ML103350217

CFR 50.55a Request ISI-04: Request for Use of Alternate Depth Sizing Qualification

ML103350217
Person / Time
Site:	Ginna
Issue date:	11/24/2010
From:	Swift P Constellation Energy Group, Ginna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ISI-04, TAC MD8733
Download: ML103350217 (6)

Text

Paul Swift R.E. Ginna Nuclear Power Plant, LLC Manager - Engineering Services 1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax

.O E N IGPa ul. swiftOce nq 11cicomn CENG a joint venture of CEfltOIMIO 1.,,eDF November 24, 2010 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:

Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 10 CFR 50.55a Request ISI-04: Request for Use of an Alternate Depth Sizing Qualification

Reference:

(1) Letter from M. G. Kowal, NRC, to J. Carlin, Ginna LLC,

Subject:

Fourth Interval Inservice Inspection Program Relief Request No. 19-Deferral of Reactor Pressure Vessel Category B-F Exams from 2009 to 2011 - R.E.

Ginna Nuclear Power Plant (TAC NO. MD8733) (ML090330300)

By letter dated February 17, 2009, the NRC granted R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) Relief Request No. 19, (Reference 1), deferring reactor pressure vessel Category B-F Examinations from 2009 to the 2011 Refueling Outage (RFO).

Pursuant to 10 CFR 50.55a(a)(3)(i), R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) hereby requests the use of alternate depth sizing qualification pertaining to examinations for the Fourth Interval Inservice Inspection (ISI) Program, as described within the attached enclosure, to be performed during the 2011 RFO. This request for relief is from certain examination coverage requirements imposed by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, 1995 Edition/1 996 Addenda. Ginna LLC proposes to apply the difference between the examination vendors achieved Root Mean Square.(RMS) error and the NRC approved Code Case N-695 required 0.125 inch RMS error to actual flaw depths when depth-sizing of indications is required. Applying the difference between the required RMS error and the achieved RMS error to the actual flaw being sized will ensure a bounding flaw depth for dissimilar metal welds examined.

Ginna LLC requests review and approval of this relief request by April 15, 2011, in support of the spring 2011 RFO.

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Document Control Desk November 24, 2010 Page 2 There are no regulatory commitments contained in this letter. Should you have questions regarding this matter, please contact Thomas Harding (585) 771-5219, or Thomas. hardinqfirccenqllc.com.

Very truly yours, Paul Swift

Enclosure:

10 CFR 50.55a R.E. Ginna Nuclear Power Plant - Fourth Interval Inservice Inspection (ISI) Program Relief Request ISI-04 cc:

W. M. Dean, NRC D. V. Pickett, NRC Resident Inspector, NRC (Ginna LLC)

ENCLOSURE 10 CFR 50.55a R.E. Ginna Nuclear Power Plant -

Fourth Interval Inservice Inspection (ISI) Program Relief Request ISI-04

ENCLOSURE 10 CFR 50.55a R.E. Ginna Nuclear Power Plant - Fourth Interval Inservice Inspection (ISI) Program Relief Request ISI-04 Alternative Requirements to ASME Section Xl Appendix VII, (Supplements 2 and 10)

Examinations of Class I Pressure Retaining Welds Conducted from the Inside Surface

1.

ASME Code Component(s) Affected Code Class: 1 Examination Categqory: B-F (Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles)

Item Number: B5.10 Table A Summary No.

Weld ID Description I 002100 PL-FW-11 RC Nozzle - to - Pipe I 002700 PL-FW-IV RC Nozzle - to - Pipe I 002400 PL-FW-V RC Elbow - to - Nozzle I 003000 PL-FW-VII RC Elbow - to - Nozzle I 003600 AC-1 002-1 SI Safe End - to - Nozzle I 003300 AC-1003-1 SI Safe End - to - Nozzle RC = Reactor Coolant SI = Safety Injection

2.

Applicable Code Edition and Addenda

This alternative requirement request pertains to examinations for R.E. Ginna Nuclear Power Plant Fourth Interval In-Service Inspection (ISI) Program as described within R.E.

Ginna Nuclear Power Plant Relief Request Number 19, to be performed during the 2011 Refueling Outage (RFO). The Fourth Interval In-Service Inspection (ISI) Program was based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, Section Xl, 1995 Edition with 1996 Addenda. Testing of personnel, procedures and equipment for the ultrasonic examination of applicable Class 1 and 2 components is governed by Appendix VIII, "Performance Demonstration for Ultrasonic Examination Systems," of the ASME Code,Section XI.

3.

