ML13100A049
| ML13100A049 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/29/2013 |
| From: | Cotton K Plant Licensing Branch II |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| N Chokshi NRO/DSER 301-415-1634 | |
| References | |
| TAC ME8774, TAC ME8775 | |
| Download: ML13100A049 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 29, 2013 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
SURRY POWER STATION, UNIT NOS 1 AND 2 - RELIEF FROM THE REQUIREMENTS OF THE ASME SECTION XI CODE S1-15-ISI-01 & S2-15-ISI-01 REGARDING USE OF ASME SECTION XI 2004 EDITION (TAC NOS. ME8774 AND ME8775)
Dear Mr. Heacock:
By letter dated April 25, 2012, Virginia Electric and Power Company (Dominion, the licensee) submitted a request to the Nuclear Regulatory Commission (NRC) for approval to use, alternatives, Relief Requests S1-15-ISI-01 and S2-15-ISI-01, to the requirements of 50. 55a(g)(4)(ii)
Title 10 of The Code ofFederal Regulations (10 CFR) paragraph 50.55a(g)(4)(ii) pertaining to the 10-year update of the Surry Inservice Inspection (lSI) program for Surry Power Station, Units 1 and 2.
Specifically, the alternatives were requested pursuant to 10 CFR 50.55a(a)(3)(i), to use an alternative to the requirements of 10 CFR 50.55a(g)(4)(ii) to update the Surry, Units 1 and 2, lSI programs for the fifth 10-year inservice inspection interval to the requirements in the 2004 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)
Section XI, rather than the 2007 Edition with the 2008 Addenda, which is the latest edition/addenda approved for use in 10 CFR 50.55a(b)(2).
The NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a, and the proposed alternatives Relief Requests S1-15-ISI-01 and S2-15-ISI-01 provide an acceptable level of quality and safety. Therefore, the NRC staff authorizes use of Relief Requests S1-15-ISI-01 and S2-15-ISI-01 for the fifth 1 O-year lSI interval scheduled to begin October 14, 2013 and end on October 13, 2023 for Unit 1 and scheduled to begin May 10, 2014 and end May g, 2024 for Unit 2.
D. Heacock
-2 If you have any questions, please contact the Project Manager, Karen Cotton at 301-415-1438 or via e-mail at Karen.Cotton@nrc.gov.
Sincerely, Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281 cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUESTS FOR RELIEF S1-15-ISI-01 AND S2-15-ISI-01 REGARDING USE OF ASME SECTION XI 2004 EDITION SURRY POWER STATION, UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
DOCKET NUMBERS 50-280 AND 281
1.0 INTRODUCTION
By letter dated April 25, 2012 (Agencywide Documents Access and Management System ADAMS Accession No. ML12130A216), Virginia Electric and Power Company (Dominion, the licensee) requested pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i) approval of Relief Requests S1-15-ISI-01 and S2-15-ISI-01, which propose an alternative to the requirements of Title 10 of the Code ofFederal Regulations (10 CFR) paragraph
- 50. 55a(g)(4)(ii) pertaining to the 10-year update of Surry Power Station, Units 1 and 2 (Surry)
Inservice Inspection (lSI) program. Specifically pursuant to 50.55 a(a)(3)(i), Relief Requests S1-15-ISI-01 and S2-15-ISI-01, propose to update the Surry Units 1 and 2 lSI programs for the fifth 10-year inservice inspection interval to the requirements in the 2004 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, rather than the 2007 Edition with the 2008 Addenda, which is the latest edition/addenda approved for use in 10 CFR 50.55a(b)(2).
2.0 REGULATORY EVALUATION
Pursuant to 10 CFR 50.55a(g)(4), ASIVIE Code Class 1, 2 and 3 components, (including supports),
shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of components. Paragraph 50.55a(g)(4)(i) requires that inservice examination of components and system pressure tests conducted during the first 120-month inspection interval comply with the requirements of the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b)(2) twelve months prior to the issuance of the operating license, subject to the conditions listed therein. Paragraph 50.55a(g)(4)(ii) requires that inservice examination of components and system pressure tests conducted during subsequent 120-month inspection intervals comply with the requirements of the latest edition and addenda of Section XI of the ASME Code incorporated
- 2 by reference in 10 CFR 50.55a(b)(2) 12 months prior to the start of the 120-month inspection interval, subject to the conditions listed therein.
Paragraph 50.55a(a)(3) to 10 CFR states, in part, that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (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 10 CFR 50.55a(g)(5)(iii) states that if the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in
§50.4, information to support the determinations.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Request for Alternative Code Requirements The Surry 120-month lSI program for the fifth 10-year lSI interval is required by 10 CFR 50.55a(g)(4)(ii) to be updated to the 2007 Edition with the 2008 Addenda of ASME Code Section XI.
Licensee's Proposed Alternative Dominion proposes Relief Requests S1-15-ISI-01 and S2-15-ISI-01 for Surry, Units 1 and 2, respectively, to utilize the alternative requirements in the 2004 Edition of ASME Code Section XI, subject to the conditions contained in 10 CFR 50.55a(b)(2) for the fifth 10-year lSI interval.
Basis for Proposed Alternative In the licensee's April 25, 2012, submittal it is stated that, "four Dominion nuclear operating units have started new 10-year inservice inspection intervals within the last three years." The licensee states that Milestone, Units 2 and 3 and North Anna, Units 1 and 2, all updated their ASME Section XI programs between April 23, 2009 and December 14, 2010. Each of these four units updated to the 2004 Edition of ASME Section XI in accordance with 10 CFR 50.55a(g)(4)(ii).
