ML17244A587

Inservice Insp Program for 1980-89 (App B of QA Manual)

ML17244A587
Person / Time
Site:	Ginna
Issue date:	07/02/1979
From:	Anderson C, Curtis A ROCHESTER GAS & ELECTRIC CORP.
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ML17244A586	List: ML17244A585 ML17244A587
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NUDOCS 7907060450
Download: ML17244A587 (63)

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SECT. NO. PACE QUALITY ASSURANCE MANUAL OF EFFECTIVE OATE January 1, 1980 ROCHESTER GAS & ELECTRIC CORPORATION SIGNATURE OATE GINNA STATION PREPAREO BY TITLE APPENDIX B IIEYIEWEO Ginna Station Inservice Inspection Program BY'PPROYEO For the 1980-1989 Interval BY:

Q g Pro ram Table of Contents

Introduction:

Discussion Program: 'SX 1.0 Scope and Responsibility ISX 2.0 Inspection Intervals ISI 3.0 Extent and Frequency ISX 4.0 Examination Methods ISI 5.0 Evaluation of Examination Results I ISI 6.0 Repair Requirements ISX 7.0 System Pressure Testing ISI 8.0 Records and Reports ISI 9.0 Exemptions

References:

Tables: ISI 1.1 Quality Group A Components, Parts and Method of Examination ISI 1.2 Quality Group B Components, Parts and Method of Examination Attachment A Quality Groups A, B, and C Exemptions tgCQ~ ops~

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TITLE APPENDIX B Panuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Progra FAG F GINNA STATION For the 1980-1989 Interval 21 OF INTRODUCTION Appendix B of this Quality Assurance Manual describes Ginna's Inservice Inspection Program for the 120 month inspection interval commencing January 1, 1980 and ending December 31, 1989. Included in this program are the following portions of systems and/or components:

Quality Group A Components Quality Group B Components Quality Group C Components High Energy Piping Outside of Containment Steam Generator Tubing Reactor Coolant Pump Flywheels Following the guidance of Reference 1,Section XI of the Code, Ginna's Inservice Inspection Program adheres to the re-quirements of Section 50.55a of the Code of Federal Regulations, Reference 2. This program, however, excludes the controls of the Authorized Nuclear Inspector, Enforcement Authority, Re-porting Systems, and N-Stamp Symbol.

The Inservice Inspection Program for Quality Groups A, B and C components, as defined in Regulatory Guide 1.26, Refer-ence 3, is controlled by Ginna's Quality Assurance Program for Station Operation. This same program which is also in compliance with the referenced Section XI, provides the most acceptable guidelines and latest techniques currently being utilized in the performance of an inservice inspection.

Repairs to Quality Groups A, B and C components shall be performed in accordance with the Owner's Design Specification and Construction Code of the component or system; Later editions of the Construction Code or ASME Section III, either in its entirety or portions thereof, can also be used. If repair welding can not be performed in accordance with these requirements, then Article 4000 of Reference 11 will be used.

As indicated in Rochester Gas and Electric's report, Reference 4, and Augmented Inservice Inspection Program for high energy piping outside of containment has been es-tablished. The inspection program provides for volumetric examination on all circumferential butt welds situated at design break locations or at discontinuity locations where probable failure could occur. Surveillance of these welds

40 OOC TITLE: DATE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Xnspection Program PAGE GINNA STATION For the 1980-1989 Interval 3 OF 21 can detect material changes in advance of a potential failure, thereby assuring that the design basis or consequential main steam or feedwater break will not occur.

The Inservice Inspection Program for steam generator tubes was developed to meet the guidance of Reference 5. At regular intervals, tubes within each leg of the steam generator are examined and evaluated for acceptable tube wall thickness.

The Inservice Inspection Program for reactor coolant pump flywheels was developed to meet the guidance of Reference 12.

At the intervals suggested, the reactor coolant pump flywheel will be examined by either the volumetric or surface exami-nation method, and evaluated to the specified acceptance criteria.

Identification is given in Section 9.0 of Ginna's Inservice Inspection Program for those areas which deviate from the requirements of Reference 1. Where applicable, currently approved edition and addendas of Section XI will be utilized for clarification and guidance. It is the intent of Rochester Gas and Electric Corporation to continually apply appropriate changes in the Code which improves the overall quality of Gihna's total Inservice Inspection Program.

PROGRAM ISI 1. 0 Sco e and Res onsibilit 1.1 Components of Quality Groups A and B are listed in Tables ISI-l.l and 1.2, respectively. Quality Group C components are identified in Appendix A of Ginna's Quality Assurance Manual. The specific components to be examined for each Quality Group shall be defined in the Examination Plans by title and/or number.

