ML023600007
| ML023600007 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 12/06/2002 |
| From: | Forbes J Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| M2002122 | |
| Download: ML023600007 (7) | |
Text
-C*
Monticello Nuclear Generating Plant Committed to Nuclear Exc*/e V
Operated by Nuclear Management Company, LLC December 6, 2002 10 CFR Part 50 Section 50.55a(a)
US Nuclear Regulatory Commission 2 002122 Attn: Document Control Desk M2 Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Monticello Relief Request Number ISI No. 7 Use of 2001 Addenda for Repair/Replacement Program The Monticello Nuclear Generating Plant is updating its Inservice Inspection Program for the Fourth Ten-Year interval to meet the 1995 Edition with the 1996 Addenda. The Monticello IWE/IWL Repair/Replacement Program currently meets the 1992 Edition, including the 1992 Addenda.
By Federal Register Notice dated September 26, 2002 (67 Federal Register 60520), the NRC amended 10 CFR 50.55a to incorporate by reference ASME Section XI, Division 1, of the ASME BPV Code, 1997 Addenda, 1998 Edition, 1999 Addenda, and 2000 Addenda for Class 1, Class 2, Class 3, Class MC, and Class CC components, with modifications and limitations. The effective date of this rule change is October 28, 2002.
Pursuant to the provisions of 10 CFR 50.55a, Nuclear Management Company, LLC (NMC) requests NRC approval of an alternative to allow the use of the 2001 Edition'for repair and replacement activities. As discussed in the attached relief request, the maintenance of two separate repair/replacement programs 'results in unnecessary burden while providing no increase in quality or safety.
Our letter of May 30, 2002, entitled "Notification of Extension of 3r Ten-year Inservice Testing and Inspection Intervals," informed NRC of our intention to extend the third ten year ISI interval through March 8, 2003. Thus, our fourth ten-year interval is currently scheduled for the period of March 9, 2002 through May 31, 2012. As discussed with NRC Project Manager John Lamb on December 2, 2002, we are in the process of reviewing implementation of the Fourth 10-Year Interval plan. Based on the results of our review, we will contact our NRC Project Manager to discuss NRC review schedules.
If you have any questions please contact Gary Park (763-295-1658) or John Fields (763-295
) 63)
Jeffrey S. oes Site Vice President Monticello Nuclear Generating Plant Cc:
(next page) 2807 West County Road 75
- Monticello, Minnesota 55362-9637 Telephone: 763-295-5151 e Fax: 763-295-1454
Committed to Nuclea Excelnce Monticello Nuclear Generatinq Plant Operated by Nuclear Management Company, LLC cc:
Regional Administrator-Ill, NRC NRR Project Manager, NRC Sr. NRC Resident Inspector, NRC State of Minnesota Boiler Inspector Hartford Insurance J. Silberg (w/o Enclosure) 2807 West County Road 75
- Monticello, Minnesota 55362-9637 Telephone 763-295-5151
- Fax: 763-295-1454
RELIEF REQUEST NUMBER: ISI No. 7 COMPONENT IDENTIFICATION Code Classes:
1, 2, and 3 References.
IWA, IWB, IWC, IWD, and IWF-4000 (IWX-4000)
Examination Category:
Not Applicable Item Number:
Not Applicable Descnption Use of the 2001 Edition of Section XI to Govern Repair/Replacement Activities and Procedures (IWX-4000).
Component Numbers:
All Class 1, 2, 3 and MC pressure retaining components and their supports CODE REQUIREMENT IWX-4000 (ASME Section XI 1995 Edition with the 1996 Addenda, used for Class 1, 2, and 3 components) provides the rules and requirements for repair/replacement activities associated with pressure retaining components and their supports, including appurtenances, subassemblies, parts of a component, core support structures, metal containments and their integral attachments, and metallic portions of Class CC containments and their integral attachments IWX-4000 (ASME Section XI 1992 Edition with the 1992 Addenda, used for IWE components) provides the rules and requirements for the repair of pressure retaining components and their supports, including appurtenances, subassemblies, parts of a component, core support structures, metal containments and their integral attachments, and metallic portions of Class CC containments and their integral attachments, by welding, brazing, or metal removal. This article also provides the rules and requirements for the specification and construction of items to be used for replacements and installation of replacement items.
