GO2-12-180, Fourth Ten-Year Interval Inservice Inspection (ISI) Program Relief Request 4ISI-03
| ML15357A274 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/22/2015 |
| From: | Brandon D, Javorik A Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-12-180 | |
| Download: ML15357A274 (3) | |
Text
ENERGY NORTHWEST December 22, 2015 G02-15-180 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 AlexJavorik Vice President, Engineering P.O. Box 968, Mail Drop PE20 Richland, WA 99352-0968 Ph. 509-377-8555 F. 509-377-4317 aljavorik@energy-northwest.com 10 CFR 50.55a
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397; FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION {ISi) PROGRAM RELIEF REQUEST 41Sl-03
Dear Sir or Madam:
Pursuant to 1 O CFR 50.55a(z)(1 ), Energy Northwest hereby requests NRC approval of the attached relief request related to the fourth ten-year inservice inspection (ISi) program at Columbia Generating Station (Columbia). The details of the 1 O CFR 50.55a request are enclosed as Attachment 1.
Energy Northwest requests temporary verbal relief due to unforeseen circumstances which prevented issuance of the ISi program plan for the fourth ten-year interval, which began on December 13, 2015.
There are no new commitments made in this submittal. If you have any questions or require additional information, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.
Executed this 12 day of Dec..em. !;tv, 20~
DJ::d 1)~5£- Brandorv At--hntJ.i V;'CJi Prislde1/vt frz_a7)l(!.tbV1Yui A. L. Javorik
-tJ
-u
--.)
Vice President, Engineering
Attachment:
As stated cc:
NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector - 988C (email)
CD Sonoda - BPA - 1399 (email)
WA Horin - Winston & Strawn (email)
GO2-15-180 Page 1 of 2 10 CFR 50.55a Request Number 4ISI-03 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)
Acceptable Level of Quality and Safety
- 1. ASME Code Component(s) Affected All American Society of Mechanical Engineers (ASME) Code Class 1, 2, 3, and MC welds, components, and their supports.
2. Applicable Code Edition and Addenda
Columbia Generating Station (Columbia) entered the fourth ten-year Inservice Inspection (ISI) interval on December 13, 2015. The applicable Edition and Addenda of the ASME Boiler and Pressure Vessel Code,Section XI (hereinafter referred to as the Code) for the fourth interval is the 2007 Edition, 2008 Addenda.
3. Applicable Code Requirement
IWA-4150(b) requires that the Edition and Addenda of Section XI used for the Repair/Replacement Program correspond with the Edition and Addenda identified in the inservice inspection program applicable to the inspection interval.
4. Reason for Request
Upon entry into the fourth ten-year interval on December 13, 2015, the applicable Code Edition and Addenda cited above became effective. Energy Northwest requests relief due to unforeseen circumstances that prevented issuance of the ISI program plan for the fourth ten-year interval at that time. The ISI program plan is the controlling document governing the inservice inspection and repair/replacement activities at Columbia during the fourth ten-year interval. Until Energy Northwest issues an ISI program plan for the fourth ten-year interval, the procedures to implement ISI and repair/replacement activities cannot become effective. Therefore, relief is requested to allow the use of existing procedures that implement ISI and repair/replacement program activities based on the Code Edition and Addenda for the third ten-year ISI interval.
Columbias refueling outage (R22) was completed in June 2015 and was the last outage of the third ten-year interval. This coincided with the preparation, adoption and implementation of the ISI program plan for the fourth ten-year interval. Despite its best efforts, Energy Northwest was unable to issue the ISI program plan prior to entering the fourth ten-year interval. Currently, the ISI program plan is being reviewed by the Authorized Nuclear Inservice Inspector (ANII) and comments are being incorporated.
Final approvals and ANII concurrence of the ISI program plan is expected in January 2016.
GO2-15-180 Page 2 of 2 No Code repair/replacement or ISI work is scheduled to occur prior to issuance of the ISI program plan for the fourth ten-year interval. However, should an emergent issue arise requiring a Code repair/replacement, Energy Northwest would be required to perform work using the 2007 Edition, 2008 Addenda of the Code, which is not yet approved for use at Columbia. Use of the existing approved procedures would be in non-compliance with 10 CFR 50.55a.
5. Proposed Alternative and Basis for Use
Energy Northwest proposes to utilize the 2001 Edition, 2003 Addenda of the ASME Boiler and Pressure Vessel Code,Section XI, as approved under the third ten-year interval plan for performing emergent repair/replacement and ISI activities.
Appendix VIII will be implemented in accordance with 10 CFR 50.55a(b)(2)(xxiv).
Energy Northwest proposes to use the 2001 Edition of ASME Section XI for Appendix VIII as modified by 10 CFR 50.55a. Energy Northwest uses the Performance Demonstration Initiative (PDI) as its Appendix VIII program. As such, the Appendix VIII Reference Code is proposed to be the 2001 Edition of Section XI.
The proposed alternative corresponds to the Code Edition and Addenda utilized during Columbias third ten-year ISI interval. This version of the Code provides an acceptable level of quality and safety since it is currently listed in 10 CFR 50.55a as an approved standard.