1.2 The Xnservice Xnspection Program for high energy piping outside of containment consists of main steam and feedwater piping welds is detailed in the Examination Plan for High Energy Piping.

L 40 OOC TITLE DATE QUALITY ASSURANCE APPENDIX B January 1, 1980 MANUAL Ginna Station Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 4 OF 21 1.3 The Xnservice Inspection Program for steam generator tubes, which is outlined in this pro-gram, was developed to the guidance provided in Reference 5, is detailed in Ginna's station procedures.

1.4 The Xnservice Inspection Program for reactor

'coolant pump flywheels, which is outlined in this program, was developed to the guidance pro-vided in Reference 12, is detailed in Ginna's station procedures.

ISI 2. 0 Ins ection Intervals 2.1 The inservice inspection (ISI) intervals for Quality Group A components shall be ten year intervals of service commencing January 1, 1970.

This program defines the ISX requirements for the second interval for Quality Group A components.

The ten year examination plan shall describe the distribution of examinations within the inspection interval in accordance with IWB-2400 of Reference 1.

'.2 The inservice inspection intervals for Quality Group B components shall be ten year intervals of service commencing on January'1, 1970. This program defines the ISI requirements for the second interval for Quality Group B components.

The ten year examination plan shall describe the distribution of examinations within the inspection interval in accordance with IWC-2400 of Reference 1.

2.3 The inservice inspection intervals for Quality Group C components shall be ten year intervals of service commencing on January 1, 1970. This program defines the ISI requirements for the second interval Quality Group C components.

The ten year examination plan shall describe the distribution of examinations within the inspection interval in accordance with IWD-2400 of Reference 1.

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0 DATE TITLE: APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL nservice Inspection Program GINNA STATION For the 1980-1989 Interval 5 OF 21 2.4 The inservice inspection intervals for the high energy piping outside of containment shall be ten year intervals of service commencing May 1, 1973.

The;ten year examination plan shall describe the distribution of examinations within the inspection interval in accordance with the requirements of Reference 4. S 2.5 The inservice inspection intervals for the exami-nation of steam generator tubes shall not be more than 24 months. However, if over a nominal 2 year period (e.g., two normal fuel cycles) at least 2 examinations of the separate legs result in less than 10% of the tubes with detectable wall penetration (0 20%) and no signifcant (P 10%)

further penetration of tubes with previous indi-cations, the inspection interval of the individual legs may be extended to once every 40 months.

2.6 As permitted by IWA-2400 of Reference 1, the inservice inspection interval for Quality Groups A, B and C and high energy piping outside con-tainment may be extended as necessary.

2.7 The inservice inspection intervals for the reactor coolant pump flywheel shall be approximately 10 year intervals of service commencing on January 1, 1970. For areas of high stress concentration at.

the bore and keyway, a reduced interval of approxi-mately 3 years shall be applied. The ten year examination plan shall describe the distribution of examinations within the inspection interval in accordance with the requirements of Reference 12.

ISI 3.0 Extent and Fre uenc 3.1 Quality Group A components, as listed in Table ISI-1.1 shall be examined to the extent and

'frequency as required in Tabl,e IWB-2500 of Refer-ence 1.

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TITLE OATE APPENDIX B January 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION ~. For the 1980-1989 Interval 6 OF 21 3.2 Quality Group B components, as 'listed in Table ISI-1.2, shall be examined to the extent and frequency as required in Table IWC-2500 of Reference 1.

3.3 Quality Group C components as described in 'the ten year examination plan shall be examined to the extent and frequency required in IWD-2400 and IWD-2600 of Reference 1.

3.4 High energy piping welds outside of containment shall be examined to the following extent and frequency:

3.4.1 During each period of the first inspection inter-val, all welds at design break locations and one-third of all welds at locations where a weld failure would result in unacceptable consequences, will be volumetrically examined.

3.4.2 During each period of succeeding intervals, one-third of all welds at design break locations and

...one-third of all welds at locations where a weld failure would result in unacceptable consequences, shall be volumetrically examined.

3.5 The extent and selection of steam generator tube examinations shall be as described in Sections C.4 and C.5 of Reference 1, with the interpretation that examination of all previously defective tubes

( > 20% detectable wall penetration) and up tp a

'4maximum of two hundred previously defect-free tubes 20% detectable wall penetration) is deemed sufficient in meeting the requirements of Refer-

ence 5.

3.5.1 In..the event a primary to secondary leak exceeds technical specification limits, a limited number of tubes shall be examined at the next refueling outage.

