ML15055A588
| ML15055A588 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/19/2015 |
| From: | Gatlin T SCANA Corp, South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RR-4-08 ISI | |
| Download: ML15055A588 (5) | |
Text
Thomas D. Gatlin Vice President, Nuclear Operations 803.345.4342 r/I
,February 19, 2015 A SCANA COMPANY Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Sir / Madam:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 REQUEST RELIEF FROM ASME CODE REQUIREMENTS IN VCSNS 4TH TEN YEAR INSERVICE INSPECTION INTERVAL RR-4-08 ISI SNUBBER AND ASSOCIATED HARDWARE EXAMINATION REQUIREMENTS Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (z)(1), South Carolina Electric &
Gas Company (SCE&G), acting for itself and as an agent for South Carolina Public Service Authority, hereby requests NRC approval of the attached relief request associated with the fourth inservice inspection (ISI) interval. VCSNS proposes to perform the visual examination of snubbers and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) per the Snubber Program which will be documented in a surveillance test.
procedure that will invoke the ASME OM Code, Subsection ISTD. The basis for the relief...
request is provided within Attachment 1.
SCE&G requests that this inspection alternative be approved by September 1, 2015, in support of the upcoming Fall 2015 refueling outage (RF22).
A new regulatory commitment to revise VCSNS Surveillance Test Procedure STP-803.002 to incorporate the visual examination of snubber attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) can be found in Attachment 2 of this submittal.
If you should have any questions, please contact Mr. Bruce L. Thompson at (803) 931-5042.
Very truly yours, Thomas D. Gatlin TS/TDG/wt : RR-4-08 (G) ISI Snubber and Associated Hardware Examination Requirements : List of Regulatory Commitments c:
K. B. Marsh J. W. Williams K. M. Sutton S. A. Byrne W. M. Cherry NSRC J. B. Archie V. M. McCree (w/attachments)
RTS (CR-14-06003)
N. S. Cams S. A. Williams (w/attachments)
File (810.19-2)
J. H. Hamilton NRC Resident Inspector PRSF (RC-15-0011) (w/attachments)
Virgil C. Summer Station -Post Office Box 88-Jenkinsville, SC. 29065. F (803) 345-5209 to e[.
Document Control Desk CR-14-06003 RC-15-0011 Page 1 of 3 SOUTH CAROLINA ELECTRIC & GAS COMPNAY (SCE&G)
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT I RELIEF REQUEST RR-4-08
- 1.
ASME Code Component Affected ASME Code Classes:
References:
Examination Category:
Item Numbers:
Code Classes 1, 2 and 3 ASME Section Xl, IWF-1220 (2007)
ASME Section Xl, IWF-1300 (2007) and Figure IWF-1300-1 (f) (2007)
ASME Section Xl, IWF-2500 (2008a) and Table IWF-2500-1 (2007)
ASME Section Xl, IWF-3410 (2007)
ASME OM Code, Subsection ISTA (2004)
ASME OM Code, Subsection ISTD (2004)
F-A F1.10, F1.20, F1.30 and F1.40
==
Description:==
Components:
Visual Examination of Snubber Attachment Hardware (Pin-to-Pipe and Pin-to-Structure), Excluding Integral Attachments Code Class 1, 2 and 3 Snubbers
- 2.
Applicable Code Edition and Addenda
2007 Edition with 2008 Addenda of the ASME Boiler and Pressure Vessel Code, Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components"
- 3.
ADplicable Code ReQuirement The examination requirements for supports and associated attachment hardware are specified in ASME Section Xl, IWF-2500. Table IWF-2500-1, Examination Category F-A requires that visual VT-3 examinations be performed on Class 1, 2 and 3 piping and component supports.
The examination and testing of Snubbers is governed by ASME OM Code, Subsection ISTD as per ASME Section Xl, IWF-1220 and 10 CFR 50.55a(b)(3)(v)(B).
When determining the boundaries for support examinations, IWF-1 300(g) states, "All integral and nonintegral connections within the boundary governed by IWF rules and requirements are included."
Document Control Desk CR-14-06003 RC-15-0011 Page 2 of 3 This verifies that attachment hardware is included in the examination boundary. The interface boundaries for the examination of Snubbers and snubber attachment boundaries for the examination of Snubbers and snubber attachment hardware is further addressed in IWF-1300(h) which states, "The examination boundary of a support containing a snubber shall not include the connection to the snubber assembly (pins)."
