addenda. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR SO.SSa(f)(4)(iv), and is in compliance with the ASME OM Code requirements.

All other ASME OM Code requirements for which relief was not specifically requested and approved remain applicable.

Therefore, the NRC staff authorizes this request for the remainder of the Third 10-Year Interval for the 1ST Program which began on June 1,2004, and is scheduled to end on May 31,2014, at the SSES, Units 1 and 2, subject to the limitations and modifications listed in 10 CFR SO.SSa(b).

Principal Contributor:

J. Billerbeck, NRR/EPTB Date: March 6, 2012 T. S. Rausch Please contact me at (301) 415-1771, or the Project Manager, Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions.

Sincerely, lraJ George A. Wilson, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and Safety cc w/encl: Distribution via DISTRIBUTION:

PUBLIC LPL 1-1 R/F RidsNRRDorILPI1-1 RidsN RRPMSusquehanna RidsNrrLASLittle RidsOGCRp RidsNrrDeEptb RidsNrrDorlDpr RidsNrrDirsltsb RidsAcrsAcnw&m MailCenter RidsRg1MailCenter Lydia Chang, EDO Region 1 Contact RidsOgcRp J. Billerbeck, NRR/EPTB ADAMS Accession No.: ML 12062A133

(*) No substantial change from the SE Input Memo LPL 1-1/PM NAME "1 DATE 03/05/12 LPL 1-1/LA SLittie 03/05/12 NRR/EPTB/BC

(*) AMcMurtray 03/01/12 LPL 1-1/BC GWilson 03/06/12 OFFICIAL RECORD COPY