Applicable Code Requirements The examination of Class I and 2 piping welds are required to be performed using procedures, personnel and equipment qualified to the criteria of the ASME Code, Section Xl, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Pipe Welds," for the examination of Code Item Number B5.10 welds.

Paragraph 3.2, "Sizing Acceptance Criteria," Subparagraph (b) of Supplement 10, states that the "examination procedures, equipment, and personnel are qualified for depth-sizing Page 1 of 3

ENCLOSURE 10 CFR 50.55a R.E. Ginna Nuclear Power Plant - Fourth Interval Inservice Inspection (ISI) Program Relief Request ISI-04 when the RMS [root mean square] error of the flaw depth measurements, as compared to the true flaw depths, is less than or equal to 0.125-inch (3.2mm)."

Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds, Section Xl, Division 1", provides alternative requirements to Appendix VIII, Supplement 10 and is unconditionally approved for use through Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section Xl, Division 1," Revision 15.

Paragraph 3.3(c) of Code Case N-695 states, "Examination procedures, equipment, and personnel are qualified for depth-sizing when the RMS error of the flaw depth measurements, as compared to the true flaw depths, do not exceed 0.125-in. (3 mm)."

4.

Reason for the Request R.E. Ginna Nuclear Power Plant is performing volumetric examinations of all reactor pressure vessel (RPV) piping dissimilar metal (DM) welds from the inside diameter (ID) surface during the upcoming 2011 RFO in accordance with our Fourth Interval Relief Request Number 19. R.E. Ginna Nuclear Power Plant will implement the NRC-approved alternative requirements of Code Case N-695 for qualification.

R.E. Ginna Nuclear Power Plant proposes using an alternative RMS error depth-sizing requirement as compared to the 0.125-inch RMS error value stated in Code Case N-695.

Electric Power Research Institute (EPRI) NDE Center was contacted and confirmed with the Performance Demonstration Initiative (PDI) Administrator that no vendor has successfully demonstrated compliance with the Code-required 0.125-inch RMS value for qualification tests for examinations conducted from the ID surface (for either stand-alone Supplement 10 or combined Supplement 2 and 10 qualifications).

R.E. Ginna Nuclear Power Plant has verified through the PDI Administrator that the examination vendor selected to perform the scheduled examinations at R.E. Ginna Nuclear Power Plant has achieved a 0.1 89-inch RMS error for the Supplement 10 qualification and a 0.245-inch RMS error for the Combined Supplement 2 and 10.

5.

Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested for an alternative requirement that will provide an acceptable level of quality and safety.

For examinations of DM welds (Supplement 10), R.E. Ginna Nuclear Power Plant proposes to apply the difference between the examination vendor's achieved RMS error and the Code Case N-695 required 0.125-inch RMS error to actual flaw depths when depth-sizing of indications is required.

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ENCLOSURE 10 CFR 50.55a R.E. Ginna Nuclear Power Plant - Fourth Interval Inservice Inspection (ISI) Program Relief Request ISI-04 Applying the difference between the required RMS error and the achieved RMS error to the actual flaw being sized will ensure a conservative bounding flaw depth for dissimilar metal welds examined at R.E. Ginna Nuclear Power Plant.

6.

Duration of Proposed Alternative This relief request will be implemented during the 2011 RFO in accordance with the R.E.

Ginna Nuclear Power Plant Fourth Interval Inservice Inspection Program, Relief Request Number 19, SER dated February 17, 2009.

7.

Precedents Similar relief requests have been granted to the following plants:

NRC to Southern Nuclear Operating Company Inc. letter, "Joseph M. Farley Nuclear Plant, Unit 1, and Vogtle Electric Generating Plant, Units 1 and 2 - Evaluation of Relief Request ISI-GEN-ALT-06-02," (TAC Nos. MD 2482, MD2483 and MD2484), dated September 29,2006, (ML062770359)

NRC to Exelon Generating Company, LLC letter, "Braidwood Station, Units 1 and 2.-

Relief Request (12R-49) Regarding Inservice Inspection Program Alternative Method (TAC Nos. MD5996 and MD5997)," dated November 8,2007, (ML072760048)

NRC to FPL Point Beach, LLC letter, "Point Beach Nuclear Plant, Units 1 and 2 - The Fourth 10-Year Interval Inservice Inspection Program Plan Requests for Relief No. RR-21 (TAC Nos. MD8319 and MD8320)," dated August 25, 2008.

NRC to FPL Energy Seabrook, LLC letter, "Seabrook Station, Unit No. 1 - Relief Request for use of an Alternate Flaw Sizing Methodology for the Second Inservice Inspection Interval (TAC No. MD9785)," dated May 19, 2009.

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