A07780, Comments on NRC 890123 SER Approving Inservice Insp Program, Third 10-yr Interval,Rev 1.Util Will Upgrade Classification of Svc Water Supply & Return Lines to Containment Air Recirculation Fan Coolers to ASME Class 2

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Comments on NRC 890123 SER Approving Inservice Insp Program, Third 10-yr Interval,Rev 1.Util Will Upgrade Classification of Svc Water Supply & Return Lines to Containment Air Recirculation Fan Coolers to ASME Class 2
ML20247K280
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 05/24/1989
From: Mroczka E
CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
A07780, A7780, TAC-65687, NUDOCS 8906010263
Download: ML20247K280 (2)


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oa ., RTFORD ONNECTICUT 06141-0270 g L y fu May 24, 1989 Docket No. 50-213 A07780 Re: 10 CFR 50.55a(g)

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Haddam Neck Plant Comments on NRC Staff Safety Evaluation Third 10-Year Interval In-Service Inspection Proaram (TAC No. 65687)

In a letter dated January 23,1989,II) the NRC Staff issued a safety evalua-tion report (SER) approving the In-Service Inspection (ISI) Program, Third 10-Year Interval, Revision 1, for the Hagm Neck Plant, submitted to the NRC Staff in a letter dated May 24, 1988. Connecticut Yankee Atomic Power Company (CYAPC0) has reviewed the Staff's SER and offers the following com- .

l ments: ,

1. The NRC Staff's January 23, 1989, letter states that "The ISI Program i Plan was reviewed for its compliance with the requirements of the 1983 Edition, Summer 1983 Addenda of the ASME Code Section XI with the follow-ing exceptions: (1) the extent of examination for Code Class 1 and Code Class 2 piping welds has been determined by the 1974 Edition through Summer 1975 Addenda (74S75) as permitted by 10 CFR 50.65a(b); and (b) the alternate rules of ASME Code Case N-408 are being used for the examina-tion of all pressure retaining welds in austenitic stainless steel or i

high alloy piping in Class 2 systems." CYAPC0's letter dated May 24,  ;

1988, discussed a third exception which should have been addressed by the Sec-NRC Staff. The Third 10-Year Interval Submittal, Revision 1, tion 4.0, Evaluation Criteria, bases some of the acceptance standards i

(1)

J. F. Stolz letter to E. J. Mroczka, " Safety Evaluation on the Third l 10-Year Interval Inservice Inspection Program for th: Haddam Neck Plant.

(TAC No. 65687)," dated January 23, 1989.

l' (2)

E. J. Mroczka letter to U.S. Nuclear Regulatory Ccmmission, "Haddam Neck Plant, Additional Information, Inservice Inspection Program," dated ,

]

j May 24, 1988.

ADO 8906010263 890524 /i gDR ADOCK 0500g3

U.S." Nuclear Regulatory Commission A07780/Page 2 May 24, 1989 upon the requirements of the 1983 Edition through Winter 1985 Addenda of ASME Section XI.

2. The NRC Staff states that Class 2 piping welds in the chemical and volume

! control system (CVCS) have been exempted from surface and volumetric examination. Based on further review of the isometric drawings, certain piping welds are no longer exempt from surface examination. CYAPC0 has decided that a 7.5 percent sample of the CVCS will be examined.

3. The NRC Staff states that Class 2 piping welds in the containment spray system have been exempted from surface and volumetric examinations. The statement is incorrect because the containment spray system is not considered a safety-related system at the Haddam Neck Plant. The con-tainment spray system is intended to be a backup to the containment air recirculation (CAR) fans, coolers, and filters. The containment spray system is not credited ^:n any of the safety analyses for the Haddam Neck Plant; therefore, it is.not part of the ISI program.
4. The NRC Staff states that the CAR fan cooler system should be examined pursuant to 10 CFR 50.55a(b)(2)(iv). CYAPC0 will upgrade the classifica-tion of the service water supply and return lines (inside containment) to the CAR fan coolers to ASME Class 2. The extent of examinations will be based upon the requirements of the 1974 Edition, Summer 1975 Addenda of ASME Section XI.

Please contact us if you have any questions or would like to discuss this further.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY M -

E.fd'. 'M'ro'cz k a#' I Senior Vice President cc: W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant l

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