JAFP-18-0053, Proposed Alternative to Utilize Code Cases N-878 and N-880

Proposed Alternative to Utilize Code Cases N-878 and N-880

ML18151A028
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
References
JAFP-18-0053, NMP1L3224, RS-18-070, TMl-18-070
Download: ML18151A028 (9)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.55a RS-18-070 NMP1L3224 JAFP-18-0053 TMl-18-070 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 NRC 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 NRC 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 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Proposed Alternative to Utilize Code Case N-878 and N-880 May 30, 2018 Page2 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 Cases N-878 and N-880 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-878 ("Alternative to QA Program Requirements of IWA-4142 Section XI, Division 1") and N-880 ("Alternative to Procurement Requirements of IWA-4143 for Small Nonstandard Welded Fittings Section XI, Division 1"). These Code Cases address 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. A separate relief request being submitted under a separate cover, requests the use of Code Case N-879 which allows the use of material that does not comply with the limitations on material specifications and grades mandated by ASME, Section Ill.

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, d(ANl\f, l~

James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

Proposed Alternative to Utilize Code Case N-878 and N-880 May 30, 2018 Page3

Attachment:

Proposed Alternative to Utilize Code Cases N-878 and N-880 cc: Regional Administrator - NRG Region I Regional Administrator - NRG Region Ill NRG Senior Resident Inspector - Braidwood Station NRG Senior Resident Inspector - Byron Station NRG Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRG Senior Resident Inspector - Clinton Power Station NRG Senior Resident Inspector - Dresden Nuclear Power Station NRG Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRG Senior Resident Inspector - LaSalle County Station NRG Senior Resident Inspector - Limerick Generating Station NRG Senior Resident Inspector - Nine Mile Point Nuclear Station NRG Senior Resident Inspector - Peach Bottom Atomic Power Station NRG Senior Resident Inspector - Quad Cities Nuclear Power Station NRG Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRG Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRG Project Manager - Braidwood Station NRG Project Manager - Byron Station NRG Project Manager - Calvert Cliffs Nuclear Power Plant NRG Project Manager - Clinton Power Station NRG Project Manager - Dresden Nuclear Power Station NRG Project Manager - James A. FitzPatrick Nuclear Power Plant NRG Project Manager - LaSalle County Station NRG Project Manager - Limerick Generating Station NRG Project Manager - Nine Mile Point Nuclear Station NRG Project Manager - Peach Bottom Atomic Power Station NRG Project Manager - Quad Cities Nuclear Power Station NRG Project Manager - R.E. Ginna Nuclear Power Plant NRG Project Manager - Three Mile Island Nuclear Station, Unit 1

Attachment Proposed Alternative to Utilize Code Cases N-878 and N-880

10 CFR 50.55a RELIEF REQUEST Revision 0 (Page 1 of 5)

Proposed Alternative to Use Code Cases N-878 and N-880 in Accordance with 10 CFR 50.55a(z)(2)

1. ASME Code Component(s) Affected:

All ASME Class 1, 2, and 3 carbon steel and stainless-steel piping systems.

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 August 22, 2029 Station, Unit 1 Nine Mile Point Nuclear Third 2004 Edition April 5, 2008 August22,2018 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 5)

PLANT INTERVAL EDITION START END Peach Bottom Atomic Fifth 2013 Edition January 1, 2019 December 31, 2028 Power Station, Units 2 and3 Quad Cities Nuclear Fifth 2007 Edition, through 2008 April 2, 2013 April 1, 2023 Power Station, Units 1 Addenda and2 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 Requirements:

Code Case N-878 ("Alternative to QA Program Requirements of IWA-4142 Section XI.

Division 1")

ASME Code, Section XI, IWA-4142 of the 2001 Edition with the 2003 Addenda, the 2004 Edition, the 2007 Edition with 2008 Addenda, and the 2013 Edition, provide requirements for procurement of materials to be used in repair/replacement activities.

Code Case N-880 ("Alternative to Procurement Requirements of IWA-4143 for Small Nonstandard Welded Fittings Section XI, Division 1")

ASME Code, Section XI, IWA-4142 and IWA-4143, of the 2001 Edition with the 2003 Addenda, the 2004 Edition, the 2007 Edition with 2008 Addenda, and the 2013 Edition, provide requirements for procurement of materials by the Owner, and fabrication of non-Code-stamped parts by the Owner, when the Construction Code is Section Ill, to be used in repair/replacement activities.

4. Reason for Request

In accordance with 10 CFR 50.55a(z)(2), Exelon Generation Company, LLC (Exelon) is requesting proposed alternatives from the ASME Section XI, IWA-4200 requirements for compliance with Section Ill, NA-3700 or NCA-3800, as applicable, for procurement of nonstandard, nonwelded, proprietary pipe fittings larger than NPS 1 or Reactor Coolant System (RCS) makeup capacity, supplied as material, installed in Section XI repair/replacement activities in applications where the Construction Code is ASME Section Ill Winter 1973 addenda or later. Section XI, IWA-4142.1 of the 2007 Edition or later, specifies alternative procurement requirements for the Owner, but these alternatives may not be used by a non-ASME-accredited contracted Repair/Replacement Organization.

