ML20212A470

Rssponds to NRC 990709 RAI Re Util Relief Request to Allow Use of 1998 Edition of ASME Section Xi,Subsection Iwe. Acceptance Criteria for Liner Plate Pressure Boundary Thickness Will Be Limited to 10% Nominal Thinning

ML20212A470
Person / Time
Site:	Callaway
Issue date:	09/10/1999
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-MA4598, ULNRC-4109, NUDOCS 9909170023
Download: ML20212A470 (5)

Text

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Union El ctric

' One Ameren Plaza 1901 Chouteau Avenue PO Box 66149

, St. Louis, MO 63166-6149 314621.3222 September 10,1999 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001

$IL ULNRC-4109

[IIO[III TAC NO. MA4598

1. E cenamen:

DOCKET NUMBER 50483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON RELIEF REQUEST TO ALLOW THE USE OF THE 1998 EDITION OF ASME SECTION XI. SUBSECTION IWE

References:

(1) ULNRC-3938, dated January 11,1999 (2) Letter dated June 24,1999 from J. N. Donohew, NRC, to G. L. Randolph (3) ULNRC-4063, dated July 9,1999 AmerenUE requested relief to use the 1998 Edition of ASME Section XI, Subsection IWE in lieu of the 1992 Edition and 1992 A 1denda of the Code via Reference 1. The NRC staff requested additional information to complete their review of this relief request in Reference 2. The requested informati'a was provided in Reference 3.

This letter, which revises our response to question 6 in Reference 3, is submitted as a result of discussions held on August 25 and September 10,1999 with NRC staff. Based upon these discussions, the acceptance criteria for liner plate pressure boundary thickness will be limited to 10% nominal thinning.

9909170023 990910

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,' , ULNRC-4109 j September 10,1999 Attached is a reprint of question 6 from Reference 2 with our revised response. if you have any questions concerning this response, please contact us. ) 1 Very truly yours, MJPL p Alan C. Paslwater Manager, Corporate Nuclear Services ,

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I STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

David Shafer, of lawful age, being first duly sworn.upon oath says that he is Supervising Engineer, Corporate Nuclear Services, Regulatory Operations for Union Electric Company; that he has read the foregoing document

-and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By M ,

David Shafer Supervising Engineer, Regulatory Operations, Corporate Nuclear Services SUBSC of n BED JA nd sporp to before me this M AT'

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, 1999.

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IEUB8A L ORR NotaryPublic NotarySeal 7

STATE OF MISS0t2 City of St. Louis My Commission Expires: June 23,2003

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cc:~ M. H. Fletcher Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 Regional Administrator U.S. Nuclear Regulatory Commission

. Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack Donohew (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department ,

Missouri Public Service Commission I P.O. Box 360 Jefferson City, MO 65102

ULNRC - 4109

,. Attachment 1

. . l REQUEST FOR ADDITIONAL INFORMATION ,

CALLAWAY PLANT ASME SECTION XI, SUBSECTION IWE On July 7,1999 AmerenUE submitted ULNRC-4063 for additional information concerning our relief request to use the 1998 Edition of ASME Section XI, Subsection IWE in lieu of the 1992 Edition and 1992 Addenda. This was in response to a Nuclear Regulator Commission letter TAC NO. MA4598 dated June 24,1999 to Mr. Garry L Randolph of Callaway Plant Subsequent to that submittal, per telephone conversation with Nuclear Regulatory Commission Staff on August 25,1999 and September 10,1999, Callaway Plant is hereby revising our response to Item 6 on ULNRC-4063. Following is a reprint of Item 6 from NRC letter TAC NO MA4598.

6. UE letter dated January 11,1999, states that metallic liners of Class CCpressure l retaining components are not subject to the same requirements as Class MC containments (IWE 3511.3,1998 Edition of the Code), therefore, the 10% material loss is not significant. However, alternative acceptance criteria, based on the discontinuity efects of thickness differences and anchor spacing, have not been defined. Is it the intent of the Callaway Plant not to document orperform supplemental examinations of the liner when loss ofmaterial has been detected? Describe when and how the supplemental examinations (as required by IWE-3200) of the liner will be performed and the associated acceptance criteria that will be used. Please refer to NRC Information Notice 97-10, " Liner Plate Corrosion in Concrete Containments."for relevant information.

Revision to Item 6:

Acceptance criteria for liner plate pressure boundary thickness at Callaway Plant will be limited to 10% nominal thinning. Any defects or deterioration greater than 10% in depth will be documented by qualified NDE QC inspectors and evaluated by Engineering on a case by case basis. Any section of the liner plate pressure boundary that is found to be unacceptable by Engineering evaluation will either be repaired or replaced under Callaway Plant's ASME Section XI, IWE repair / replacement program.