ML070730599

Relief Request No. 3ISI-06 for the Third 10-Year Inservice Inspection Interval Synchronization of Interval for Class Mc Components and Their Supports

ML070730599
Person / Time
Site:	Columbia
Issue date:	03/22/2007
From:	Terao D NRC/NRR/ADRO/DORL/LPLIV
To:	Parrish J Energy Northwest
Lyon C Fred, NRR/DORL/LPL4, 301-415-2296
References
TAC MD1169
Download: ML070730599 (9)

Text

March 22, 2007 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION - RELIEF REQUEST NO. 3ISI-06 FOR THE THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RE:

SYNCHRONIZATION OF INTERVAL FOR CLASS MC COMPONENTS AND THEIR SUPPORTS (TAC NO. MD1169)

Dear Mr. Parrish:

By letter dated December 15, 2005, as supplemented by letter dated April 27, 2006, Energy Northwest (the licensee) submitted requests for relief 3ISI-01 and 3ISI-03 through 3ISI-07 from certain requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, for the third 10-year inservice inspection (ISI) interval at Columbia Generating Station (CGS). The ASME Code,Section XI, of record for CGS for the third 10-year ISI interval is the 2001 Edition with 2003 Addenda. The third 10-year ISI interval at CGS began on December 13, 2005, and ends on December 12, 2015.

Based on the information provided in the licensees submittal, the U.S. Nuclear Regulatory Commission (NRC) staff concluded that relief request 3ISI-06 for synchronization of the 10-year interval for ASME Code Class MC components and their supports with the 10-year ISI interval for Code Class 1, 2, and 3 components and their supports was acceptable. Relief requests 3ISI-01, 3ISI-03, 3ISI-04, 3ISI-05, and 3ISI-07 were addressed by separate NRC correspondence.

For relief request 3ISI-06, relief is authorized for the third 10-year ISI interval pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations based on the determination that the licensees proposed alternative provides an acceptable level of quality and safety.

The above relief request is applicable for the third 10-year ISI interval at CGS. All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

J. V. Parrish The detailed results of the NRC staffs review are provided in the enclosed safety evaluation. If you have any questions concerning this matter, please call Mr. F. Lyon of my staff at 301-415-2296.

Sincerely,

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

Safety Evaluation cc w/encl: See next page

ML070730599 *memo dated 3/5/07 OFFICE LPL4/PM LPL4/LA CPNB/BC OGC - NLO LPL4/BC NAME FLyon LFeizollahi TChan* TCampbell DTerao DATE 3/21/07 3/21/07 3/5/07 3/22/07 3/22/07 Columbia Generating Station cc:

Mr. W. Scott Oxenford (Mail Drop PE04) Mr. Dale K. Atkinson (Mail Drop PE08)

Vice President, Technical Services Vice President, Nuclear Generation Energy Northwest Energy Northwest P.O. Box 968 P.O. Box 968 Richland, WA 99352-0968 Richland, WA 99352-0968 Mr. Albert E. Mouncer (Mail Drop PE01) Mr. William A. Horin, Esq.

Vice President, Corporate Services/ Winston & Strawn General Counsel/CFO 1700 K Street, N.W.

Energy Northwest Washington, DC 20006-3817 P.O. Box 968 Richland, WA 99352-0968 Mr. Matt Steuerwalt Executive Policy Division Chairman Office of the Governor Energy Facility Site Evaluation Council P.O. Box 43113 P.O. Box 43172 Olympia, WA 98504-3113 Olympia, WA 98504-3172 Ms. Lynn Albin Mr. Douglas W. Coleman (Mail Drop PE20) Washington State Department of Health Manager, Regulatory Programs P.O. Box 7827 Energy Northwest Olympia, WA 98504-7827 P.O. Box 968 Richland, WA 99352-0968 Technical Services Branch Chief FEMA Region X Mr. Gregory V. Cullen (Mail Drop PE20) 130 228th Street, S.W.

Supervisor, Licensing Bothell, WA 98201-9796 Energy Northwest P.O. Box 968 Ms. Cheryl M. Whitcomb (Mail Drop PE03)

Richland, WA 99352-0968 Vice President, Organizational Performance & Staffing/CKO Regional Administrator, Region IV Energy Northwest U.S. Nuclear Regulatory Commission P.O. Box 968 611 Ryan Plaza Drive, Suite 400 Richland, WA 99352-0968 Arlington, TX 76011-4005 Assistant Director Chairman Nuclear Safety and Energy Siting Division Benton County Board of Commissioners Oregon Department of Energy P.O. Box 190 625 Marion Street, NE Prosser, WA 99350-0190 Salem, OR 97301-3742 Senior Resident Inspector Special Hazards Program Manager U.S. Nuclear Regulatory Commission Washington Emergency Management Div.