10 CFR 50.55a dated September 6, 1996 required the implementation of Subsections IWE and IWL of the 1992 Edition with the 1992 Addenda.
BASIS FOR RELIEF The 1992 Edition with the 1992 Addenda to Section XI made several changes to Articles IWX-4000. Very few of these changes were technical in nature. Instead, the changes restructured some of the requirements, (ie. Combined IWX-4000 and IWX-7000 into one section) clarified others that were difficult to interpret, and eliminated redundant requirements. Of the actual technical changes made, these changes either added enhancements to the program or added requirements not applicable to Monticello.
Meeting both the 1995 with the 1996 Addenda and the 1992 with the 1992 Addenda of ASME Section Xl would require the maintenance of two separate repair and replacement programs (one for the IWB, IWC, and IWD components per the 1996 Addenda of ASME Section XI and one for the 1992 Addenda for the containment vessel). Duplicate records to demonstrate compliance with the 1996 Addenda and the 1992 Addenda would also be required. This duplication of programs and records increases the man-hours necessary to maintain the Monticello Repair/Replacement Program without providing any increase in quality or safety.
The final rule (Federal RegisterNol. 67, No. 187, dated September 26, 2002) incorporates reference to the 1998 Edition through 2000 Addenda. Attached is a reconciliation of the changes made and a comparison of the 2001 Edition to the 2000 Addenda of Section XI. Each change related to Repair/Replacement Activities is addressed in the attachment to show it will be implemented at the Monticello RELIEF REQUEST NUMBER: ISI No. 7 ALTERNATE EXAMINATION This alternative is requested in accordance with 10CFR 50 55a(a)(3)(i)
Monticello Nuclear Generating Plant will use the 2001 Edition of ASME Section XI, to govern Repair/Replacement Procedures (IWX 4000) for Class 1,2,3, and MC pressure retaining components and their supports Using the requirements contained in the 2001 Edition of ASME Section XI for Repairs/Replacements at the Monticello Nuclear Generating Plant will maintain the safety of the plant The following table indicates the implementation of the 2001 Edition for Repair/Replacement Activities.
Article Top~ic Bases Scope and Responsibility Examination and Inspection Acceptance Standards Repair/Replacements Pressure Tests (Periodic)
Pressure Tests (Repair/Replacements)
Records Glossary Scope and Responsibility Examination and Inspection Acceptance Standards Pressure Tests (Periodic)
Pressure Tests (Repair/Replacements)
Scope and Responsibility Examination and Inspection Acceptance Standards Pressure Tests (Periodic)
Pressure Tests (Repair/Replacements) 1996 Addenda 1996 Addenda 1996 Addenda 2001 Edition 1996 Addenda 2001 Edition 2001 Edition 2001 Edition 1996 Addenda 1996 Addenda 1996 Addenda 1996 Addenda 2001 Edition 1996 Addenda 1996 Addenda 1996 Addenda 1996 Addenda 2001 Edition IWA-1000 IWA-2000 IWA-3000 IWA-4000 IWA-5000 IWA-5000 IWA-6000 IWA-9000 IWBo1000 IWB-2000 IWB-3000 IWB-5000 IWB-5000 IWC-1000 IWC-2000 IWC-3000 IWC-5000 IWC-5000 IWD-1000 IWD-2000 IWD-3000 IWD-5000 IWD-5000 IWE-1 000 IWE-2000 IWE-3000 IWE-5000 IWE-5000 IWF-1 000 IWF-2000 IWF-3000 IWF-5000 APPLICABLE TIME PERIOD Relief is requested for the fourth ten-year interval of the Inservice Inspection Program for Monticello Nuclear Generating Plant. Scope and Responsibility 1996 Addenda Examination and Inspection 1996 Addenda Acceptance Standards 1996 Addenda Pressure Tests (Periodic) 1996 Addenda Pressure Tests (Repair/Replacements) 2001 Edition Scope and Responsibility 1992 Addenda Examination and Inspection 1992 Addenda Acceptance Standards 1992 Addenda Pressure Tests (Periodic)
Appendix J Pressure Tests (Repair/Replacements) 2001 Edition w/
Appendix J Scope and Responsibility 1996 Addenda Examination and Inspection 1996 Addenda Acceptance Standards 1996 Addenda Snubber Examinations and Tests 1996 Addenda