Section XI activities (e.g. lSI, repair/replacement, pressure testing, and Non-Destructive Examination (NDE) at, Millstone, Units 2 and 3, North Anna, Units 1 and 2 and Surry, Units 1 and 2, are standardized and corporately administered by Dominion.
The licensee's April 25, 2012, submittal goes on to state that, "ASME Section XI activities at the Millstone, North Anna and Surry Power Station units are standardized and corporately administered as a fleet operation at Dominion. Dominion lSI and Non Destructive Examination personnel assist one another in the planning, performing, reporting and assessing of lSI activities throughout the fleet. Maintaining a common ASME Section XI Code for the Dominion units and conforming to identical ASME Section XI rules would assist incorporation of industry best standards and would reduce administrative burden and error-likely situations."
Dominion performed a detailed comparison of the 2004 Edition and the 2007 Edition with the 2008 Addenda of ASME Code Section XI and identified no changes that ensured or increased the
- 3 level of safety or quality. Also, no changes were found that addressed deficiencies in the 2004 Edition. Dominion believes that use of a common set of ASME Code Section XI requirements will improve the level of quality and safety at the fleet's units by reducing error-likely situations and through the sharing of knowledge and lessons learned in implementation of the same lSI Program rules.
3.2 Staff Evaluation The licensee's proposed alternatives S1-15-ISI-01 and S2-15-ISI-01 would allow Surry Unit 1 and 2 respectively to update the fifth 10-year lSI interval program to the 2004 Edition of ASME Code,Section XI rather than the 2007 Edition through the 2008 Addenda currently incorporated by reference in 10 CFR 50.55a(b). The Unit 1, fifth 10-year lSI interval is scheduled to begin October 14, 2013, and the Unit 2, fifth 10-year lSI interval is scheduled to begin May 10, 2014.
There were numerous changes incorporated into the 2004 Edition of ASME Code,Section XI.
The NRC staff evaluated these changes when the 10 CFR 50.55a(b)(2) regulations were changed to incorporate by reference the 2007 Edition through the 2008 Addenda of Section XI.
The staff did not find it necessary to mandate that plants following earlier editions and addenda of ASME Code,Section XI implement any of the changes incorporated into the 2007 Edition through the 2008 Addenda of Section XI. However, the staff did mandate certain augmented inservice inspection program requirements found in 10 CFR 50.55a(g)(6)(ii) which include containment inservice inspection in accordance with Subsections IWE and IWL, Reactor vessel head inspections, Reactor coolant pressure boundary visual inspections and Examination requirements for class 1 piping and nozzle dissimilar-metal butt welds which Surry, Units 1 and 2, must follow. The licensee is required to implement the requirements of 10 CFR 50.55a(g)(6)(ii) at Surry, Units 1 and 2. The staff also notes that 10 CFR 50.55a(b)(2)(xv) requires licensees utilizing editions and addenda after the 2001 Edition through the 2006 Addenda to use the 2001 Edition of Appendix VIII. With these mandatory augmented examinations, the staff finds that an lSI program following the requirements of the 2004 Edition of ASME Code,Section XI subject to the conditions of 10 CFR 50.55a(b) and the requirements of 50.55a(g)(6)(ii) will provide an acceptable alternative to the 2007 Edition through the 2008 addenda.
The proposed alternative will allow the use of a common Code of record for the Dominion Surry Power Station, Unit 1 and 2, the Millstone, Units 2 and 3, and the North Anna, Units 1 and 2, lSI Programs. The common Code of record will be 2004 Edition of ASIVIE Code,Section XI for all six of these Dominion lSI programs. There are distinct advantages in implementing the same code requirements at multi-unit sites for a licensee. The advantages include the reduction of administrative burden of maintaining different sets of procedures and requirements and results in a significant decrease in the chances of applying the wrong requirements.
Based on the above, the NRC staff has determined that the licensee's proposed alternatives will make implementation of the lSI programs at Surry Power Station more efficient and effective.
Therefore, the staff finds that the licensee's proposed alternatives will provide an acceptable level of quality and safety.
-4
4.0 CONCLUSION
As set forth above, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a, and the proposed alternatives Relief Requests S1-15-ISI-01 and S2-15-ISI-01 provide an acceptable level of quality and safety.
Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(i), and is in compliance with the ASME Code's requirements. Therefore, the NRC staff authorizes use of Relief Requests S1-15-ISI-01 and S2-15-ISI-01 for the fifth 10-year lSI interval at Surry Power Station, Unit 1 and Unit 2, respectively. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the authorized Nuclear Inservice Inspector.
Principal Contributor: Keith M. Hoffman Date: April 29, 2013
D. Heacock
- 2 If you have any questions, please contact the Project Manager, Karen Cotton at 301-415-1438 or via e-mail at Karen.Cotton@nrc.gov.
Docket Nos. 50-280 and 50-281 cc w/encls: Distribution via Listserve DISTRIBUTION:
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RidsN rrDorl Lp12-1 RidsAcrsAcnwMailCenter RidsNrrPMSurry Resource K. Hoffman NRR/DE ADAMS Accession No.: ML131 OOA049 Sincerely, IRA!
Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation "via email OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DE/EPNB/BC NRR/LPL2-1/BC NRR/LPL2-1/PM NAME KCotton SFigueroa*
TLupold RPascerel1i KCotton DATE 04/16/13 04/26/13 04105113 04/29/13 04/29/13 OFFICIAL RECORD COpy