3.5.2 In the event of a seismic occurance greater than that for which the plant is designed to continue operation, Reference 6, a special examination of a limited number of tubes shall be conducted.

1 49 90C DATE TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 7 21 OF

3. 5. 3" In the event of a major steam line or feedwater line break, or a loss-of-cool'ant'ccident (LOCA) which imposes a significant pressure transient on the steam generators and requires actuation of the engineered safe-guards, a special exami-nation of a limited number of tubes shall be conducted.

3.6 The reactor coolant pump flywheel, listed in Table ISI-1.1, shall be examined to the extent and frequency as required in Reference 12.

XSI 4.0 Examination Methods 4.1 Quality Groups A and B components shall be examined by the required visual, surface or volumetric methods. These examinations shall include one or a combination of the following:

visual, liquid penetrant, magnetic particle, ultrasonic, eddy-current or radiographic exami-nation. These methods, shall as a minimum, be in accordance with the rules of IWA-2000 of Reference 1.

4. 1..1 Ultrasonic examinations shall be performed in accordance with the following:

4.1.1.1 '-For ferritic vessels with wall thickness of 2-1/2 inches or greater, an ultrasonic examination shall be conducted in accordance with the rules of Appendix I of Reference 1.

4.1.1.2 'For ferritic piping systems, an, ultrasonic exami-nation shall be conducted in accordance with the rules of Appendix IXX of Reference 7.

4.1.1.3 For components other than those 'listed in 4.1.1.1 and 4.1.1.2, an ultrasonic examination shall be conducted in accordance with, the rules of Article 5 of Reference 8.

4.1.1.4 All indications which produce'. a response greater than 50% of the reference level shall be recorded.

rt TITLE APPENDIX' 'Fhnuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PACf 21 OF All indications which produce a response 7 100%

of the reference level shall be investigated to the extent that the operator can evaluate the shape, identity, and location of all such re-flectors in terms of the acceptance/rejection standards of IWA-3100 (b) of Reference 1. The.

length of reflectors shall be measured between points which give amplitudes equal to 100% of the reference level.

4.2 Quality Group C components shall be visually examined for leakage during a system pressure test.

4.3 High energy piping welds outside of containment shall be radiographically examined.

4 ' Steam generator tubes shall be examined by a volumetric method (e.g. eddy current) or al-ternative method which is acceptable.

4.5 Reactor coolant pump flywheels shall be examined by the required surface and volumetric methods, in accordance with the requirements of IWA-2200 of Reference 1.

ISI 5. 0 Evaluation of Examination Results 5.1 The evaluation of nondestructive examination results shall be in accordance with Article IWB-3000 of Reference 1. All reportable indications shall be subject to comparison with previous data to aid in its characterization and in deter-mining its origin.

5.2 Quality Group B Components

5. 2.1 The evaluation of nondestructive examination re-sults shall be in accordance with Article IWC-3000 of Reference 1. All reportable indications shall be subject to comparison with previous data to aid in its characterization and in determining its origin.

5.3 Quality Group C Components

49 QOC TITLE DATE APPENDIX B January 1, 1980 auaLITY AssuRaNGE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 9 OF 21 5.3.1 The evaluation of the visual examination results shall be in accordance with Article IWA-5000 of Reference 1.

5.4 High Energy Piping 5.4.1 The evaluation of nondestructive examination results shall be in accordance with Reference 9.

5.5 Indications that were recorded in previous pre-service or inservice inspections and which were not characterized as propagating flaws are acceptable for continued service.

5.6 The evaluation of any corroded area shall be performed in accordance with Article IWA-5000 of Reference 11.

5.7 Steam Generator Tubes

5. 7.1 The evaluation of nondestruct'ive examination results shall be as follows:

5.7.1.1 Plant operation may resume when all tubes are within acceptable wall thickness criteria and the conditions of (a) or (b) are met:

(a) When less than 10 percent of previously defect-free tubes examined, (i.e.,g 20% of wall penetration) have developed detectable wall penetrations of greater than 20%, or (b) When previously degraded;tubes exhibit further wall penetration of+10%.

NOTE: An acceptable tube wall thickness is one which can sustain a LOCA in combination with a seismic occurrence, for which the plant is designed to continue operation, without a loss of function to Class 1 systems, Reference 8.

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TITLE APPENDIX B PAnuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAGANO 21 1

OF

5. 7.1.2 If no more than 3 tubes have unaccpetable wall thickness and the criteria of 5.7.1.1 is tube otherwise met, plant operation may resume after corrective measures have been taken. When the above criteria is not met, the situation shall be immediately reported to the Commission. Plant operation may resume after corrective measures are taken. All abnormal degradation to steam generator tubes shall be reported with a Licensee Event Report (LER) in accordance with technical specification requirements.

