RS-08-157, Request to Use Later Edition and Addenda to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code
| ML083380760 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/03/2008 |
| From: | Simpson P AmerGen Energy Co, Exelon Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-08-157 | |
| Download: ML083380760 (4) | |
Text
AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 RS-08-157 December 3, 2008 www.exeloncorp.COM U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 erG An Exelon Company 10 CFR 50.55a(f)(4)(iv)
Subject:
Request to Use Later Edition and Addenda to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code References
- 1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004 2. Nuclear Energy Institute White Paper, "Standard Format for Requests from Commercial Reactor Licensees Pursuant to 10 CFR 50.550," dated June 2004 In accordance with 10 CFR 50.550, "Codes and standards," paragraph (f)(4)(iv), AmerGen Energy Company, LLC (AmerGen) requests NRC approval to use portions of a later edition and addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the Clinton Power Station (CPS) Inservice Testing Program. Pursuant to 10 CFR 50.55a(f)(4)(iv) and in accordance with the guidance provided in NRC Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," (Reference 1), CPS requests approval to implement Subsection ISTC-3540, "Manual Valves," of the 2004 Edition of the ASME OM Code. Paragraph 50.55a(f)(4)(ii) requires the use of the latest edition and addenda that have been incorporated by reference 12 months prior to the beginning of each 120-month interval. This is considered the Code of Record. Licensees that plan to use for their IST program later editions and addenda of the ASME OM Code or Section XI that have been incorporated by reference into 10 CFR 50.550 must obtain prior NRC approval pursuant to 10 CFR 50.55a(f)(4)(iv). The licensee may request this approval by submitting a letter to the NRC Document Control Desk. As noted in RIS 2004-12, licensees seeking to use later editions and addenda of the ASME Code,Section XI, pursuant to 10 CFR 50.55a(f)(4)(iv) for inservice testing items are not required to seek relief pursuant to 10 CFR 50.55a(a)(3) or 10 CFR 50.55a(f)(5)(iv).
December 3, 2008 U. S. Nuclear Regulatory Commission Page 2 RIS 2004-12 also notes that the regulations do not specify when a licensee must submit a letter requesting approval to use later editions and addenda of the Code, only that the letter must be submitted before using the proposed later Code edition and addenda. The request is detailed in the attachment to this letter and is in accordance with the guidance provided in Nuclear Energy Institute white paper entitled "Standard Format for Requests from Commercial Reactor Licensees Pursuant to 10 CFR 50.55a," (Reference 2). AmerGen requests approval of this request by December 3, 2009, to support planning for the twelfth refueling outage (C1 R12) scheduled for January 2010. There are no regulatory commitments contained in this letter. If you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 637-2804. Respectfully, K~ Patrick R. Simpson Manager - Licensing Attachment
- 10 CFR 50.55a Request Regarding Proposed Use of Subsequent ASME Code Edition and Addenda For Inservice Testing ATTACHMENT 10 CFR 50.55a Request Regarding Proposed Use of Subsequent ASME Code Edition and Addenda For Inservice Testing 1. ASME Code Component(s)
Affected 2. Applicable Code Edition and Addenda 10 CFR 50.55a Request Number 2211 Page 1 of 2 In accordance with 10 CFR 50.55a(f)(4)(iv), as clarified in NRC Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," AmerGen Energy Company, LLC (AmerGen) requests NRC approval to use portions of a later edition and addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the Clinton Power Station (CPS) Inservice Testing (IST) Program. This request affects all active function manual valves in the IST Program at CPS. The current Code of Record for CPS is the 1987 Edition up to and including the OM-10a, 1988 Addenda of the ASME Code for inservice testing. 3. Proposed Subsequent Code Edition and Addenda (or Portion) AmerGen requests approval to use the portions of the 2004 Edition of the ASME OM Code related to inservice testing of manually operated valves. Federal Register, Volume 73, Number 176, dated September 10, 2008 (73 FR 52730), incorporates by reference the 2004 Edition of the ASME OM Code for inservice testing programs in 10 CFR 50.55a(b). Specifically, AmerGen would apply the requirements of Subarticle ISTC-3540, "Manual Valves." ISTC-3540 Manual Valves. Manual valves shall be full-stroke exercised at least once every 5 years, except where adverse conditions may require the valve to be tested more frequently to ensure operational readiness. Any increased testing frequency shall be specified by the Owner. The valve shall exhibit the required change of obturator position. AmerGen proposes to apply the requirements of Subarticle ISTC-3540 to all active function manual valves in the IST Program at CPS.
ATTACHMENT 10 CFR 50.55a Request Regarding Proposed Use of Subsequent ASME Code Edition and Addenda For Inservice Testing 4. Related Requirements 10 CFR 50.55a(f)(4)(iv) states: 10 CFR 50.55a Request Number 2211 Page 2 of 2 Inservice tests of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of this section, subject to the limitations and modifications listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met. The requirements of Subarticle ISTC-3540 are modified by 10 CFR 50.55a(b)(3)(iv), which requires the exercising of manual valves at a biennial frequency rather than the 5-year frequency specified in Subarticle ISTC-3540 of the 1999 addenda through the latest edition and addenda provided that adverse conditions do not require more frequent testing. Subarticle ISTC-3540 of the 2004 Edition of the ASME OM Code contains a footnote that describes adverse conditions such as harsh service environment, lubricant hardening, corrosive or sediment-laden process fluid, or degraded valve components. All subject valves have been evaluated for these conditions. Adverse conditions have not been observed at CPS such that an exercise test frequency of less than two years would be required. 5. Duration of Proposed Request The duration of the proposed request is for the remainder of CPS's second 10-year IST interval, which began on January 1, 2000 and is scheduled to end on December 31, 2009.