Section XI permits use of these fittings in ASME 831.1, 831.7, or pre-Winter 1973 applications. Compliance with the ASME Code results in additional critical path time, cost, and radiation exposure that can be avoided through use of the Case.

10 CFR 50.55a RELIEF REQUEST Revision O (Page 3 of 5)

In accordance with 10 CFR 50.55a(z)(2), Exelon is requesting proposed alternatives from the ASME Section XI, IWA-4200 requirements for compliance with Section Ill, NA-8000 or NCA-8000, as applicable, for fabrication of nonstandard, proprietary welded pipe fittings larger than NPS 1 or RCS makeup capacity up to NPS 2, installed in Section XI repair/replacement activities in applications where the Construction Code is ASME Section Ill 1971 edition or later. Section XI, IWA-4143 permits fabrication of welded fittings at the Owner's facilities, but does not permit such fabrication to be performed in a facility owned by a Repair/Replacement Organization or other contractor or supplier. 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.

Both Cases Exelon is requesting to use nonstandard, proprietary, welded or nonwelded pipe fittings in applications requiring compliance with ASME Section Ill, without having to comply with the administrative requirements imposed by ASME Section XI, IWA-4142, IWA-4143, and IWA-4200.

Nonstandard, proprietary welded or nonwelded pipe fittings can be proven, by testing, to comply with Section Ill design requirements. Exelon has a supplier of such fittings that does not possess ASME accreditation as a Quality System Certificate Holder or an NPT Certificate Holder.

Exelon is currently permitted by ASME Section XI to install the following:

1. Welded or nonwelded fittings produced by a non-ASME-accredited supplier in safety-related applications in ASME 831.1 or 831.7 Class I, II, or Ill piping systems (IWA-4221 ).

2. Welded or nonwelded fittings produced by a non-ASME accredited supplier in Class 1 systems no larger than NPS 1 and no larger than RCS makeup capacity (IWA-4131).

3. Welded or nonwelded fittings produced by this supplier in Class 2 or 3 systems NPS 1 or smaller (IWA-4131 ).

4. Nonwelded fittings produced by a non-ASME accredited supplier in ASME Section Ill Class 1, 2, and 3 piping systems as permitted by the reference code year.

5. Nonwelded fittings NPS 2 and smaller produced by this supplier in ASME Section Ill Class 1 , 2, and 3 piping systems, provided Exelon verifies material conformance with the reference code year.

6. Nonwelded fittings larger than NPS 2 produced by a non-ASME-accredited supplier in ASME Section Ill Class 1, 2, and 3 piping systems, with additional material testing by Exelon as permitted by the reference code year.

10 CFR 50.55a RELIEF REQUEST Revision O (Page 4 of 5)

7. Welded fittings fabricated by a non-ASME-accredited supplier in Class 2 and 3 piping systems in plants with construction permits issued before the NRC made Section 111 compliance and Code Symbol Stamping of Class 2 and 3 systems mandatory in 10 CFR 50.55a on May 14, 1984 (49 FR 9711) (IWA-4221 and 10 CFR 50.55a).

Exelon is not currently permitted by ASME Section XI to install the following:

1. Nonwelded fittings larger than NPS 1, or RCS makeup capacity, fabricated by a non-ASME-accredited supplier, and purchased by a contractor without ASME accreditation without additional material testing by Exelon, in Section Ill, Class 1, 2, and 3 piping systems certified to the Section Ill Winter 1973 Addenda or later.

2. Welded fittings larger than NPS 1, or RCS makeup capacity, fabricated by a non-ASME accredited supplier in Section Ill, Class 1, 2, and 3 piping systems certified to the Section 111 1971 Edition or later.

These two Cases will expand Exelon's ability to use these proprietary fittings in sizes larger than NPS 1, or RCS makeup capacity, in Section Ill, Class 1, 2, and 3 systems.

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 (NOE) 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 ASME Code Cases N-878 for procurement of nonstandard, nonwelded, proprietary pipe fittings larger than NPS 1, or RCS makeup capacity, supplied as material, and N-880 for procurement of nonstandard, proprietary welded pipe fittings larger than NPS 1, or RCS makeup capacity, up to NPS 2.

ASME Section XI requires the fittings to be designed 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/N0-3671.7 may be used for Class 2 or 3 fittings, as applicable.

Reconciliation and use of editions and addenda of ASME Section Ill 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 various IWA paragraphs of Section XI, unless specific regulatory relief to use other editions or addenda is approved.

10 CFR 50.55a RELIEF REQUEST Revision O (Page 5 of 5)

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

Without the use of these Code Cases 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 Cases N-878 and N-880 apply when compliance with the ASME Section Ill administrative requirement for possession of a Quality System Certificate (N-878) or NPT Certificate of Authorization (N-880) would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Code Cases N-878 and N-880 were approved by the ASME Board on Nuclear Codes and Standards on April 18, 2017 and July 25, 2017, respectively. They have not yet been incorporated into NRC Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability, ASME Section XI, Division 1," and thus are not available for application at nuclear power plants without specific NRC approval. Therefore, Exelon requests use of the alternative procurement requirements described in these Cases via this relief request.

6. Duration of Proposed Alternative:

The proposed alternative is for use of the Cases 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