P.O. Box 69 127 W. Clark Street Richland, WA 99352-0069 Pasco, WA 99301 March 2007

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF NO. 3ISI-06 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397

1.0 INTRODUCTION

By letter dated December 15, 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML053620391), as supplemented by letter dated April 27, 2006 (ADAMS Accession No. ML061250154), Energy Northwest (the licensee) submitted relief requests pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(6)(i) associated with its third 10-year interval inservice inspection (ISI) program at Columbia Generating Station (CGS). The third 10-year ISI interval began on December 13, 2005, and is scheduled to end on December 12, 2015. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, 2001 Edition with 2003 Addenda is the ISI code of record for the CGS third 10-year interval ISI program.

The licensee submitted relief request 3ISI-06 to synchronize the 10-year interval for Code Class MC components and their supports with the 10-year interval for Code Class 1, 2, and 3 components and their supports. Specifically, the licensees proposed alternative is to reduce the initial containment 10-year ISI interval by one refueling outage and synchronize it with the third 10-year ISI interval. The applicable Code for both inspection programs will be the ASME Code,Section XI, 2001 Edition with 2003 Addenda. The licensee stated that a similar relief request was approved by the U.S. Nuclear Regulatory Commission (NRC) for Susquehanna Steam Electric Station (ADAMS Accession No. ML042680078, dated September 24, 2004).

2.0 REGULATORY EVALUATION

Paragraph 50.55a(g) of 10 CFR specifies that ISI of nuclear power plant components shall be performed in accordance with the requirements of the ASME Code,Section XI, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).

Paragraph 50.55a(a)(3) of 10 CFR states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Paragraph 50.55a(g)(5)(iii) of 10 CFR states that if the licensee has determined

that conformance with certain ASME Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in Section 50.4, information to support the determinations.

The information provided by the licensee in support of its request has been evaluated by the NRC staff and the bases for disposition are documented below.

3.0 LICENSEES EVALUATION (AS PROVIDED) 3.1 Component Identification

[ASME] Code[,Section XI,] Class MC [Metallic Containment and Concrete Containment Component(s)]

3.2 Applicable Code Edition and Addenda ASME [Code,] Section XI 1992 Edition through 1992 Addenda 3.3 Applicable Code Requirement IWA-2432, Inspection Program B 3.4 Reason for Request Synchronization of ten year interval for [ASME] Code Class MC components and their supports with the ten year interval for [ASME] Code Class 1, 2, and 3 components and their supports.

3.5 Proposed Alternative and Basis for Use The alternative is to reduce the initial Containment Inservice Inspection [Interval]

(CISI) ten year interval by one refuel outage and synchronize it with the third Inservice Inspection (ISI) ten year interval. The applicable Code for both inspection programs will be ASME [Code,] Section XI 2001 Edition through the 2003 Addenda.

CISI Programs were initially required by regulation (10 CFR 50.55a) as amended within a Final Rule (61 FR 41303) issued on August 8, 1996. Accordingly, the CISI Program was prepared and has been implemented to the 1992 Edition through the 1992 Addenda of Subsection IWE of ASME [Code,] Section XI, Rules for Inservice Inspection of Nuclear Plant Components, Division 1, as modified by the regulation at that time.

All examinations and tests required by the CISI Program have been implemented in accordance with the established schedule. All the examinations scheduled for the first and second inspection periods have been completed. All of these examinations and tests performed to date have satisfied the acceptance standards contained within Article IWE-3000, without exception. Currently, there

are no containment surfaces or components requiring designation as augmented examination areas. The VT-3 visual examinations currently scheduled for the end of [the] interval are discussed later in this request.

Reducing the duration of the first CISI Interval will permit commencement of the second CISI Interval to coincide with the start of the third ISI Interval for Class 1, 2, and 3 components. This will result in both the ISI and CISI Programs being able to use the same Code Edition and Addenda for the successive intervals.

Currently, the latest edition and addenda of the [C]ode incorporated by reference in 10 CFR 50.55a(b)(2) of the regulation is the 2001 Edition through the 2003 Addenda. This Code version is being used, as required by 10 CFR 50.55a(g)(4)(ii), for development of the ISI Program update for the third Inspection Interval of ISI Class 1, 2, and 3 components and their component supports, subject to the limitations and modifications within the regulation.

In accordance with the last sentence of 10 CFR 50.55a(b)(2)(vi) and 10 CFR 50.55a(g)(4)(ii), the 2001 Edition through the 2003 Addenda of [ASME Code,]

Section XI will also be used for development and implementation of the second CISI Interval, subject to the limitations and modifications within the 10 CFR 50.55a(b)(2) of the regulation.