ISI 6.0 Re air Re uirements 6.1 Repair of Quality Groups A, B and C components shall be performed in accordance with the appli-cable Subsections of Reference 11.

6.2 Examinations associated with repairs or modifi-cations shall meet the applicable design and inspection Code requirements as described in the following paragraphs:

6.2.1 Whenever Quality Groups A, 'B or C System modifi-cations or repairs have been made which involve new strength welds on components greater than 2 inches diameter, the new welds shall receive both surface and 100 percent volumetric nondestructive examinations.

6.2.2 Whenever system modifications or repairs have been made which involve new strength welds on Quality Groups A, B or C components of 2 inches or less, a surface examination shall be performed.

6.3 Surface defects in Quality Groups A, B or C bolts, studs, nuts and ligaments may be removed by mechanical means provided the removal of that defect does not alter the basic configuration of the item. Bolts, studs and nuts that have de-fects that cannot be removed by mechanical means shall be replaced.

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TITLE APPENDIX B Sanuary 1, 1980 QUALITY ASSU RANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAG$

21 OF 6.4 Repair of .high energy piping welds outside of containment shall be performed in accordance with the applicable Code specified in Reference 11.

6.5 Repair of steam generator tubes that have un-acceptable defects shall be performed by using a tube plugging technique.

6.6 Repair of reactor coolant pump flywheel that have unacceptable defects shall be performed in accordance with Reference 12.

ISI 7. 0 S stem Pressure Testin 7.1 General Requirements 7.1.1 System pressure test shall be conducted in accordance with Article IWA-5000 of Reference 11.

7.1.2 Repairs of corroded areas shall be performed in accordance with Section 6.0 of this program.

7.2 Quality Group A Components 7.2.1 Whenever the reactor coolant system is closed after it has been opened, the system shall be leak tested to the requirements of Article IWB-5000 of Reference 11. Temperature and pressure requirements of Figure 3.1-1, Section 3.1 of Ginna's "Technical Specifications" shall not be exceeded.

7.2.2 At or near the end of each inspection interval, a hydrostatic pressure test shall be performed on the reactor coolant system components. This test shall be conducted in accordance with the require-ments of Article IWB-5000 of Reference 11. Test pressures and temperatures shall be maintained for at least four hours prior to performing the visual examination. Section 3.1 of Ginna's "Technical Specification" shall not be exceeded.

7.3 Quality Group B Components

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TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGf GINNA STATION For the 1980-1989 Interval 21 OF 7.3.1 At or near the end of each inspection interval, a hydrostatic pressure test shall be performed on Quality Group B Systems and Components. This test shall be conducted in accordance with the requirements of Article IWC-5000 of Reference 11.

When Quality Group A systems and components are also being pressurized, the pressure and temper-ature shall comply with the requirements of Paragraph 7.2.2 of this Appendix. This test temperature and pressure shall be maintained for at least 10 minutes prior to the performance of the visual examination.

7.4 Quality Group C Components 7.4.1 Quality Group C components shall have system pressure test in accordance with Article IWD-5000 of Reference 11.

ISI 8.0 Records and Re orts 8.1 Records and reports developed from those exami-nations performed in accordance with this Appendix shall be maintained in accordance with Article IWA-6000 of Reference 11.

ISI 9. 0 9.1 Quality Groups A, B and C components exemptions are identified in Attachment A to this Appendix.

However, Paragraphs IWB-1220 and IWC-1220 of Reference 1 exempt certain components from exami-nations, where certain conditions are met. These exemptions will be applied to the components listed on Tables ISI-1.1 and 1.2 with the result that only those non-exempt components are listed herein.

REFERENCES American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BEPVC)Section XI "Rules for Inservice Inspection of Nuclear Power Plant Components",

1974 Edition through Summer 1975 Addenda.

49 OOC TITLE APPENDIX B PSnuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAG$

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2. Code of Federal Regulations, Title 10, Part 50, dated January 1, 1978.

3. Nuclear Regulatory Commission, Regulatory Guide 1.26, Revision 1, dated February 1976 "Quality Group Classifi-cations and Standards for Water, Steam, and Radioactive Waste-Containing Components of Nuclear Power Plants".

4. Rochester Gas and Electric Corporation Report "Effects of Postulated Pipe Breaks Outside the Containment Building", dated October 29, 1973.

5. Nuclear Regulatory Commission, Regulatory Guide 1.83, Revision 1, dated July 1975, "Inservice Inspection of Pressurized Water Reactor Steam Generator Tubes".