These boundaries are shown graphically in Figure IWF-1300-1 (f).
- 4.
Reason for Request
VCSNS Unit 1 is required to perform VT-3 visual examinations on Class 1, 2 and 3 supports, including attachment hardware, per ASME Section Xl. VCSNS is also required to perform visual examinations and testing on snubber assemblies in accordance with ASME OM Code, Subsection ISTD. When incorporating the criteria of Subsection ISTD into the Snubber Program, SCE&G included the visual examination of the snubber assembly (pin-to-pin). VCSNS Unit 1 will update Surveillance Test Procedure STP-803.002, Mechanical Snubber Visual Examination, to include the visual examination of snubber attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments). With the proposed procedure update, the visual examination criteria of the Snubber Program will meet the requirements established by ASME Section X1. Having two nearly identical sets of requirements for the visual examination of snubber attachment hardware would require the performance of redundant examinations and cause unnecessary confusion in the sample selection, data collection and documentation of these examinations.
- 5.
Proposed Alternative and Basis for Use Proposed Alternative Pursuant to 10 CFR 50.55a(z)(1), SCE&G proposes to perform the visual examination of snubbers and associated attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments) upon revision to STP-803.002, which will provide the requirements necessary to implement and administer a comprehensive snubber surveillance, testing, maintenance, and service life monitoring program. STP-803.002 is written to meet ASME OM Code, Subsection ISTA, "General Requirements" and Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants."
The examination of integral attachments will be in accordance with ASME Section Xl, Table IWB-2500-1 (Examination Category B-K), Table IWC-2500-1 (Examination Category C-C) and Table IWD-2500-1 (Examination Category D-A).
Document Control Desk CR-14-06003 RC-15-0011 Page 3 of 3 Basis for Use The examination and testing requirements for snubbers are documented in VCSNS STP-803.002. The proposed revision to the procedure will require an examination frequency that establishes a high level of confidence in the acceptability of the plant's snubbers. In addition, the revised procedure will require the visual examination of snubber attachments, support attachments and attachments to the supporting foundation, including nuts, bolts, studs, welds, pins spacers and embedments. Upon revision, the visual examination criteria established in STP-803.002 will meet the examination criteria specified in ASME Section Xl, IWF-3410. Performing both the ASME Section Xl and Snubber Program examinations would be redundant and would not improve the level of quality and safety in the plant. In addition, it would increase the occupational radiation exposure due to the repetitive activity.
The examinations on integral attachments that are associated with snubber attachment hardware are not included in the scope of this request for relief. The examination of these items will continue in accordance with ASME Section Xl.
- 6.
Duration of Proposed Alternative SCE&G will implement the alternative requirements during the fourth 10-year inservice inspection (ISI) interval at VCSNS Unit 1 which began January 1, 2014 and ends December 31, 2023.
- 7.
Precedents The NRC has approved similar requests for alternatives at the following facilities:
Relief Request No. IR-3-01 was approved for the Millstone Power Station, Unit 3 in a letter from the NRC dated April 6, 2010, ADAMS Accession No. ML100680118.
Relief Request No. 13R-03 was approved for the Calloway Energy Center in a letter from the NRC dated March 7, 2006, ADAMS Accession No. ML060580568.
Relief Request No. RR-111-01 was approved for the V.C. Summer Nuclear Station in a letter from the NRC dated May 10, 2005, ADAMS Accession No. ML051290198.
Relief Request No.03-002 was approved for the McGuire Nuclear Station, Unit 2 in a letter from the NRC dated November 22, 2004, ADAMS Accession No. ML043080435.
Document Control Desk CR-14-06003 RC-15-0011 Page 1 of 1 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT I DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS The following table identifies the action committed to by the Virgil C. Summer Nuclear Station (VCSNS) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Bruce L. Thompson at (803) 931-5042.
MMTM TRUIWATEV N.
VCSNS is to revise Surveillance Test Procedure STP-803.002 to incorporate the visual examination of snubber attachment hardware (pin-to-pipe and pin-to-structure, excluding integral attachments).
30 Days After Relief Request Approval