- 6. Duration of Proposed Relief Alternative Relief is requested from the date of relief approval through January 31, 2016.
- 7. References None
ENERGY NORTHWEST December 22, 2015 G02-15-180 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 AlexJavorik Vice President, Engineering P.O. Box 968, Mail Drop PE20 Richland, WA 99352-0968 Ph. 509-377-8555 F. 509-377-4317 aljavorik@energy-northwest.com 10 CFR 50.55a
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397; FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION {ISi) PROGRAM RELIEF REQUEST 41Sl-03
Dear Sir or Madam:
Pursuant to 1 O CFR 50.55a(z)(1 ), Energy Northwest hereby requests NRC approval of the attached relief request related to the fourth ten-year inservice inspection (ISi) program at Columbia Generating Station (Columbia). The details of the 1 O CFR 50.55a request are enclosed as Attachment 1.
Energy Northwest requests temporary verbal relief due to unforeseen circumstances which prevented issuance of the ISi program plan for the fourth ten-year interval, which began on December 13, 2015.
There are no new commitments made in this submittal. If you have any questions or require additional information, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.
Executed this 12 day of Dec..em. !;tv, 20~
DJ::d 1)~5£- Brandorv At--hntJ.i V;'CJi Prislde1/vt frz_a7)l(!.tbV1Yui A. L. Javorik
-tJ
-u
--.)
Vice President, Engineering
Attachment:
As stated cc:
NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector - 988C (email)
CD Sonoda - BPA - 1399 (email)
WA Horin - Winston & Strawn (email)
GO2-15-180 Page 1 of 2 10 CFR 50.55a Request Number 4ISI-03 Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1)
Acceptable Level of Quality and Safety
- 1. ASME Code Component(s) Affected All American Society of Mechanical Engineers (ASME) Code Class 1, 2, 3, and MC welds, components, and their supports.
2. Applicable Code Edition and Addenda
Columbia Generating Station (Columbia) entered the fourth ten-year Inservice Inspection (ISI) interval on December 13, 2015. The applicable Edition and Addenda of the ASME Boiler and Pressure Vessel Code,Section XI (hereinafter referred to as the Code) for the fourth interval is the 2007 Edition, 2008 Addenda.
3. Applicable Code Requirement
IWA-4150(b) requires that the Edition and Addenda of Section XI used for the Repair/Replacement Program correspond with the Edition and Addenda identified in the inservice inspection program applicable to the inspection interval.
4. Reason for Request
Upon entry into the fourth ten-year interval on December 13, 2015, the applicable Code Edition and Addenda cited above became effective. Energy Northwest requests relief due to unforeseen circumstances that prevented issuance of the ISI program plan for the fourth ten-year interval at that time. The ISI program plan is the controlling document governing the inservice inspection and repair/replacement activities at Columbia during the fourth ten-year interval. Until Energy Northwest issues an ISI program plan for the fourth ten-year interval, the procedures to implement ISI and repair/replacement activities cannot become effective. Therefore, relief is requested to allow the use of existing procedures that implement ISI and repair/replacement program activities based on the Code Edition and Addenda for the third ten-year ISI interval.
Columbias refueling outage (R22) was completed in June 2015 and was the last outage of the third ten-year interval. This coincided with the preparation, adoption and implementation of the ISI program plan for the fourth ten-year interval. Despite its best efforts, Energy Northwest was unable to issue the ISI program plan prior to entering the fourth ten-year interval. Currently, the ISI program plan is being reviewed by the Authorized Nuclear Inservice Inspector (ANII) and comments are being incorporated.
Final approvals and ANII concurrence of the ISI program plan is expected in January 2016.
GO2-15-180 Page 2 of 2 No Code repair/replacement or ISI work is scheduled to occur prior to issuance of the ISI program plan for the fourth ten-year interval. However, should an emergent issue arise requiring a Code repair/replacement, Energy Northwest would be required to perform work using the 2007 Edition, 2008 Addenda of the Code, which is not yet approved for use at Columbia. Use of the existing approved procedures would be in non-compliance with 10 CFR 50.55a.
5. Proposed Alternative and Basis for Use
Energy Northwest proposes to utilize the 2001 Edition, 2003 Addenda of the ASME Boiler and Pressure Vessel Code,Section XI, as approved under the third ten-year interval plan for performing emergent repair/replacement and ISI activities.
Appendix VIII will be implemented in accordance with 10 CFR 50.55a(b)(2)(xxiv).
Energy Northwest proposes to use the 2001 Edition of ASME Section XI for Appendix VIII as modified by 10 CFR 50.55a. Energy Northwest uses the Performance Demonstration Initiative (PDI) as its Appendix VIII program. As such, the Appendix VIII Reference Code is proposed to be the 2001 Edition of Section XI.
The proposed alternative corresponds to the Code Edition and Addenda utilized during Columbias third ten-year ISI interval. This version of the Code provides an acceptable level of quality and safety since it is currently listed in 10 CFR 50.55a as an approved standard.
- 6. Duration of Proposed Relief Alternative Relief is requested from the date of relief approval through January 31, 2016.
- 7. References None