6. Ginna's Final Safety Analysis Report, Section 2.9.3.

7. ASME, BGPVC,Section XI, 1974 Edition through Summer 1976 Addenda.

8. ASME, BGPVC, Section V, 1974 Edition through Summer 1975 Addenda.

9. USAS B31.1.0 1967, "Power Piping".

10. ASME, B&PVC, Section III, 1974 Edition through Summer 1975 Addenda.

ll. ASME, B6PVC Addenda.

Section XI, 1977 Edition through Summer 1978

12. Nuclear Regulatory Commission, Regulatory Guide 1.14, Revision 1, dated Auguset, 1975, "Reactor Coolant Pump Flywheel Integrity".

i TABLE ISI 1.1 QUALITY GROUP A D COMPONENTS, PARTS, AND METHODS OF EXAMINATION I

ZRH EXAMINATION +

-I c= ~

cn CATEGORY ~ + cnca ITEM TABLE COMPONENTS AND PARTS Zl O

No. IWB-2500 TO BE EXAMINED METHOD z zn Reactor Vessel B1.1 B-A , Longitudinal and circumferential shall welds in Volumetric core region. 0 m 5 8 I m

B1.2 B-B Longitudinal and circurmferential welds in shell Volumetric rt 4 W f"'

(other than those of Category B-A and B-C) and 0 8 Q meridional and circumferential beam welds in I bottom head and closure head (other than those 00 g of Category B-C). omI'0 5 w R we (AU B1.3 B-C Vessel-to-flange and head-to-flange circumferen- Volumetric WO cort jb N tial welds. 0 I" td MN 0 B1.4 B-D Primary nozzle-to-vessel welds and nozzle inside Volumetric rt %

tial welds. 8 8 Q

B1.5 B-E Vessel penetrations, including control rod drive Visual (IWA-5000) and instrumentation penetrations. 8 0

Bl.6 B-F Nozzle-to-safe-end welds. Volumetric and m Surface m

B6.10 BW-1 Closure head nuts. Surface O

B6.20 BW-1 Closure studs, in place. Volumetric B6.30 B-G-1 Closure studs, when removed. Volumetric and Surface

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TABLE IS I 1. 1 (Cont ')

COMPONENTS, PARTS, AND METHODS OF EXAMINATION D

cozen EXAMINATION CATEGORY Dye ITEM TABLE COMPONENTS AND PARTS +

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c- co ca No. IWB-2500 TO BE EXAMINED METHOD O

z z Reactor Vessel m B6. 40 B-G-1 Ligaments between stud holes. Volumetric H

B6.50 BW-1 Closure Washers, bushings. Visual 0 OI 5 III B7.10 B-G-2 Bolts, studs and nuts. Visual rI. <

wr-III 0 B8.10 B-H Integrally-welded attachments. Surface III A MH5 B1.15 B-N-1 Vessel Interior. Visual o<<II m X I '0 R I m<<aa B1 . 17 B-N-3 Core-support structures. Visual WO <<tH

<<ort NX LDI '<<t Bl.18 B-0 Control rod drive housings. Volumetric H5 0 0 I". t5 B1.19 B-F Exempted components. Visual (IWA-5000) <<t M III 8 8 0 Pressurizer R III 8

B2.1 B-B Longitudinal and circumferential welds. Volumetric 0 Nozzle-to-vessel welds III m B2.2 B-D and nozzle-to-vessel Volumetric radiused section.

B2.3 B-E Heater penetrations. Visual (IWA-5000)

B2.4 B-F Nozzle-to-safe-end welds. Volumetric and Surface

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TABLE ISI 1.1 (Cont'd)

COMPONENTS, PARTS, AND METHODS OF EXAMINATION D I

EXAMINATION RgH CATEGORY cn ~ 3o ITEM TABLE COMPONENTS AND PARTS ~~ cn No. IWB-2500 TO BE EXAMINED METHOD Pressurizer B6. 60 BW-1 Bolts and studs, in plae. Volumetric H

B6.70 BW-1 Bolts and studs, when removed. Volumetric and 0 m I Surface 8 8 m rl <

B6. 80 B-G-1 Bolting. Visual 9 0 IQ I I B8.20 B-H Integrally-welded attachments. Surface u CO g om0bs I ~

B2.10 B-P Exempted components. Visual (IVA-5000) &8 MO WO Cl H B7.20 B-G-2 Bolts, studs, and nuts. Visual OP txl H5 0 Heat Exchangers and Steam Generators rt  %

8 8 B3.1 B-B Longitudinal and circumferential welds, including Volumetric 8 0 Tube sheet-to-head or shell welds on the pri-mary side. 8 O

B3.2 B-D Nozzle-to-head welds and nozzle inside radiused Volumetric m rn section on the primary side.

