ML083540098
| ML083540098 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/21/2008 |
| From: | Joseph Pacher Constellation Energy Group, Nuclear Generation Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML083540098 (7) | |
Text
Joe Pacher Manager, Nuclear Engineering Services Constellation Energy' Nuclear Generation Group R.E. Ginna Nuclear Power Plant. LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax joseph.pacher@ constellation.com November 21, 2008 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 First Interval IWEJIWL Containment Pro2ram Submittal of Relief Request Number 22 Pursuant to 10 CFR 50.55a(a)(3)(i), R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) hereby requests NRC approval of the following request for the First Interval IWE/IWL Containment Program:
R.E. Ginna is requesting a three month extension beyond the Code allowed 12 month extension of IWA-2430(d) for the current Containment Inservice Inspection (CISI) interval for the R.E. Ginna Nuclear Power Plant to enable the CISI and the ASME Class 1, 2, and 3 components Inservice Inspection (ISI) intervals to coincide.
The proposed extension will eliminate the need to maintain two programs that have different Code requirements caused by the difference in the starting dates of the intervals without impacting quality or safety. The ASME Section XI Subsection [WE and IWL intervals ended on September 9, 2008 and the ASME Class 1,2, and 3 interval currently ends on December 31, 2009. The details of the 10 CFR 50.55a request is enclosed.
Ginna LLC requests NRC approval of the attached relief request No. 22 by June 25, 2009 to support the submittal of the combined ISI and containment program document for the next interval.
Should you have questions regarding this matter, please contact David Wilson (585.) 771-5219, or david.f.wilson @constellation.com.
Very truly yours, oeph E. Pacher
Attachment:
RELIEF REQUEST NO. 22 R. E. Ginna Nuclear Power Plant - First Interval IWE/IWL Containment Program Alternative for Containment Inservice Inspection (CIS) Interval Extension CV r/ 0
cc:
S. J. Collins, NRC D. V. Pickett, NRC Resident Inspector, NRC RELIEF REQUEST NO. 22 R. E. Ginna Nuclear Power Plant - First Interval IWE/IWL Containment Program Alternative for Containment Inservice Inspection (CISI) Interval Extension
RELIEF REQUEST NO. 22 R. E. Ginna Nuclear Power Plant - First Interval IWE/1WL Containment Program Alternative for Containment Inservice Inspection (CISI) Interval Extension Proposed Alternative In Accordance with 10 CFR 50.55a (a)(3)(i)
-Alternative Provides Acceptable Level of Quality and Safety-
- 1. ASME Code Component(s) Affected The affected components are the R.E. Ginna Nuclear Plant's American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code Section XI (Reference 1) Examination Categories and Item Numbers covering examinations of the components of ASME XI Subsection IWE (Class MC and Metallic Liners of Class CC Components) and Subsection IWL (Class CC Concrete Components).
Code Class:
MC/CC Code
Reference:
Examination Category:
Item Number:
==
Description:==
Component Number:
IWA-2430(d)
IWA-2432 All Examination Categories under Subsection IWE and IWL1 All Item Numbers under Subsection IWE and IWL1 Class MC pressure retaining components, metallic shell and penetration liners of Class CC components, and reinforced concrete of Class CC components All Class MC and CC Components
'Note: Applicability to Subsection IWL is limited to the referencing of the Code of Record in program documents and to the update of program procedures to the new Code requirements. Subsection IWL inspection frequencies will remain unchanged.
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers Code,Section XI, 1992 Edition and 1992 Addenda, "Rules for Inservice Inspection of Nuclear Power Plant Components" Page 1 of 4
RELIEF REQUEST NO. 22 R. E. Ginna Nuclear Power Plant - First Interval IWE/IWL Containment Program Alternative for Containment Inservice Inspection (CISI) Interval Extension
3. Applicable Code Requirement
An-alternative is requested for the following requirements of the ASME Boiler and Pressure Vessel Code, Section Xl, 1992 Edition with the 1992 Addenda, applicable to the containment first inservice inspection interval:
- 1. IWA-2430(d) requires that for components inspected under Program B, the inspection intervals may be extended or decreased by as much as 1 year, provided successive intervals are not altered by more than 1 year from the original pattern of intervals.
