ML080420681
| ML080420681 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/28/2008 |
| From: | Lois James NRC/NRR/ADRO/DORL/LPLIII-1 |
| To: | Rencheck M Indiana Michigan Power Co |
| Tam P | |
| References | |
| TAC MD6083, TAC MD6084 | |
| Download: ML080420681 (7) | |
Text
March 28, 2008 Mr. Michael W. Rencheck Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - APPROVAL OF ALTERNATIVE TO EXTEND THE CONTAINMENT INSERVICE INSPECTION INTERVAL TO COINCIDE WITH THE INSERVICE INSPECTION INTERVAL (TAC NOS. MD6083 AND MD6084)
Dear Mr. Rencheck:
By letter dated July 17, 2007, as supplemented by letter dated November 16, 2007, Indiana Michigan Power Company (I&M) proposed relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME B&P) Code,Section XI, Rules for In-service Inspection of Nuclear Power Plant Components.@ Specifically, I&M sought relief to extend the current interval of Donald C. Cook Nuclear Plant, Units 1 and 2 (DCCNP-1 & 2) containment in-service inspection (CISI) program by approximately 18 months from September 9, 2008, to March 1, 2010, to establish a common Edition and Addenda of Section XI of the ASME Code for its in-service inspection program.
The Nuclear Regulatory Commission (NRC) staff completed its review of the submittals, and has determined that the proposed alternative to the requirements of ASME B&P Code,Section XI, IWA-2432, extending the first CISI interval approximately 18 months will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the alternative is authorized for DCCNP-1 & 2 until March 1, 2010. Details of the NRC staffs review are set forth in the enclosed safety evaluation.
Sincerely,
/RA/
Lois M. James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316
Enclosure:
Safety Evaluation cc w/encls: See next page
ML080420681 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/EMCB/BC OGC NRR/LPL3-1/BC NAME PTam THarris KManoly MSpencer LJames DATE 2/26/08 2/25/08 1/30/08*
3/6/08 3/28/08
- Safety evaluation transmitted by memo of 1/30/08.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALTERNATIVE FOR CONTAINMENT INSERVICE INSPECTION PROGRAM RELIEF REQUEST CISIR-06 INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316
1.0 INTRODUCTION
By letter dated July 17, 2007 Agencywide Documents Access and Management System (ADAMS) (Accession No. ML072060375), as supplemented by the letter dated November 16, 2007 (Accession No. ML073320611), Indiana Michigan Power Company (I&M, the licensee) proposed relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME B&P) Code,Section XI, ARules for In-service Inspection of Nuclear Power Plant Components.@ Specifically, I&M sought relief to extend the current interval of Donald C. Cook Nuclear Plant, Units 1 and 2 (DCCNP-1 & 2) containment in-service inspection (CISI) program by approximately 18 months from September 9, 2008, to March 1, 2010, to establish a common Edition and Addenda of Section XI of the ASME Code for its in-service inspection (ISI) program.
The Nuclear Regulatory Commission (NRC) staff review addresses the ability of the licensee to maintain an acceptable level of quality and safety after altering the inspection interval of the CISI program to ensure integrity of the containment.
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR ) Section 50.55a(g) 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 relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i). Also, 10 CFR 50.55a(a)(3) 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. The provision of 10 CFR 50.55a(g)(5)(iii) 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 10 CFR 50.4, information to support the determinations.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components.
ENCLOSURE Specifically, 10 CFR 50.55a(g)(4)(ii) requires that ISI of components and system pressure tests conducted during intervals subsequent to the first 120-month interval comply with requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
3.0 TECHNICAL EVALUATION
3.1 ASME Code Components Affected
All Class MC components and Class CC components (i.e., Subsection IWL inspection frequencies are not affected).
3.2
Applicable Code Edition and Addenda
The licensee stated that the current code of record for the DCCNP-1 & 2 CISI program is ASME Code Section XI, 1992 Edition through the 1992 Addenda. After extending the first CISI interval dates from September 9, 2008, to March 1, 2010, as proposed, the common ASME Code of record for CISI and ISI programs will be the latest incorporated by reference in 10 CFR 50.55a(b)(2) 12 months prior to March 1, 2010.
3.3 Applicable ASME Code Requirement ASME Code,Section XI, IWA-2432 requires that each inspection interval consists of a 10-year duration, except as modified by IWA-2430(d), which permits the inspection interval to be reduced or extended by as much as 1 year, provided that successive intervals are not altered by more than 1 year from the original pattern of intervals.
3.4 Licensee Proposed Alternative and Basis for Use I&M requested to modify the CISI program interval dates by extending the duration of the first CISI interval for DCCNP-1 & 2 by approximately 18 months from September 9, 2008, to March 1, 2010, and to permit commencement of the second CISI interval for Class MC and Class CC components to coincide with the start of the fourth 10-year ISI interval. This will result in both the ISI and CISI programs being under the same ASME Code edition and addenda for the next and successive intervals.