RELIEF REQUEST NUMBER: ISI No. 7 Certificate of Reconciliation This Certificate of Reconciliation provides the basis for revisions to the Monticello Nuclear Generating Plant's ASME Section XI "Repair /Replacement Program" (4AWI-09.04.03) in order to meet the 2001 Edition of ASME Section XI On September 9, 1996, the Nuclear Regulatory Commission (NRC) issued a revision to 10 CFR 50.55a, implementing subsections IWE and IWL* of the 1992 edition, including the 1992 addenda of Section XI of the ASME Code. This required utilities to develop and implement a program for the examination of containments by September 9, 2001. Additionally, it required implementation of an IWE/IWL repair/replacement program effective September 9, 1996 The Monticello Nuclear Generating Plant is updating the Inservice Inspection Program for the fourth ten-year interval to meet the 1995 Edition with the 1996 Addenda Because of the hardship to maintain two separate Repair/Replacement Programs, this alternative is made to allow the use of the 2001 Edition of ASME Section XI This reconciliation is completed to provide justification for allowing the use of the 2001 Edition for Class 1,2,3 and MC pressure retaining components and their supports The revision of 10CFR50 55a (12 months prior to the 4th 10 year interval for Monticello) requires ASME Section XI Programs to follow the 1995 Edition as amended by the 1996 Addenda of ASME Section XI for Class 1,2, and 3 and the 1992 Edition as amended by the 1992 Addenda for Class MC. There are some general issues to discuss prior to delineating the specific changes that have been made to the ASME Section XI Code (2000 Addenda to 2001 Edition)
- 1)
The NRC has reviewed and approved with some exceptions the 1998 Edition through 2000 Addenda. This has been included in the Final Rule (dated September 26, 2002).
Those specific exceptions made to the rules for repair/replacement activities are included in the implementation of the 2001 Edition
- 2)
The Inservice Inspection requirements will be based on the 1995 Edition as amended by the 1996 Addenda.
- 3)
The Periodic Pressure Testing requirements will be based on the 1995 Edition as amended by the 1996 Addenda. While the pressure testing requirements for repair/replacement activities will be based on the 2001 Edition.
- 4)
The reconciliation attached will address the changes contained within the IWA-4000 paragraphs In addition, any significant changes identified within any related requirement will be addressed.
- IWL "Requirements for Class CC Concrete Components of Light-Water Cooled Plants" is not applicable to the Monticello Nuclear Generating Plant RELIEF REQUEST NUMBER: 151 No. 7 Certificate of Reconciliation IWA-4110(b), IWA 4230, IWA-4400, IWA 4410, IWA-4411, IWA 4412, IWA-4413, IWA 4420, IWA-4421, IWA 4422, IWA-4430, IWA 4450, IWA-4451, Table IWA-4461.1-1, IWA 4461.4, IWA-4462, IWA-4500, IWA-4520, IWA-4600, IWA-4610, IWA-4611, IWA-4620, IWA-4624, IWA-4630, IWA-4634, IWA-4644, IWA-4654, IWA-4666, IWA-4711.4, IWA-4712, IWA-4721.1 2001 Edition This revision clarifies the requirements applicable to metal removal by grinding, thermal metal removal, welding, brazing, or modification In addition, provisions are added for metal removal not associated with defect removal, restoration of thinned areas by welding, and defect mitigation by modification The modified rules simplify defect removal requirements by applying Section Xl acceptance criteria to existing base material and weld metal, and by only applying Construction Code acceptance criteria to new material and associated welds The revision also modifies the provisions regarding extent of defect removal required prior to application of a temperbead weld repair, by clarifying that defect removal is accomplished when the defect has been reduced to an acceptable flaw, whether or not temperbead welding will be performed A number of paragraphs have been reorganized to eliminate sources of misinteroretation of reauirements (See Note 1)
