ML092320057

NRC Verbal Approval of Ginna Relief Request No. 24

ML092320057
Person / Time
Site:	Ginna
Issue date:	08/19/2009
From:	Pickett D Plant Licensing Branch 1
To:	Harding T, Roby M Constellation Energy Group
Pickett , NRR/DLPM, 415-1364
References
TAC ME1364
Download: ML092320057 (3)

Text

From: Pickett, Douglas Sent: Wednesday, August 19, 2009 11:12 AM To: 'Harding Jr, Thomas'; 'Ruby, Mike' Cc: Mitchell, Matthew; Salgado, Nancy; Dentel, Glenn; Casey, Lauren; Kolaczyk, Kenneth; Burket, Elise; Perry, Neil; Hawkins, Justin; Hardies, Robert

Subject:

NRC Verbal Approval of Ginna Relief Request No. 24 Earlier today, Matthew Mitchell, Branch Chief of NRR's Vessels & Integrity Branch, and I, as Acting Branch Chief of NRR's Plant Licensing Branch I-1, provided verbal approval pursuant to NRR Office Instruction LIC-102, "Relief Request Reviews," for Ginna's proposed Relief Request No. 24.

We read from the prepared script provided below. The staff will followup with a written safety evaluation in the near future.

This email will be declared an official agency record and made publicly available in ADAMS.

Douglas V. Pickett, Senior Project Manager Calvert Cliffs Nuclear Power Plant, R.E. Ginna Nuclear Power Plant U.S. Nuclear Regulatory Commission 301-415-1364 Email: douglas.pickett@nrc.gov (Matthew Mitchell speaking)

By letter dated May 22, 2009, as supplemented by letter dated August 14, 2009, Constellation Energy, the licensee for R.E. Ginna Nuclear Power Plant, LLC (Ginna), submitted a request for authorization of an alternative to certain requirements of the plants fourth 10-year Inservice Inspection (ISI) interval. The request for authorization of the alternative was made pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i). Specifically, the licensee has proposed an alternative to the 100 percent bare metal visual examination requirements of 10 CFR 50.55a(g)(6)(ii)(E). The licensee requested approval of this alternative for the examinations required during its next refueling outage scheduled to begin in September 2009.

Constellation Energys Relief Request No. 24 proposed an alternative to the bare metal visual inspection requirements of ASME Code Case N-722, which was mandated by NRC as an augmented ISI requirement in 10 CFR 50.55a(g)(6)(ii)(E) on September 8, 2008. ASME Code Case N-722 and 10 CFR 50.55a(g)(6)(ii)(E) require, in part, that 100 percent bare metal visual inspection of bottom mounted instrument (BMI) nozzles be performed every other refueling outage. The licensees proposed alternative is to take credit for limited visual examination of BMI nozzle locations (some of which are partially or wholly occluded by a coating) during the units fall 2009 outage, supplemented by limited visual examination and ultrasonic (UT) inspection from the inside of the 36 BMI nozzles during the units 2011 refueling outage. The proposed volumetric and visual inspections are in lieu of 100 percent bare metal visual examination of the nozzles from outside the reactor vessel. The proposed alternative would include a visual examination of each of the units 36 nozzle locations, to the extent possible, from outside of the vessel in both 2009 and 2011. The proposed alternative would also include an UT inspection in 2011 of each BMI nozzle above, over, and below the partial penetration weld between the penetration nozzle and the reactor vessel.

The licensees basis for requesting the proposed alternative noted that, based on an evaluation of the coating information by a coating specialist and the owners acceptance review of the evaluation, in the event of a reactor coolant leak through the BMI nozzle weld or base material, the coating would be unlikely to resist reactor coolant system pressure and would instead either blister or pass leakage that could be detected by visual examination. In addition, the licensee indicated that its visual examination procedure has a higher visual resolution requirement than that required in Code Case N-722. The use of UT inspection of the BMI nozzle base material will be accomplished using procedures, equipment and personnel who demonstrate proficiency in detecting flaws in site-specific mockups. The licensee concluded that a UT inspection will identify potential flaws in the BMI nozzle base material whose leakage could otherwise be masked during the visual examination of the coating. Additionally, the licensee noted that the UT inspection could identify precursors to leakage by finding part through wall cracks, if any exist, in the base material. The licensee provided an evaluation of service experience with nozzles and partial penetration welds manufactured of Alloy 600/82/182 and noted that cracks in the base material are much more likely than cracks in weld metal. Therefore, the use of the proposed UT and visual inspection techniques will provide an acceptable alternative to the bare metal visual inspection of the BMI nozzles required by 10 CFR 50.55a(g)(6)(ii)(E) for the purpose of detecting flaws which could lead to reactor coolant system leakage.

The NRC has completed its review of the information provided in the licensees submittal dated May 22, 2009, as supplemented by the licensees letter dated August 14, 2009. The NRC has concluded, in accordance with 10 CFR 50.55a(a)(3)(i), that the licensee provided adequate information regarding the proposed alternative to substantiate its implementation. Hence, as Chief of the Office of Nuclear Reactor Regulations Vessel and Internals Integrity Branch, I hereby recommend authorization of the licensees implementation of the proposed alternative in accordance with the information provided in the licensees letters dated May 22, 2009, and August 14, 2009.

(Douglas Pickett speaking)

As Acting Chief of the Office of Nuclear Reactor Regulations Plant Licensing Branch I-1, I concur with the Vessel and Internals Integrity Branchs conclusions. Based on these conclusions, I conclude that the alternative proposed in the licensees letter dated May 22, 2009, as supplemented by letter dated August 14, 2009, will provide an acceptable level of quality and safety. Therefore, the licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the 2009 and 2011 refueling outage.

E-mail Properties Mail Envelope Properties ()

Subject:

NRC Verbal Approval of Ginna Relief Request No. 24 Sent Date: 08/19/2009 11:01:26 AM Received Date: 08/19/2009 11:11:00 AM From: Pickett, Douglas

Created By: Douglas.Pickett@nrc.gov Recipients:

Thomas.HardingJr@constellation.com ('Harding Jr, Thomas')

Tracking Status: None Mike.Ruby@constellation.com ('Ruby, Mike')

Tracking Status: None Matthew.Mitchell@nrc.gov (Mitchell, Matthew)

Tracking Status: None Nancy.Salgado@nrc.gov (Salgado, Nancy)

Tracking Status: None Glenn.Dentel@nrc.gov (Dentel, Glenn)

Tracking Status: None Lauren.Casey@nrc.gov (Casey, Lauren)

Tracking Status: None Kenneth.Kolaczyk@nrc.gov (Kolaczyk, Kenneth)

Tracking Status: None Elise.Burket@nrc.gov (Burket, Elise)

Tracking Status: None Neil.Perry@nrc.gov (Perry, Neil)

Tracking Status: None Justin.Hawkins@nrc.gov (Hawkins, Justin)

Tracking Status: None Robert.Hardies@nrc.gov (Hardies, Robert)

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 26784 08/19/2009 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: