JAFP-18-0052, Proposed Alternative to Utilize Code Case N-879

Proposed Alternative to Utilize Code Case N-879

ML18151A023
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	05/30/2018
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18150A385	List: JAFP-18-0052, Proposed Alternative to Utilize Code Case N-879 ML18150A387
References
JAFP-18-0052, NMP1L3223, RS-18-069, TMl-18-069
Download: ML18151A023 (8)

Text

Exelon Generation ~) 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp com 10 CFR 50.55a RS-18-069 NMP1L3223 JAFP-18-0052 TMl-18-069 May 30, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRG Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRG Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRG Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRG Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRG Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRG Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRG Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRG Docket Nos. 50-352 and 50-353

Proposed Alternative to Utilize Code Cases N-879 May 30, 2018 Page 2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-41 O Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Proposed Alternative to Utilize Code Case N-879 In accordance with 10 CFR 50.55a(z)(2), Exelon Generation Company, LLC (Exelon) is requesting a proposed alternative to the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code, Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," on the basis that compliance with the code results in hardship without a compensating increase in quality. Specifically, this proposed alternative concerns the use of Code Case N-879, "Use of Micro-Alloyed Carbon Steel Bar in Patented Mechanical Joints and Fittings, Classes 1, 2, and 3 Section Ill, Division 1." This Code Case allows the use of a material that does not comply with the limitations on material specifications and grades mandated by ASME Section Ill. A separate relief request being submitted under a separate cover, requests approval of Code Cases N-878 and N-880 to allow the procurement of material from a material supplier that does not possess ASME accreditation as a Quality System Certificate Holder or an NPT Certificate Holder.

There are no regulatory commitments contained in this letter. Exelon requests your review and approval of this fleet request by May 30, 2019.

If you have any questions, please contact Tom Loomis (610) 765-5510.

Respectfully, Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Proposed Alternative to Utilize Code Cases N-879 May 30, 2018 Page 3

Attachment:

Proposed Alternative to Utilize Code Case N-879 cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - James A. FitzPatrick Nuclear Power Plant NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - Quad Cities Nuclear Power Station NRC Project Manager - R.E. Ginna Nuclear Power Plant NRC Project Manager - Three Mile Island Nuclear Station, Unit 1

Attachment Proposed Alternative to Utilize Code Case N-879

10 CFR 50.55a RELIEF REQUEST Revision O (Page 1 of 4)

Proposed Alternative to Utilize Code Case N-879 in Accordance with 10 CFR 50.55a{z)(2)

1. ASME Code Component(s) Affected:

All ASME Class 1, 2, and 3 carbon steel piping systems Nominal Pipe Size (NPS) 2 and smaller.

2. Applicable Code Edition and Addenda

PLANT INTERVAL EDITION START END Braidwood Station, Units Fourth 2013 Edition August 29, 2018 July 28, 2028 1and2 October 17, 2018 October 16, 2028 Byron Station, Fourth 2007 Edition, through 2008 July 16, 2016 January 15, 2026 Units 1 and 2 Addenda Calvert Cliffs Nuclear Fourth 2004 Edition October 10, 2009 June 30, 2019 Power Plant, Units 1 and 2

Clinton Power Station, Third 2004 Edition July 1, 2010 June 30, 2020 Unit 1 Dresden Nuclear Power Fifth 2007 Edition, through 2008 January 20, 2013 January 19, 2023 Station, Units 2 and 3 Addenda James A. FitzPatrick Fifth 2007 Edition, through 2008 August 1, 2017 June 15, 2027 Nuclear Power Plant Addenda LaSalle County Stations, Fourth 2007 Edition, through 2008 October 1, 2017 September 30, 2027 Units 1 and 2 Addenda Limerick Generating Fourth 2007 Edition, through 2008 February 1, 2017 January 31, 2027 Station, Units 1 and 2 Addenda Nine Mile Point Nuclear Fourth 2004 Edition August 23, 2009 August22,2019 Station, Unit 1 Nine Mile Point Nuclear Fifth 2013 Edition August23,2019 August22,2029 Station, Unit 1 Nine Mile Point Nuclear Third 2004 Edition April 5, 2008 August 22, 2018 Station, Unit 2 Nine Mile Point Nuclear Fourth 2013 Edition August 23, 2018 August22,2028 Station, Unit 2 Peach Bottom Atomic Fourth 2001 Edition, through 2003 November 5, 2008 December 31 , 2018 Power Station, Units 2 Addenda and 3

10 CFR 50.55a RELIEF REQUEST Revision O (Page 2 of 4)

PLANT INTERVAL EDITION START END Peach Bottom Atomic Fifth 2013 Edition January 1, 2019 December 31, 2028 Power Station, Units 2 and 3 Quad Cities Nuclear Fifth 2007 Edition, through 2008 April 2, 2013 April 1, 2023 Power Station, Units 1 Addenda and 2 R. E. Ginna Nuclear Fifth 2004 Edition January 1, 201 O December 31, 2019 Power Plant Three Mile Island Nuclear Fourth 2004 Edition April 20, 2011 April 19, 2022 Station, Unit 1

3. Applicable Code Requirement

ASME Code, Section Ill, NB/NC/ND-2121 (a), of the 1971 Edition through the 2017 Edition, provides requirements for materials to be used in Class 1, 2, and 3 piping systems.