The requirements within the first sentence of paragraph 10 CFR 50.55a(b)(2)(vi) which only permits licensees to use either the 1992 Edition through the 1992 Addenda or the 1995 Edition through the 1996 Addenda of Subsection IWE as modified and supplemented by the requirements in paragraphs (b)(2)(viii) and (b)(2)(ix) of the regulation when implementing the initial 120-month inspection interval for the CISI requirements of the regulation are fully satisfied by approval of this proposed alternative to reduce the duration of the first CISI Interval.

Section 50.55a(g)(4)(ii) does not prohibit licensees from updating to a later edition and addenda of the ASME Code midway through a ten-year examination interval.

The current CISI Program requires performance of several VT-3 visual examinations in accordance with Table IWE-2500-1, Examination Category E-A, Items E1.12 and E1.20 at the end of the first inspection interval. Accordingly, these examinations have not all been performed. Table IWE-2500-1, Examination Category E-A, Items E1.12 and E1.20 of the 2001 Edition through the 2003 Addenda of [ASME Code,] Section XI do not limit performance of these examinations to the end of interval. Therefore, [CGS] has scheduled performance of these examinations for the first inspection period in the third ISI Interval. Scheduling these examinations for this inspection period will retain the originally scheduled point in time, thus meeting the intent for performance of these examinations.

In conclusion, granting the proposed alternative as described herein provides an acceptable level of quality and safety, and does not adversely impact the health and safety of the public.

4.0 NRC STAFF EVALUATION As an alternative to the full 10-year interval duration requirement for the first CISI interval, the licensee proposes to reduce the length of the first CISI interval by one refueling outage (approximately 18 months). This reduction will permit the subsequent CISI interval to coincide with the dates for the third and subsequent ISI intervals for Class 1, 2, and 3 components and thus enable both the CISI and ISI Programs to use the same Code Edition and Addenda for the successive intervals. Therefore, the start date of the third interval for the ISI Program and the second interval for the CISI Program at CGS will be December 13, 2005. The third interval is scheduled to end on December 12, 2015.

In the supplementary information contained within Section 2.2 of the Final Rule (67 FR 60520) dated September 26, 2002, the NRC staff stated that 10 CFR 50.55a(g)(4)(ii) does not prohibit licensees from updating to a later edition and addenda of the ASME Code midway through a 10-year IWE or 5-year lWL examination interval. This facilitates licensees synchronizing their ISI intervals for the CISI with that of Class 1, 2, and 3 components. Additionally, the staff advised the industry that licensees wishing to synchronize their 120-month intervals may submit a request in accordance with 10 CFR 50.55a(a)(3) to obtain authorization to extend or reduce 120-month intervals.

The licensee stated that all examinations and tests required by the CISI Program for the first and second inspection periods have been implemented and completed in accordance with the established schedule. All of the examinations and tests performed to date have satisfied the acceptance standards contained within Article IWE-3000, without exception. Currently, there are no containment surfaces or components that require augmented examination. The VT-3 visual examinations that were scheduled for the end of interval have not been performed.

However, Table IWE-2500-1, Examination Category E-A, Items E1.12 and E1.20 of the 2001 Edition through the 2003 Addenda of ASME Code,Section XI, do not limit performance of these examinations until the end of interval. The licensee stated that it has scheduled these examinations for the third ISI interval, which will retain their originally scheduled point in time and thus meet the intent for performance of these examinations. Since (1) all of the examinations and tests required by the CISI program to date have been satisfactory, and no augmented examinations have been required, and (2) the VT-3 examinations which have not yet been performed have been scheduled within the third ISI interval and will retain their original scheduled point in time, the staff concludes that the licensees proposed change meets the purpose and intent of the required examinations.

The NRC staff finds the licensees approach in synchronizing the CISI with that of Class 1, 2, and 3 components acceptable. Based on the assessment that the licensees proposed change continues to meet the purpose and intent of the ASME Code requirements for ISI, the staff concludes that the licensees request to permit the shorter (than 10 years) interval for ISI of metallic containment and concrete containment components in the second 10-year containment ISI interval provides an acceptable level of quality and safety.

5.0 CONCLUSION

The NRC staff has reviewed the information provided by the licensee in support of relief request 3ISI-06 for the third 10-year ISI interval for CGS. Based on this evaluation, the staff concludes that the licensees proposed alternative provides an acceptable level of quality and safety.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the licensee's proposed alternative is authorized for the third 10-year ISI interval.

All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: G. Georgiev Date: March 22, 2007