ML13365A060
| ML13365A060 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/18/2013 |
| From: | Mark D. Sartain Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 13-648 | |
| Download: ML13365A060 (7) | |
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10 CFR 50.55a VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 18, 2013 U. S. Nuclear Regulatory Commission Serial No.13-648 Attention: Document Control Desk NAPS/JHL RO Washington, D.C. 20555 Docket Nos. 50-338, 339 License Nos. NPF-4, 7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNITS 1 AND 2 REQUEST FOR ALTERNATIVE TO REQUIREMENTS OF ASME BOILER AND PRESSURE VESSEL CODE REQUEST FOR ALTERNATIVE - IWEI Pursuant to 10CFR50.55a(a)(3)(i), Dominion requests NRC approval of the attached request for an American Society of Mechanical Engineers (ASME) alternative associated with the Second 10-Year Containment Inservice Inspection (ISI) Program Interval for North Anna Power Station Units 1 and 2. The second interval of the North Anna I and 2 Containment ISI Program complies with the ASME Boiler and Pressure Vessel (B&PV) Code, Section Xl Rules for Inservice Inspection of Nuclear Power Plant Components, 2001 Edition with 2003 Addenda.
The steel liners used for the North Anna Units 1 and 2 concrete containments are Class MC components.
Minor containment liner repair activities [two liner test connections
(< /2 inch) in each unit] were performed in accordance with the North Anna Repair/Replacement Program during previous refueling outages (N1R20 and N2R20).
Detailed visual and surface (liquid penetrant) examinations were performed satisfactory in accordance with the ASME Section XI. Consistent with IWE-5222, the pressure tests of the repairs were deferred to the next scheduled 1 OCFR50, Appendix J pressure test.
However, ASME Section XI, IWE-5240 specifies a detailed visual inspection concurrently with the pressure test for the repair. A 10CFR50, Appendix J pressure test is to be performed, but the repaired/replaced areas of the containment liner will be inaccessible during the pressure test, and the concurrent detailed visual examination required by IWE-5240 is not possible.
The attached request for alternative would permit extending ASME Code Case N-649 applicability to the 2001 Edition / 2003 Addenda for use in the North Anna Units 1 and 2 second 10 year Containment Inservice Inspection Interval.
Approval of this request allows previously performed detailed visual examinations as substitutes for the concurrent detailed visual examinations required by IWE-5240.
NRC approval of the attached alternative is requested on the basis that performing visual examinations of North Anna Units 1 and 2 containment liners during post repair pressure test (Type A test) as required by IWE-5240 are not possible due to the
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Serial No.13-648 Docket Nos. 50-338, 339 Request for Alternative IWE1 Page 2 of 3 containments inaccessibility during the pressure test. The proposed alternative will provide an acceptable level of quality and safety.
Dominion requests to implement this alternative to the ASME Code up to the next scheduled 10CFR50 Appendix J pressure test (Type A) for any repair/replacement activity occurring in the second 10-year Containment Inservice Inspection (CISI) interval at North Anna Power Station Unit 1 and Unit 2, which will end on October 6, 2017 for Unit 1 and October 11, 2018 for Unit 2. Dominion requests approval of this request for alternative by September 1, 2014 to support the upcoming North Anna Unit 2 refueling outage.
If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.
Respectfully, M. D. Sartain Vice President - Nuclear Engineering and Development Commitments made in this letter: None Attachment - North Anna Power Station Units 1 and 2 Request for Alternative IWE1
Serial No.13-648 Docket Nos. 50-338, 339 Request for Alternative IWE1 Page 3 of 3 cc:
U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, Virginia 23060 NRC Senior Resident Inspector North Anna Power Station Ms. K. R. Cotton-Gross NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 G9A 11555 Rockville Pike Rockville, Maryland 20852 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738
Serial No.13-648 ATTACHMENT CONTAINMENT INSERVICE INSPECTION PROGRAM SECOND 10-YEAR INTERVAL REQUEST FOR ALTERNATIVE IWE1 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNITS 1 AND 2
Serial No.13-648 Virginia Electric and Power Company (Dominion)
North Anna Power Station Unit 1 and Unit 2 Second 10 Year Interval 1/2-NAPS-RR-IWE1 ASME Code Case N-649 Proposed Alternative in Accordance with 10CFR50.55a(a)(3)(i)
-- Alternative Provides Acceptable Level of Quality or Safety --
1.0 ASME CODE COMPONENTS AFFECTED Code Class:
MC
Reference:
ASME Code, Section Xl, Paragraphs IWE 5221, IWE-5240, and ASME Code Case N-649 Examination Category:
E-A Item Number:
E1.10 and E1.12
==
Description:==
Containment metallic liner Component Number:
Various 2.0 APPLICABLE CODE EDITION AND ADDENDA North Anna Power Station Units 1 and 2 are currently in the second 10-year Containment Inservice Inspection Interval which began on October 7, 2007 for Unit 1 and October 12, 2008 for Unit 2. The ASME Boiler and Pressure Vessel Code (ASME Code) of record for the current interval is the 2001 Edition with 2003 Addenda.
