JPN-97-031, Requests Relief from 1992 Edition of ASME Section Xi,Article IWA-2000, Exam & Insp, Per 10CFR50.55a.Request Applies for Duration of Third ten-yr Interval Which Began on 970929

Requests Relief from 1992 Edition of ASME Section Xi,Article IWA-2000, Exam & Insp, Per 10CFR50.55a.Request Applies for Duration of Third ten-yr Interval Which Began on 970929

ML20211M563
Person / Time
Site:	FitzPatrick
Issue date:	10/06/1997
From:	James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JPN-97-031, JPN-97-31, NUDOCS 9710150013
Download: ML20211M563 (5)

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October 6, 1997 JPN-97-031 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 ,

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Request for Relief from 1992 Edition ASME Section XI Article IWA-2000 " Examination and Inspection"

Reference:

NYPA letter to NRC, JPN-95-050," Request for Relief From ASME Section XI Code Regarding Implementation Schedule For Containment Repair / neplacement Requirements", dated November 26,1996.

Dear Sir:

This letter requests relief from the 1992 Edition of ASME Sectiou XI, Article IWA-2000,

" Examination and Inspection", as evoked by 10 CFR 50.55a. This request is consistent with the request a,r relief submitted previously in the above reference. The requirements of the 1992 Edition of the ASME Code were incorporated into 10 CFR 50.55a and became effective September 9,1996. The attached request for reliefis submitted pursuant to 10 CFR 50.55a(g)(iii) and applies for the duration of the 3rd 10-year interval which began on September 29,1997.

No new commitaients are made by the Authority in this letter. An accelerated review and approval is requested for this matter. If you have any questions, please contact Ms. C. Faison.

Very truly you s,

. Knubel t Senior Vice-President & -[ l

] y ? ( /] 3 Chief Nuclear Ofiicer _/. ('l}

Attachments: as stated cc: next page 9710150013 971006 PDR ADOCK 05000333 G PDR

4, .

cc: Regional Administrator U.S. Nuclear Regulatory Commission 473 /llendale Road King of Prussia, PA 19416 '

Resident Inspector's Orlice James A. FitzPatrick Nuclear Power Plant U.S. Nuc'! ear Regulatory Conunission P.0, Box 136 Lycoming, NY 13093 <

Ms. Karen Cotton, Acting Project Manager Project Directorate I-l Division of Reactor Projects -I/II U.S. Nuclear Regulatory Commissior Mail Stop 14 B-2 Washington, DC 20555

Attachment to JPN-97-031 4

Request for Relief from 1992 Edition ASME Section XI Article IWA-2000 Examination and Inspection I

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 a "

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• Attachment to JPN-97-031 Page1of2 Request for Relief from 1992 Edition ASME Section XI Article IWA-2000 Examination and Inspection A. COMPONENT IDENTIFICATION:

Class:

MC (Metallic Containments)

Identification of System: Primary Containment Structure B. EXAMINATION REQUIREMENTS:

The ASME Section XI 1992 Edition, Article IWE requires that repairs and replacements to the containment be made in accordance with the 1992 Code Edition requirements.

Additionally, the definitions of visual examination methods VT-1 and VT-3, and visual examiner and authorizcd inspectior qualifications are required to comply with Article IWA in the 1992 Editon.

C. RELIEF REQUESTED:

Reliefis requested from the requirements of ASME Secti on XI 1992, Edition Article IWA-2000, as evoked by 10 CFR 50.55a (b)(2)(6).

D. BASIS FOR RELIEF:

The current ISI Program for Class 1,2, and 3 components and their supports is based on the ASME Sectior. XI,1989 Edition without Addenda. This program defines the VT-1 and VT-3 examinations and includes all factors necessary to qualify the examiners and assure the examinations are performed at the highest quality levels. The imposition of evoking ASME Section XI,1992 Edition Code requirements for containment would necessitate a separate administrative program including procedures, certification tests and recordkeeping requirements, which would merely parallel the existing program with no benefit to quality. The existing program is used on the reactor and other Class I components, and continues to prove effective. Maintaining two separate programs for the same activities is a significant burden that has no benefit to quality or safety. Similarly, the repair and replacement program for Class 1,2, and 3 components is based on the 1989 Edition and has proven effective. Use of the 1992 Code for containment would require a separate set of procedures with 1992 references and parallel recordkeeping. This is a significant burden with no compensating increase in quality or safety.

Implementi.y procedures for all applicable portions of Article IWE will be in accordance with the Authority's Quality Assurance Program, which meets 10 CFR 50 Appendix B.

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' Attachment to JPN-97-031 Page 2 of 2 E. ALTERNATIVE EXAMINATIONS OR TESTS:

The ISI Program at JAF will meet the requirements specified in ASME Section XI 1989 Edition without Addenda, Article IWA 2000.

l F. IMPLEMENTATION SCHEDULE:

l The requirements as specified in this relief request will be incorporated into JAF Insersice l Inspection Program for the duration of the 3rd Ten-Year Interval.-

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