IWA-4131.1(a), 4713 This revision adds new requirements for qualification of Class 1 (See Note mechanical tube plugs These requirements represent a
- 2) compilation of the standards and methods that have been used for twenty years to design, qualify, and install steam generator tube plugs They have proven to provide safe installation and service for mechanical steam generator tube plugs. These requirements include development and qualification of the plug design and of a Plugging Procedure Specification (PPS), and performance qualification for individuals who install the tube plugs IWA-4132 This revision deletes the requirement for pressure testing and VT-(See Note 2 visual
- 3) examination of relief valves rotated from stock and installed by mechanical means In the 1999 Addenda, the requirement to pressure test mechanical joints made in installation of pressure retaining items was deleted from IWA-4540, because Owner's operation and maintenance personnel post-installation inspections are adequate without an additional Code-required examination With the deletion of pressure tests for mechanical connections, a similar exemption is warranted for installation of relief valves by mechanical means The revision also clarifies that no other IWA 4000 requirements apply to rotation of snubber and relief valves, except those of IWA-4132, and clarifies that use of an ANII is not required This revision incorporates the provislions of Case N-508 2, "Rotation of Serviced Snubbers and Pressure Relief Valves for I the Purpose of Testing,Section XI, Division 1."
1 NOTE 1. It is important to apply the correct acceptance criteria to each repair/replacement activity completed. As reflected in the Final Rule, the NRC recognizes the difference between the NDE of the Construction Codes and ASME Section Xl The Monticello R/R Program incorporates these rules.
NOTE 2. NMC feels it is important to have all special processes qualified and/or demonstrated to verify it's application The Monticello R/R Program incorporates these provisions NOTE 3. Since the installation of mechanical joints does not require a VT-2 Examination, then the installation of relief valves rotated from stock and installed by mechanical means would also not require a VT-2 examination The Monticello R/R Program will include the following statement "The requirement to perform a pressure test on mechanical joints made during installation was deleted from Section XI IWA 4540(c), however, a pressure test shall be performed by Operations or Maintenance, but without a VT-2 exam" TRANSMITTAL MANIFEST NUCLEAR MANAGEMENT COMPANY, LLC NUCLEAR LICENSING DEPARTMENT MONTICELLO NUCLEAR GENERATING PLANT Monticello Relief Request Number ISI No. 7 Use of 2001 Addenda for Repair/Replacement Program Correspondence Date: December 6, 2002 Manifest Date: December 16, 2002 Monticello Site Distribution Special Instructions*
Melissa Miszczak....... USAR File............. Yes No x Ron Baumer.......... NRC Commitment.... Yes No x Linda Christianson.... Monti OC Sec.......... Yes__ No x_ - 12, No dist to OC members below if YES Darla Minkkinen......... Monti OSRC Sec...... Yes No_x
- 5 Monticello Site Distribution:
J S Forbes, Site VP, OSRC S R Radebaugh, OC P C Albares, Mgr Program Engr G C Park G B Bregg, Mgr Nuclear Oversight R A Deopere W P Cheever, Training Mgr Kurt Suleski, ANII - Monti SAB2 D P Fadel, Dir Site Engr NRC Resident Inspector J C Grubb, Ops Mgr, OC Monti Document Control File J D Purkis, Plant Mgr, OC Monti Licensing ISI File B J Sawatzke, Maint Mgr, OC Monti Site Licensing File E C Sopkin, Mgr System Engr, OC NMC Distribution:
Xcel Energy Distribution:
C R Bomberger, RS-10 External Distribution.
Doc Control Desk, NRC Joel Amato, Minn State Boiler Inspector Regional Admin-III, NRC J E Silberg Darl Hood, NRR-PM, NRC Minnesota Dept. of Commerce (NRR-PM copy sent to John Lamb)
Hartford Insurance 12109/2002 M-10d