3.0 APPLICABLE CODE REQUIRMENTS The ASME Code, Section Xl, Paragraph IWE-5221, "System Pressure Tests:
Tests following Repair/Replacement Activities: Except as noted in IWE-5222, repair/replacement activities performed on the pressure retaining boundary of Class MC or Class CC components shall be subjected to a pneumatic test in accordance with the provisions of Title 10, Part 50 of the Code of Federal Regulations, Appendix J, Paragraph IV.A."
The ASME Code, Section Xl, Paragraph IWE-5240, "Visual Examination: During the pressure test required by IWE-5220, a detailed visual examination (IWE-2310) shall be performed on areas affected by repair/replacement activities."
4.0 REASON FOR REQUEST Pursuant to 10CFR50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative will provide an acceptable level of quality and safety.
Serial No.13-648 ASME Section Xl repair/replacement activities were performed on the Unit 1 and Unit 2 containments. Detailed visual and surface (liquid penetrant) examinations were performed in accordance with ASME Section XI.
ASME Section XI, IWE-5240 requires a detailed visual inspection of the repair/replacement area concurrent with the pressure test. ASME Section Xl, IWE-5222 allows deferral of the pressure test until the next scheduled leakage test for minor repair/replacement activities. A 1 0CFR50, Appendix J pressure test is to be performed, but the repaired/replaced components will be inaccessible during the pressure test, and the concurrent detailed visual examination for IWE-5240 is not possible.
If a 1 OCFR50 Appendix J pressure test (Type A) is deferred, ASME Code Case N-649, "Alternative Requirements for IWE-5240 Visual Examination" provides the alternative to perform the visual examination upon completion of the repair/replacement and complete the pressure test at a later scheduled date.
NRC Regulatory Guide 1.147, Revision 16, "Inservice Inspection Code Case Acceptability, ASME Section Xl, Division 1," lists ASME Code Case N-649 as acceptable for use with no conditions or limitations. However, the Code Case N-649 visual examination requirements are limited to the 1998 Edition with the 2000 Addenda.
5.0 PROPOSED ALTERNATIVES AND BASIS FOR USE North Anna Power Station Units 1 and 2 request extending ASME Code Case N-649 applicability to the 2001 Edition / 2003 Addenda of ASME Section Xl for use in the North Anna second 10 year Containment Inservice Inspection Interval.
The requirements of Paragraphs IWE-5221 and IWE-5240 in the 2001 Edition /
2003 Addenda are identical to those in the 1998 Edition / 2000 Addenda. Code Case N-649 will permit crediting the scheduled Type A, Type B or Type C test, regardless of deferral, as the required pressure test for a containment repair/replacement activity.
ASME Section Xl, Paragraph IWE-5210 states that except as noted within Paragraph IWE-5240, the requirements of Article IWA-5000 are not applicable to Class MC or Class CC components. Paragraph IWE-5240 states that the requirements of IWE-2310 for detailed visual examination are applicable.
A detailed visual examination in accordance with IWE-231 0 prior to the Appendix J pressure test is adequate to assess the condition of the surfaces affected by repair/replacement activities and to determine the magnitude and extent of any deterioration and distress of these surfaces.
I Serial No.13-648 Dominion has determined that compliance with the pressure test requirements to perform a detailed visual examination during the 10CFR50 Appendix J pressure test is not possible. The proposed alternative provides an acceptable level of quality and safety. The pressure testing in accordance with 1 OCFR50 Appendix J provides an additional verification of the integrity of the welds. Therefore, Dominion requests approval of this alternative pursuant to the provisions of 1 OCFR50.55a(a)(3)(i).
6.0 DURATION OF PROPOSED ALTERNATIVE The proposed alternative to the ASME Code is applicable up to the next scheduled 10CFR50 Appendix J pressure test (Type A) for any repair/replacement activity occurring in the second 10-year Containment Inservice Inspection (CISI) interval at North Anna Power Station Unit 1 and Unit 2, which will end on October 6, 2017 for Unit I and October 11, 2018 for Unit 2.
7.0 PRECEDENTS Similar relief requests to extend ASME Code Case N-649 applicability was approved or submitted for approval for the following utilities:
" Three Mile Island Unit 1 (NRC Safety Evaluation Report dated July 20, 2011 - ADAMS Accession ML111730475
" Braidwood Station, Units 1 and 2 (NRC Safety Evaluation Report dated September 4,2013) - ADAMS Accession ML13246A019
" Proposed Alternative to Utilize Code Case N-649, "Alternative requirements for IWE-5240 Visual Examination Section Xl, Division 1 -
ADAMS Accession ML13270A060
8.0 REFERENCES
Case N-649 - Alternative Requirements for IWE-5240 Visual Examination Section XI, Division 1