C B3.3 B-F Nozzle-to-safe-end welds. Volumetric and 0 Surface Bolts and studs, in place. Volumetric

A TABLE ISI 1.1 (Cont'd)

COMPONENTS, PARTS, AND METHODS OF EXAMINATION D

EXAMINATION zz+ I CATEGORY CO +

< Pcn ITEM TABLE COMPONENTS AND PARTS +

~ ~ caC No. IWB-2500 TO BE EXAMINED METHOD Q

z zCl Heat Exchangers and Steam Generators m

B6.100 B-G-1 Bolts and studs, when removed. Volumetric and Surface Izj Q M B6. 110 BW-1 Bolting. Visual 8 8 rt 4 Wl B8.30, B-H Integrally-welded attachments. Surface 8 0 B8.40 S A I

IDHQ 0 CO P B3.9 B-P Exempted components. Visual (IWA-5000) otngR I '6

&8 VJU MQClH B7.30, B-G-2 Bolts, studs, and nuts. Visual mctfu X B7.40 C) l rt OP tXI MP 0 Piping Pressure Boundary 8 8 B4.1 B-F Safe-end to piping welds and safe-end in branch Volumetric and 8 0 piping welds. Surface 8

B6. 150 BW-1 Bolts and studs, in place. Volumetric B6.160 BW-1 Bolts and studs, when removed. Volumetric and Surface B6.170 BW-1 Bolting. Visual B4.5 Circumferential and longitudinal pipe welds. Volumetric

II TABLE ISI 1.1 (Cont'd)

COMPONENTS, PARTS, AND METHODS OF EXAMINATION D

l EXAMINATION CATEGORY ITEM No.

TABLE IWB-2500 COMPONENTS AND PARTS ~+M g l- C TO BE EXAMINED METHOD O

z z Piping Pressure Boundary m B4.6 B-J Branch pipe connection welds exceeding six inch Volumetric diameter. H 0 M I B4.7 B-J Branch pipe connection welds six inch diameter Surface 8 8 m and smaller.

8 0 B4.8 B-J Socket welds. Surface 8 Q MH5 B10. 10 B-K-1 Integrally welded attachments. Surface le 5 5 'u c) N Ql X I '0 BW-2 I SMO B11.10 Component supports. Visual WQ AH le ri. Q X B-P

'LDf 0

'ft td B4.11 Exempted components. Visual (IWA-5000) I ~

H5 0 B7.50 BW-2 Bolts, studs and nuts. Visual rt N 8 8 0

Pump Pressure Boundary 8

B6.180 B-G-1 Bolts and studs, in place. Volumetric B6.190 B-G-1 Bolts and studs, when removed. Volumetric and Surface B6.200 B-G-1 Bolting. Visual O B10.20 B-K-1 Integrally-welded attachments. Surface B11.20 B-K-2 Component supports. Visual

TABLE ISI 1.1 (Cont'd)

COMPONENTS, PARTS, AND METHODS OF EXAMINATION EXAMINATION C CATEGORY Z C cn ITEM TABLE COMPONENTS AND PARTS + cnC No. IWB-2500 TO BE EXAMINED METHOD Pump Pressure Boundary m B5. 6 B-L-1 Pump casing welds. Volumetric H

B5.8 B-P Exempted components. Visual 0OI g g Q m B7.60 BW-2 Bolts, studs, and nuts. Visual rt 4 III 0 Reactor Coolant Pump Flywheel. Volumetric and 8 Q I P P Surface MH5 tD N Ql ITI Valve Pressure Boundary I '0 I 8MU WO ftH B6.210 BW-1 Bolts and studs, in place. Volumetric mrtP R m I ~

rt 0 I" W BW-1 Bolts HN 0 B6.220 and studs, when removed. Volumetric and Surface-8 0 B6.230 BW-1 Bolting. Visual M III 8

B10.30 B-K-1 Integrally welded attachments. Volumetric 0 Al B11.30 B-K-2 Component supports. Visual C

B6.6 B-M-1 Valve-body welds. Volumetric 0

B6.8 B-P Exempted components. Visual (IMA-5000)

B7.70 BW-2 Bolts, studs, and nuts. Visual

TABLE ISI 1.2 QUALITY GROUP B D COMPONENTS, PARTS, AND METHODS OF EXAMINATION I

EXAMINATION CO a CATEGORY ITEM TABLE COMPONENTS AND PARTS al C)

