ML092300587

Relief Request for Use of Subsequent Edition and Addenda or American Society of Mechanical Engineers Code for Inservice Testing

ML092300587
Person / Time
Site:	Clinton
Issue date:	08/20/2009
From:	Shawn Campbell Plant Licensing Branch III
To:	Pardee C Exelon Nuclear
Goodwin, Cameron S, NRR/DORL, 415-3719
References
TAC ME0217
Download: ML092300587 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 20, 2009 Mr. Charles Pardee President and Chief Nuclear Office Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO.1 - RELIEF REQUEST FOR USE OF SUBSEQUENT EDITION AND ADDENDA FOR THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) CODE FOR INSERVICE TESTING (TAC NO. ME0217)

Dear Mr. Pardee:

By letter to the Nuclear Regulatory Commission (NRC) dated December 3, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083380760),

AmerGen Energy Company, LLC (AmerGen), the licensee, submitted a request for approval to use a portion 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 inservice testing (1ST) program at Clinton Power Station, Unit NO.1 (CPS). Specifically, approval was requested to apply the requirements of paragraph ISTC-3540, "Manual Valves," of the 2004 Edition of the ASME OM Code related to the 1ST of manually operated valves.

AmerGen requested approval through the remainder of CPS's second 10-year 1ST interval, which began on January 1, 2000, and ends on December 31, 2009.

At the time of the application, AmerGen was the licensee for CPS. AmerGen was a wholly owned subsidiary of Exelon Generation Company, LLC (EGC). On January 8,2009, EGC eliminated AmerGen and transferred the operating licenses of the AmerGen reactor plants to EGC. By letter dated January 9,2009 (ADAMS Accession No. ML090120538), EGC adopted and endorsed docketed submittals that requested specific licensing actions that were made by AmerGen, and requested that the NRC staff continue to process those pending actions on the schedules previously agreed to by AmerGen.

The NRC staff has completed its review of this relief request. The details of the NRC staff's review are included in the enclosed safety evaluation. Accordingly, this relief request is acceptable, and subject to the limitations and modifications listed in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(b)(3)(vi). Therefore, pursuant to 10 CFR 50.55a(f)(4)(iv), the NRC staff approves the request to use the 2004 Edition of the ASIVIE OM Code, Paragraph ISTC-3540.

C. Pardee -2 If you have any questions, please contact the Clinton Project Manager, Mrs. Cameron Goodwin, at 301-415-3719.

~0~

Stephen J. Campbell, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST FOR USE OF SUBSEQUENT CODE FOR INSERVICE TESTING EXELON GENERATION COMPANY, LLC CLINTON POWER STATION, UNIT NO.1 DOCKET NO. 50-461

1.0 INTRODUCTION

By letter dated December 3, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083380760), AmerGen Energy Company, LLC (AmerGen), the licensee, submitted a request for 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 inservice testing (1ST) program at Clinton Power Station, Unit NO.1 (CPS). Specifically, approval was requested to apply the requirements of paragraph ISTC-3540, "Manual Valves," of the 2004 Edition of the ASME OM Code related to 1ST of manually operated valves. AmerGen requested approval through the end of the current (second) 1ST interval, which ends on December 31, 2009.

At the time of the application, AmerGen was the licensee for CPS. AmerGen was a wholly owned subsidiary of Exelon Generation Company, LLC (EGC). On January 8, 2009, EGC eliminated AmerGen and transferred the operating licenses of the AmerGen reactor plants to EGC. By letter dated January 9, 2009 (ADAMS Accession No. ML090120538), EGC adopted and endorsed docketed submittals that requested specific licensing actions that were made by AmerGen, and requested that the U.S. Nuclear Regulatory Commission (NRC) staff continue to process those pending actions on the schedules previously agreed to by AmerGen.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(f), requires 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 incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the NRC pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(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 50.55a(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 50.55a(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.

- 2 NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482 Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants."

3.0 TECHNICAL EVALUATION

3.1 Affected Components All active function manual valves in the CPS 1ST program.

3.2 Applicable Code The applicable Code of record for CPS is the ASME OM Code, 1987 Edition with 1988 Addenda. This Code requires that active Category A and B valves be tested nominally every 3 months, with certain exceptions.

3.3 Proposed Portion of Subsequent Code Edition and Addenda The licensee requested approval to use the portions of the 2004 Edition of the ASME OM Code related to 1ST of manually operated valves. Federal Register, Volume 73, Number 176, dated September 10, 2008 (72 FR 52730) incorporates by reference the 2004 Edition of the ASME OM Code for 1ST programs in 10 CFR 50.55a(b).

Specifically, the licensee would apply the requirements of paragraph ISTC-3540, which state that "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."

The licensee proposes to apply paragraph ISTC-3540 to all active function manual valves in the 1ST program at CPS. In accordance with the limitation imposed by 10 CFR55a(b)(3)(vi), manual valves must be exercised on a 2-year interval rather than a 5-year interval specified in paragraph ISTC-3540 of the 2004 Edition, provided that adverse conditions do not require more frequent testing. The licensee stated that adverse conditions have not been observed for manual valves within the scope of the 1ST program. Therefore, a test exercise interval of less than 2 years would not be required.

3.4 Technical Bases Federal Register, Volume 73, Number 176, dated September 10, 2009 (73 FR 52730) incorporates by reference the 2004 Edition of the ASME OM Code for 1ST programs in 10 CFR 50.55a(b), subject to the modifications and limitations imposed by 10 CFR 50.55a(b)(3).

3.5 Duration of Proposed Request The duration of the proposed request is through the second 1ST interval, which ends December 31,2009, for CPS.

-3 3.6 NRC Staff Evaluation The requirements of 10 CFR 50.55a(f)(4)(iv) allow licensees to use subsequent editions and addenda of the ASME OM Code, provided that editions and addenda are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed in 10 CFR 50.55a(b)(3), 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 10 CFR 50.55a(b) allow use of the 2004 Edition of the ASME OM Code, subject to the modifications and limitations imposed by 10 CFR 50.55a(b)(3).

The licensee has requested approval to exercise manual valves in accordance with paragraph ISTC-3540 of the 2004 Edition of the ASME OM Code. The licensee also acknowledged the requirement to test the manual valves consistent with the limitation imposed by 10 CFR 50.55a(b)(3)(vi), on a 2-year interval rather than the 5-year interval specified in the 2004 Edition of the ASME Code, provided that adverse conditions, as defined in footnote 2 to paragraph ISTC-3540, do not require more frequent testing. The NRC staff has identified no additional related requirements in the specified ASME OM Code Edition that needs to be met in order to implement the use of paragraph ISTC-3540.

4.0 CONCLUSION

Based on the above evaluation, the staff finds the licensee's request to use the 2004 Edition of the ASME OM Code, paragraph ISTC-3540, for manual valve 1ST for the remainder of the second 10-year 1ST interval at CPS acceptable, and subject to the limitations and modifications listed in 10 CFR 50.55a(b)(3)(vi). Therefore, pursuant to 10 CFR 50.55a(f)(4)(iv), the staff approves the request to use the 2004 Edition of the ASME OM Code, Paragraph ISTC-3540.

Principal Contributor: RWolfgang, NRR Date: August 20, 2009

C. Pardee -2 If you have any questions, please contact the Clinton Project Manager, Mrs. Cameron Goodwin, at 301-415-3719.

Sincerely, IRA!

Stephen J. Campbell, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosure:

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