ML14051A106

Response to Request for Additional Information (RAI) Alternative to Requirements of ASME Boiler and Pressure Vessel Code Request for Alternative - IWE1

ML14051A106
Person / Time
Site:	North Anna
Issue date:	02/17/2014
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-648A
Download: ML14051A106 (5)

Text

10 CFR 50.55a VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 17, 2014 U. S. Nuclear Regulatory Commission Serial No. 13-648A 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 I AND 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

ALTERNATIVE TO REQUIREMENTS OF ASME BOILER AND PRESSURE VESSEL CODE REQUEST FOR ALTERNATIVE - IWEI In a letter dated December 18, 2013, Dominion requested NRC approval of an 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 1 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 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. In a January 24, 2014 e-mail from Dr. V. Sreenivas, the NRC requested additional information to complete the technical review of the proposed alternative. The attachment to this letter provides the requested information.

Dominion continues to request 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 Commitments made in this letter: None Attachment - Response to Request for Additional Information - Alternative to Requirements of ASME Boiler and Pressure Vessel Code Request for Alternative - IWE1

Serial No. 13-648A Docket Nos. 50-338, 339 Request for Alternative IWE1 Page 2 of 2 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. M. C. Barillas 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. 13-648A Docket No. 50-338/339 ATTACHMENT CONTAINMENT INSERVICE INSPECTION PROGRAM SECOND 10-YEAR INTERVAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

ALTERNATIVE TO REQUIREMENTS OF ASME BOILER AND PRESSURE VESSEL CODE REQUEST FOR ALTERNATIVE - IWE1 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2

Serial No. 13-648A Docket No. 50-338/339 Attachment Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)

FOR ALTERNATIVE TO REQUIREMENTS OF ASME BOILER AND PRESSURE VESSEL CODE REQUEST FOR ALTERNATIVE - IWE1

Background

By letter dated December 18, 2013 (ML13365A060), Virginia Electric and Power Company (Dominion), requested a relief request to the Renewed Facility Operating License (FOL) Numbers NPF-4 and NPF-7 for North Anna Power Station (NAPS) Units 1 and 2. The proposed request would permit use of Alternative to Requirements of ASME Boiler and Pressure Vessel Code," Cases of ASME Boiler and Pressure Vessel Code, Case N-649, "Alternative Requirements for IWE-5240 Visual Examination, Section Xl, Division 1," March 28, 2001.

In a January 24, 2014 e-mail from Dr. V. Sreenivas, the NRC Staff requested additional information to complete its detailed technical review. The additional information was requested by February 24, 2014.

NRC Question American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Xl, Paragraph IWE-5220, "System Pressure Tests: Tests Following Repair/Replacement Activities," requires, in part, that, "repair / replacement activities performed on the pressure retaining boundary of Class MC or Class CC components shall be subjected to a pneumatic leakage test..."

Section 5.0 of the proposed alternative states that, "a detailed visual examination in accordance with IWE-2310 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." No discussion is provided in Reference 1 of visual examinations conducted on areas affected by repair/replacement activities after the pressure test.

Paragraph (b) of Code Case N-649 states in part, "when the pressure test is performed, the requirements of the above paragraph shall be met." The "above paragraph" refers to Paragraph (a) which states in part "... [visual examination] shall be performed during or after the pressure test on the areas affected by the repair/replacement activity."

Explain how the requirements of ASME Code Case N-649, for a visual examination of areas affected by repair/replacement activities during or after the required pressure test, will be met.

Serial No. 13-648A Docket No. 50-338/339 Attachment Page 2 of 2 Dominion Response The pressure test (Type A) has not been performed. Satisfactory detailed visual examinations (VT-1), and dye-penetrant (PT) tests were completed on the areas affected by the repair/replacement activities prior to returning them to service, which satisfies the Code Case N-649 alternative of paragraph (b). The use of the alternative is requested to permit the use of Code Case N-649 which allows the pressure test (Type A) to be performed without the concurrent visual examination required under Section Xl, Paragraph IWE-5240.

Following the pressure test (Type A) for each unit, additional VT-3 visual examinations will be performed on the areas affected by the repair/replacement activities to meet the requirements of Code Case N-649 paragraph (a). In accordance with Code Case N-649 paragraph (a), a post pressure test visual examination (VT-3) will be performed to provide verification that surface conditions have not changed following pressure testing and that no conditions adverse to safety or quality exist. Completion of the VT-1 and VT-3 examinations exceed the requirements of Code Case N-649 to provide alternative requirements for IWE-5240 Visual Examinations.