No. IWC-2520 TO BE EXAMINED METHOD O~

m Pressure Vessels C1.1 C-A Circumferential butt welds. Volumetric ~ rJ 0 m C1.2 C-B Nozzle-to-vessle welds. Volumetric 8 8 C3.10 C-C Integrally-welded support attachments. Surface Kf 8 0 8 A k k" C4.10 C-D Bolts and studs. Volumetric loHN '0 CO P CON Ql td C3. 20 C-E Component supports. Visual I '0 vS MU lOO rtH Ct C3.30 C-E Supports mechanical and hydraulic. Visual CO LO I Ql

'Ct 0 I.td HP 0 Piping X3 a 8 8 C2.1 C-F, C-G Circumferential butt welds. Volumetric gF-8.0 IF C2.2 C-F, C-G Longitudinal weld joints in fittings. Volumetric vm 8

O C2.3 C-F, CW Branch pipe-to-pipe weld joints. Volumetric Q Ill C4.20 C-D Bolts and studs. Volumetric C m

C3. 40 C-E-1 Integrally welded support attachments. Surface C3.50 C-E-2 Component supports. Visual C3.60 Supports mechanical and hyraulic. Visual

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TABLE ISI 1.2 (Cont'd)

COMPONENTS, PARTS, AND METHODS OF EXAMINATION D EXAMINATION Zg CATEGORY CO +

ITEM TABLE COMPONENTS AND PARTS ~2 No. IWC-2520 TO BE EXAMINED METHOD ID Pumps m C3. 1 C-F, C-G Pump casing welds. Volumetric C4.30 C-D Bolts and studs. Volumetric Q M 8 8 C3. 20 C-E-1 Integrally welded support attachments. Surface rt <

8 0 C3. 80 C-E-2 Component supports. Visual 8 Q

'Q H

'u oI '6Qm CO C3. 90 Supports mechanical and hydraulic. Visual R

I 6 MU Valves M 0 rt H CO pt LOf' rt C4.1 C-F, CW Valve body welds. Volumetric I.W H0 0 C4. 40 " C-D Bolts and studs. Volumetric 8 8 Q

C3. 100 '-E-1 ~ 1F Integrally welded support attachments. - Surface 8

C3.110 C-E-2 Component supports. Visual 0

~2 N rn C3.120 Supports mechanical and hydraulic. Visual C 0

t 4Q IIOA SECT. NO. REV.

QUALITY ASSU CE MANUAL EFFECTIVE DATE January 1, 1980 ROCHESTER GAS 6 ELECTRIC CORPORATXON SIGNATIIRE GINNA STATION PREPARED BY Yio/~T TITLE Appendix B Ginna Station REVIEWED BY Inservice Inspection Program For the 1980-1989 Interval 7/~ W Exem tion I

1. IDENTIFICATXON OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The Quality Group C components of the service water system provide the heat sink to various turbine and reactor auxiliary building components including various safety related heat ex-changers. The service water system operates in all modes of reactor operation including cold shutdown and refueling.

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition requires that the system be subjected to a visual examination under system operating conditions every three and one-third years and a system hydrostatic test at 1.1 times the system design pressure each ten year interval.

Rochester Gas and Electric believes that the hydrostatic test requirement. for 'the service water system is impractical due to system design and therefore request for relief from this requirement is sought.

2. BASIS FOR RELIEF The design of the system dictates the use of an open-ended well-pit pump, whose suction cannot be blanked off to permit a full system pressure test. The portion of the system down-stream of the heat exchanger is also open-ended and cannot be hydrostatically tested. The remaining section of the system is only isolatable by means of butterfly valves which were not designed to provide a leaktight boundary. With the system as such it would be impractical to expect that, leakages other than at the valves could be detected.

t t t P'

TITLE APPENDIX B Sknuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAP GINNA STATION For the 1980-1989 Interval 18 Attachment, A Exemptions OF The ample margin in cooling capacity inherently provided by system design does not dictate the need for an essentially leaktight boundary. Since the system is in constant operation, its integrity is continually monitored. Thorough inspection of the system each period at the full operating pressure is adequate to detect any gross failures in the"system without degrading system safety or availability.

3. ALTERNATIVE PROVISIONS No alternate or augmented examinations or tests are necessary in this case.

Exem tion II

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENT The rules of Article 5 of Section V recommended that UT indi-cations which produce a response greater than 20% of the ref-erence level be investigated to the extent that the operator can evaluate the shape, identity, and location of all such reflectors in terms of the acceptance/rejection standards of Section XI.

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda requires that the pro-visions of Article 5 of Section V shall apply Appendix I or III of Section XI are applicable.

if neither However, in the 1977 Edition of Section XI, Summer 1978 Addenda, the rules of Article 5 of Section V were amended to only require investigation of UT indication which produce a response greater than 100% of reference level.