The licensee stated that all originally scheduled first CISI interval examinations will be completed prior to the extended period. Additional examinations will be performed in accordance with the first CISI interval requirements to bridge the gap between the inspection intervals. The Subsection IWE general visual examination of accessible surfaces, the VT-3 visual examination of moisture barriers, and the VT-1 visual examinations of pressure retaining bolting will be performed during DCCNP-1 & 2 outages in the extended period. These additional examinations performed in the extended period will not be credited to the second CISI program inspection interval. Furthermore, the licensee stated that the Class CC examinations performed under Subsection IWL requirements were completed in 2007, and will remain on a 5-year schedule.
The IWL examination schedule will not be affected by this proposed alternative.
The licensee stated that the proposed alternative, as described above, provides an acceptable level of quality and safety, and does not adversely impact the health and safety of the public.
3.5
NRC Staff Evaluation
In the supplementary information contained in 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 IWL examination interval. Additionally, the NRC staff advised 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 the 120-month intervals.
In the subject relief request, the licensee proposed an alternative to the ASME Code,Section XI, IWA-2432 requirements. The proposed alternative will increase the duration of the first 10-year CISI interval of DCCNP-1 & 2 by approximately 18 months. However, the ASME Code at Section XI, IWA-2432(d), allows only 1 year change to the original inspection interval.
Therefore, to determine whether the proposed alternative will provide an acceptable level of quality and safety, the NRC staff=s review focused on the proposed alternative=s effect on the implementation of the ASME Code-required CISI.
Currently, the 10-year interval dates for DCCNP-1 & 2 CISI are different from that of the ISI. The proposed alternative will align the 10-year CISI intervals of Units 1 and 2 with the ISI interval.
This will establish a common interval for both the ISI and the CISI programs at DCCNP-1 & 2, and allow the use of a common ASME Code of record. The common code of record will be the latest incorporated by reference in 10 CFR 50.55a(b)(2) 12 months prior to March 1, 2010.
There are distinct advantages in implementing the same code requirements at both units in a common interval. The advantages include the reduction of administrative burden of maintaining different sets of procedures and requirements, and thus reducing chances of applying the wrong requirements.
The licensee stated that all originally scheduled first CISI interval examinations will be completed prior to the extended period. According to the licensee=s November 16, 2007, letter, the ISI program examination interval dates are not affected by this relief request. Additional examinations (100 percent visual examination of accessible surfaces, 100 percent VT-3 visual examination of moisture barriers, and VT-1 visual examinations of a percentage of pressure retaining bolting as specified in IWE 2412 for the first inspection period) will be performed in accordance with ASME Section XI, 1992 Edition/Addenda requirements to bridge the gap between the first and second CISI intervals. These additional examinations during the 18-month extended period are normally performed in a 3-year inspection period as specified in Table IWE-2412-1 and provide further assurance that continued inspection of Class MC components is maintained during the 18-month extended period. The licensee also stated that these additional examinations will not be credited to the second CISI interval. The licensee stated that the examination of Class CC components in accordance with Subsection IWL requirements was completed in 2007, and that the IWL examinations will remain on a 5-year schedule and will not be affected by this relief request.
According to the licensee=s November 16, 2007, letter, the recent examination results of the containment liner showed no adverse conditions and there are no augmented examination areas for either unit. Also, the recent examination of the exterior concrete of both containment structures did not show any adverse condition.
Based on the above, the NRC staff has determined that the licensee=s proposed alternative (extension of the first CISI interval approximately 18 months in conjunction with additional examinations) will provide an acceptable level of quality and safety.
4.0 CONCLUSION
Based on the information provided in the licensee=s submittals cited above, the NRC staff concludes that the licensee=s proposed alternative to the requirements of ASME Code,Section XI, IWA-2432 is acceptable because it will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i) the implementation of the alternative is authorized for DCCNP-1 & 2 until March 1, 2010.
Principal Contributors: F. Farzam H. Ashar Date: March 28, 2008
Donald C. Cook Nuclear Plant, Units 1 and 2 cc:
Attorney General Department of Attorney General 525 West Ottawa Street Lansing, MI 48913 Township Supervisor Lake Township Hall P.O. Box 818 Bridgman, MI 49106 U.S. Nuclear Regulatory Commission Resident Inspector's Office 7700 Red Arrow Highway Stevensville, MI 49127 Kimberly Harshaw, Esquire Indiana Michigan Power Company One Cook Place Bridgman, MI 49106 Mayor, City of Bridgman P.O. Box 366 Bridgman, MI 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, MI 48909 Susan D. Simpson Regulatory Affairs Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 Michigan Department of Environmental Quality Waste and Hazardous Materials Div.
Hazardous Waste & Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P. O. Box 30241 Lansing, MI 48909-7741 Lawrence J. Weber, Plant Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 Joseph Jensen, Site Vice President Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106