- 2. IWA-2432 requires that the first inspection interval consist of ten years following start of commercial service and that subsequent inspection intervals consist of ten years following previous inspection intervals, except as modified by IWA-2430(d).
4. Reason for Request
R.E. Ginna is requesting a three month extension beyond the Code allowed 12 month extension of IWA-2430(d) for the current Containment Inservice Inspection (CISI) interval for the R.E. Ginna Nuclear Power Plant to enable the CISI and the ASME Class 1, 2, and 3 components Inservice Inspection (ISI) intervals to coincide.
The proposed extension will eliminate the need to maintain two programs that have different Code requirements caused by the difference in the starting dates of the intervals without impacting quality or safety. The ASME Section XI Subsection IWE and IWL intervals ended on September 9, 2008 and the ASME Class 1, 2, and 3 interval currently ends on December 31, 2009.
5. Proposed Alternative and Basis for Use
In lieu of the ASME Boiler and Pressure Vessel Code,Section XI, 1992 Edition with the 1992 Addenda requirements listed in Section 3 the following alternative is proposed for the containment first inservice inspection interval end date:
- 1. The first containment inservice inspection interval shall end no later than December 31, 2009.
- 2. All examinations required for the first containment inspection interval per ASME XI 1992 Edition with the 1992 Addenda have been completed and were in compliance with the requirements of Inspection Program B prior to September 9, 2008.
Page 2 of 4
RELIEF REQUEST NO. 22 R. E. Ginna Nuclear Power Plant - First Interval IWE/lWL Containment Program Alternative for Containment Inservice Inspection (CISI) Interval Extension The first inservice inspection interval for containment began on September 9, 1998 and ended on September 8, 2008 for the R.E. Ginna Nuclear Power Plant. This inspection interval was established in order to implement the Expedited Examination requirements for containments imposed by 10CFR50.55a following September 9, 1996.
R.E. Ginna Nuclear Power Plant chose to establish a new inspection interval for containment so that the end of the first period of the first inspection interval (for IWE) coincided with the end of the Expedited Examination Period on September 9, 2001. As a result, the inspection interval does not coincide with the inspection interval for ASME Class 1, 2, and 3 components. This4 has resulted in different editions and addenda of Section Xl being required for inservice inspection and repair/replacement activities for Class 1, 2, and 3 components, and for Class MC (IWE) and CC (IWL) components.
The proposed alternatives herein will allow alignment of the CISI with the Class I, 2, and 3 inspection interval. This has distinct advantages in that there will be fewer procedures to maintain. The procedures will meet the requirements of one edition/addenda of the Code, instead of multiple editions/addenda. This also reduces the potential to apply incorrect ISI requirements for specific repair/replacement or component examinations.
Common procedures and documents can be used that will reduce the administrative burden of complying with different ISI requirements without a reduction in the quality or safety of the CISI or ASME Class 11 2, and 3 ISl Program.
IWA-2430 of ASME Xl does not address requirements for establishing inservice inspection intervals for Subsection IWL examinations. However, R.E. Ginna intends to establish a 120 month inspection interval for IWL consistent with the interval start and end dates of the ASME Class 1, 2 and 3 ISI interval for purposes of complying with the 120 month interval update requirements of 10 CFR 50.55a(b)(2)(vi) and 10 CFR 50.55a(g) (4) (ii).
Based on the above, R.E. Ginna concludes that this proposed alternative provides an acceptable level of quality and safety.
6. Duration of Proposed Alternative
This request is applicable to the R.E. Ginna Nuclear Power Plant First Containment Inservice Inspection Interval end date. The proposed duration of this request is until December 31, 2009.
Page 3 of 4
RELIEF REQUEST NO. 22 R. E. Ginna Nuclear Power Plant - First Interval IWE/IWL Containment Program Alternative for Containment Inservice Inspection (CISI) Interval Extension
7. Precedents
Similar relief request with regards to extending the 10-year Containment (IWWE/IWL) inservice inspection interval was sub0mitted by American Electric Power for D.C. Cook Nuclear Plants Unit 1 and 2 in correspondence dated July 17, 2007 and approved on March 28, 2008.
- 8. References
- 1. ASME Boiler and Pressure Vessel Code,Section XI, 1992 Edition with the 1992 Addenda, American Society of Mechanical Engineers, New York.
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