4. Reason for Request

In accordance with 10 CFR 50.55a(z)(2), Exelon Generation Company, LLC (Exelon) is requesting a proposed alternative from the ASME Section Ill, NB/NC/ND-2121 (a) requirements for compliance with the specifications for material given in ASME Section II, Part D (previously Section 111, Division 1, Appendix I), Subpart 1, Tables 1A, 18, 2A or 28, as applicable, on the basis that compliance with code results in hardship without a compensating increase in quality.

Exelon desires to use nonstandard, proprietary, welded or nonwelded pipe fittings in applications requiring compliance with ASME Section Ill, without having to comply with the limitations on material specifications and grades mandated by Section Ill. Compliance with the ASME Code results in additional critical path time, cost, and radiation exposure that can be avoided through use of the code case.

Code Case N-879 ("Use of Micro-Alloyed Carbon Steel Bar in Patented Mechanical Joints and Fittings, Classes 1, 2, and 3 Section Ill, Division 1,") permits use of a micro-alloyed steel composition similar to that of ASME SA-675 and ASTM A 576 Grade 1524, with additions of vanadium and nitrogen, to enhance the strength needed to ensure a high-strength, leak-tight mechanical joint. The additional strength ensures that the deformation produced during installation of the fittings occurs in the pipe material, rather than in the fitting material. It is this deformation that produces the stresses necessary for the joint structural and leak-tight integrity.

This Code Case will expand Exelon's ability to use these proprietary fittings in safety-related piping, by including coverage for ASME Section Ill, Class 1, 2, and 3 systems NPS 2 or smaller. These provisions may also be used for installation of these fittings in 831.7 Class 1, 2, and 3 piping NPS 2 or smaller.

10 CFR 50.55a RELIEF REQUEST Revision o (Page 3 of 4)

These fittings are already permitted to be used in safety-related piping constructed in accordance with ASME 831.1. These fittings are also already permitted to be used in compression-type fittings in ASME Section Ill, Class 1, 2, and 3 instrument lines, up to NPS 1, in accordance with NB/NC/ND-2121 (f) in the Winter 1972 Addenda through Winter 1973 Addenda, and NB/NC/ND-2121 (d) through the 2017 Edition.

Most piping fabrication and installation joints have been traditionally fabricated by welding.

Installation of pipe and piping subassemblies by mechanical means can save significant amounts of time, money, critical path time, and radiation exposure to plant personnel and installation and examination contractors. In systems containing radioactive materials, or in systems near irradiated components, personnel can be subjected to significant amounts of radiation during preparation for welding, welding, and nondestructive examination (NDE) of welds. Most of this exposure can be eliminated by use of mechanical connections. The amount of time to which mechanical installation personnel are exposed is a fraction of the time to which a welder or a nondestructive examiner would be exposed. Without installation welds, there is no associated installation NOE.

5. Proposed Alternative and Basis for Use:

Exelon proposes to implement the requirements of Code Case N-879 for procurement of nonstandard, proprietary welded and nonwelded pipe fittings NPS 2 or smaller.

ASME Section XI requires the fittings to be designed and manufactured in accordance with the original Construction Code, which, for these applications, is ASME Section Ill. These fittings are typically designed in accordance with ASME Section Ill, NB-3671.7, "Sleeve Coupled and Other Patented Joints," using the option of prototype testing. Alternatively, NC/ND-3671.7 may be used for Class 2 or 3 fittings, as applicable.

Reconciliation and use of editions and addenda of ASME Section 111 will be in accordance with ASME Section XI, IWA-4220, and only editions and addenda of ASME Section Ill that have been accepted by 10 CFR 50.55a may be used. The Code of Record for the specific 10-year ISi interval at each nuclear unit as identified under Section 2 above, will be used when applying the requirements of Section XI, unless specific regulatory relief to use of other editions or addenda is approved.

All other ASME Section XI requirements for which relief was not specifically requested and authorized by the NRG Staff will remain applicable, including third party review by the Authorized Nuclear lnservice Inspector.

Without the use of this Case in some situations, outage times could be increased, and plant and contractor personnel will receive significantly higher radiation doses, due to longer exposure times in the vicinity of the piping joint installation.

Based on the above, use of Code Case N-879 applies when compliance with the ASME Section Ill requirement for compliance with the specifications for material given in ASME Section II, Part D (previously Section Ill, Division 1, Appendix I), Subpart 1, Tables 1A, 18, 2A or 28, as applicable, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 4 of 4)

Code Case N-879 was approved by the ASME Board on Nuclear Codes and Standards on May 10, 2017. It has not yet been incorporated into NRC Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1," and thus is not available for application at nuclear power plants without specific NRC approval. Therefore, Exelon requests use of the alternative material requirements described in this Code Case via this relief request.

6. Duration of Proposed Alternative:

The proposed alternative is for use of the Case for the remainder of each plant's 10-year inspection interval as specified in Section 2 and for the remainder of the plant's life.

7. Precedent:

None