B11882, Responds to NRC Re Unresolved Item Noted in Insp Rept 50-336/83-17.Use of Recent ASME Code Editions W/O Prior NRC Concurrence Justified.Nrc Approval Will Be Obtained Prior to Use of Subsequent Editions or Addenda

Responds to NRC Re Unresolved Item Noted in Insp Rept 50-336/83-17.Use of Recent ASME Code Editions W/O Prior NRC Concurrence Justified.Nrc Approval Will Be Obtained Prior to Use of Subsequent Editions or Addenda

ML20211G413
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	04/07/1986
From:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20211G406	List: B11882, Responds to NRC Re Unresolved Item Noted in Insp Rept 50-336/83-17.Use of Recent ASME Code Editions W/O Prior NRC Concurrence Justified.Nrc Approval Will Be Obtained Prior to Use of Subsequent Editions or Addenda IR 05000336/1983017
References
B11882, TAC-61847, NUDOCS 8606190403
Download: ML20211G413 (8)

Text

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.au .. . ma. cw L L J  %['[.((2,2,$~'. (203) 66s-s000 April 7,1986 Docket Nos. 50-213 50-245 50-336 50 423 B11882 Mr. Stewart D. Ebneter, Director Division of Reactor Safety Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Interpretation of 10 CFR 50.55a(gX4Xiv)

Introduction In an August 18,1983 letter (I), transmitting Inspection Report No. 50-336/83-17 for Millstone Unit No. 2, the NRC Staff identified unresolved item 83-17-01.

Unresolved item 83-17-01 concerned the use of portions of ASME Code Editions referenced by 10 CFR 50.55(a) but more recent than the Edition approved in the current Millstone Unit No. 2 Inservice Inspection Program.

As indicated in Inspection Report No. 50-336/83-17,' Northeast Nuclear Energy Company (NNECO) (and Connecticut Yankee Atomic Power Company (CYAPCO)) understood that it was permissible to use any portion of an ASME Code Edition referenced by 10 CFR 50.55a. Upon furtner investigation, NNECO i

and CYAPCO are prepared to accept an interpretation of 10 CFR 50.55a(gX4Xiv) which allows for the use of portions of later ASME Code Editions, referenced in 10 CFR 50.55a, with orlor NRC concurrence.

The purpose of this letter is to document our earlier interpretation of 10 CFR 50.55a(g)(4Xiv) and to address the situations in which a portion of an updated code edition or an entire updated code edition was used without prior NRC approval. The status of all four nuclear units in the Northeast Utilities system is addressed, individually, as follows.

(1)T.T. Martin letter to W. G. Counsil, dated August 18, 1983.

8606190403 860612 6 PDR ADOCK 0500 G

2 Haddam Neck Plant The Haddam Neck Plant Inservice Inspection Program is currently approved with the ASME Boiler and Pressure Vessel Code, editions through the 1974 Edition and addenda through the Summer 1975 Addenda subject to the limitations listed in paragraph (b) of 10 CFR 50.55a. CYAPCO is currently utilizing editions through the 1980 Edition and addenda through the Winter 1980 Addenda at the Haddam Neck Plant as noted in an April 9,1984(2) letter.

While CYAPCO did not obtain NRC approval prior to use of the later ASME Code Edition, CYAPCO did determine that the intent of the NRC Inservice inspection Program requirements would be met when the later Code Edition was utilized and that use of the later code edition was technically acceptable and appropriate. CYAPCO is currently awaiting Staff review and approval of the April 9,1984 request.

Millstone Unit No.1 The Millstone Unit No.1 Inservice Inspection Program secong approved ten-year interval the use started on December 28,1980. The NRC, on April 10, 1981,(

of ASME Boiler and Pressure Vessel Code, editions through the 1977 Edition and addenda through the Summer 1978 Addenda subject to the limitations listed in paragraph (b) of 10CFR50.55a.

Subsequently, in NRC Inspection Report No. 50 245/82-20(4) the Staff reviewed NNECO's assessment that the ASME Code 1980 Edition through Winter 1980 Addenda would be appropriate for use at Millstone Unit No. I and concluded that use of this updated code edition at Millstone Unit No. I was acceptable.

Accordingly, The Millstone Unit No.1 Inservice Inspection Program is currently approved with the ASME Boiler and Pressure Vessel Code, editions through the 1980 Edition r.nd addenda through the Winter 1980 Addenda subject to the limitations listed in paragraph (b) of 10 CFR 50.55a. NNECO has not used any portions of later ASME Code Editions at Millstone Unit No. '.

Millstone Uni No. 2 The Millstone Unit No. 2 Inservice Inspection Program in question was approved with the ASME Boiler and Pressure Vessel Code Editions through the 1974 l Edition and addenda through the Summer 1975 Adcenda subject to the limitations l

listed in paragraph (b) of 10 CFR 50.55a.

i l

l (2)W. G. Counsil letter to D. M. Crutchfield, dated April 9,1984.

! (3)D. M. Crutchfield letter to W. G. Counsil, dated April 10, 1981.

! b)T. T. Martin letter to W. G. Counsil, dated November 3,1982.

t

. The only use of portions of a later code edition involved the requirements for examinations of Category B-F, Category C-F, and Category C-G pressure retaining welds. The relevant portions of the 1980 Edition and 1981 Winter Addenda were used at Millstone Unit No. 2, from 1983 on, as follows:

Category B-F: 1975 Addenda requires volumetric and surface exam. The exam performed shall cover the circumference of 100% of each weld.

1980/81 Addenda requires volumetric and surface exam. The volumetric exam shall be to the extent shown in Figure I/1WB-2500-8. (Requires that only bottom 1/3 of weld be examined volumetrically - see drawing).

Category C-F: 1975 Addenda requires volumetric exam and this exam shall cover 100% of the weld.

1980/81 Addenda requires volumetric examinations of pipe material over 1/2" thick and a surface exam of pipe material 1/2" and less. The volumetric exam sha'l cover the bottom 1/3 of the weld as shown in Figure IWC-2500-7.

Category C-G: 1975 Addenda requires volumetric exam and this exam shall cover 100% of the weld.

1980/81 Edition and Addenda dropped the piping welds for the C-G category and added them to C-F category. The C-G piping welds are now examined in accordance with the above listed 1980/81 C-F category. ,

While NNECO did not obtain NRC approval prior to use of the above described porti ns of a later ASME Code Edition, NNECO did determine that the intent of the 7.C's Inservice Inspection Program requirements would be met when the later Code portions were utilized and that use of the later Code portions was technically acceptable and app-opriate.

Specifically, NNECO had determined that ultrasonic examination of thin wall pipe weldments (less than .5 inches "T"), using the contact method in accordance l

with ASME Section XI, did not provide acceptable resolution of results due to erratic near-field waves. Accordingly, in order to obtain more meaningful results at that time, NNECO decided to utilize the portion of the 1980 Edition I and addenca through Winter 1980 Adcenda which permitted the use of a surface exam on the welds in question.

Further, NNECO submitted the proposed Inservice Inspection (ISI) Program for the second ten-year interval for Millstone Unit No. 2 on June 28, 1985. This ten-year ISI program was implemented on December 28, 1985, with interim NRC approval granted until October 1,1986 or until the NRC ongoing review is completed. This current ten-year 151 program referencesSection XI of the ASME Boiler and Pressure Vessel Code, editions through the 1980 Edition and addenda through the Winter 1981 Addenda subject to the limitations listed in paragraph (b) of 10 CFR 50.55a. This 151 program utilizes the Code portions as discussed above (and previously used) for Category B-F, C-F, and C-G welds.

4-In light of the above discussion, NNECO does not consider it necessary or appropriate to pursue relief requests on the above items at this time. We are, however, prepared to address any questions the Staff may have on this subject.

Millstone Unit No. 3 The Millstone Unit No. 3 Preservice Inspection Program is currently approved with ASME Boiler ant. Pres:ure Vessel Code, editions through the 1980 Edition and addenda ince::gh the Winter 1980 Addenda subject to the limitations listed in paragraph (b) of 10 CFR 50.55a.

It is anticipated that the Mills'.one Unit No. 3 Inservice Inspection Program first ten-year interval, to be s6mitted and approved before the first refueling outage, will be updated to the ASME Section XI 1983 Edition Summer 1983 Addenda.

Conclusion NNECO and CYAPCO conclude that the above discussions concerning the use of later ASME Code Edition, or code edition portions should resolve any concerns the Staff may have with respect to this subject. NNECO and CYAPCO will obtain NRC approval prior to the use of subsequent ASME Code Editions or Addenda, . or portions of subsequent ASME Code Editions or Addenda, incorporated by reference into 10 CFR 50.55a, paragraph (b).

We trust you will find this information satisfactory and sufficient to resolve unresolved item 50-336/83-17-01.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY-NORTHEAST NUCLEAR ENERGY COMPANY F- rn A._

a. P. Ope ~ o Senior Vice President cc: Mr. Christopher 1. Grimes, Director Integrated Safety Assessment Project Directorate U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Ashok C. Thadani, Director PWR Project Directorate 68~

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Vincent S. Noonan, Director PWR Project Directorate 65 U.S. Nuclear Regulatory Commission Washington, D.C. 2C555

. . _ . . _ _ ._ - = ._.

I

• l

.$. l Mr. R. A. McBrearty l l

Reactor Inspector Region i U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. H. W. Kerch Lead Reactor Engineer Region i U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

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