Rochester Gas 6 Electric concurs with the requirements of the later Code and Addenda and therefore, a request for relief from the earlier requirement is sought.

2. BASIS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements of IWA-2232 of Section XI of the 1977 Edition of Section XI, through the Summer 1978 Addenda. This is done pursuant to

l 49 90C TITLE APPENDIX B 5knuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAGf 18 Attachment A Exemptions OF 10CFR50,55a, Paragraph (g)(4)(iv), which says "Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met."

Adopting the evaluation criterion of 100% of reference level is acceptable because:

a) Indication of this level found during examinations have been sufficiently reliable to detect flaws.

b) Rochester Gas & Electric has committed to record all indication greater than 50% of reference level, thereby establishing a permanent history which can be subsequently examined.

c) Rochester Gas 6 Electric's inspection history at Ginna has shown that the level of "noise" or "hash" in the UT response from examinations on Quality Groups A and B systems has typically been 20%-30%

and 20%-40% of reference level, respectively.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exem tion III

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The reactor vessel and associated closure head are cladded with stainless steel on the interior surfaces. Six patches each having a 36 square inch area were selected for exami-nation in accessible locations of the reactor vessel shell and closure head. The pressurizer and steam generators also require a 36 square inch area to be accessible for examination.

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through the Summer 1975 Addenda requires that the clad patches in the reactor vessel, pressurizer and steam generators be visually examined each interval. In addition, the closure head patches require visual plus a surface or

TITLE APPENDIX B Sanuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAG3 18 Attachment A Exemptions OF volumetric examination each interval. In the 1977 Edition of Section XI, Summer 1978 Addenda, the ASME Code had com-pletely eliminated the examination categories B-I-1 and B-I-2.

Rochester Gas and Electric believes the earlier examinations are impractical since it offers no real means of checking pressure vessel integrity. Therefore, a request for relief from the earlier requirement is sought.

2. BASXS FOR RELXEF Analysis has shown that flaws which initiate in the pressure vessel cladding, at locations other than nozzles, do not propagate through the clad-base metal interface. Therefore, their existence does not pose a threat to pressure vessel integrity. The nozzle inner radii areas will be volumetrically examined to detect the presence of flaws which may have propa-gated into the base material.

Performing these examinations only constitutes a needless exposure of personnel to radiation with no compensatory in-crease in safety. Rochester Gas 6 Electric therefore, will not perform the above mentioned examinations in the remaining inspection intervals.

3. ALTERNATXVE PROVISIONS

,No alternate or augmented examinations are necessary in this case.

Exem tion IV

1. IDENTIFICATION OF COMPONENTS AND IMPRACT1CAL CODE REQUIREMENTS This relief request addresses the Section XI examination categories concerning pressure retaining bolting, that is, B-G-1 and B-G-2. Category B-G-1 in the 1974 Edition of Section XI, Summer 1975 Addenda covers bolting two-inches in diameter and greater and category B-G-2 covers bolting less than two-inches in diameter. However, in the 1977 Edition of Section XI, Summer 1978 Addenda, the bolting exactly two-inches in diameter is shifted from category B-G-1 to B-G-2 by revision of the category definition.

TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Xnservice Inspection Program FAG)

GINNA STATION For the 1980-1989 Interval 18 Attachment A Exemptions OF Rochester Gas 6 Electric concurs with the category definition of the later Code and Addenda and therefore, a request for relief from the earlier requirement is sought.

2. BASXS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements of Section XI of the 1977 Edition of Section XI through the Summer 1978 Addenda for examination categories B-G-1 and B-G-2. This is done pursuant, to 10CFR50.55a Paragraph (g)

(4)(iv) which says "Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met."

Adoption of cludes only this a

exemption has a minimal impact, since it small percentage of the Quality Group A bolting in-and will in no way effect plant safety margins.

3. ALTERNATXVE PROVISIONS

~

No alternative or augmented examinations are necessary in this case.

Exem tion V

1. XDENTXFXCATION OF COMPONENTS AND XMPRACTICAL CODE REQUXREMENTS The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda requires that pressure retaining components within each system boundary be visually examined while subjected to system pressure tests. These test requirements are not only an important part of the inservice inspection, but also demand clarity in their appli-cation.

Rochester Gas & Electric feels the earlier hydrostatic test requirements are not as definitive as the later Edition and Addenda of Section XI, and for this reason believes misinter-pretation and/or misapplication could occur. Request for relief from the earlier requirement is therefore sought.

TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAG$

18 Attachment A Exemptions OF

2. BASIS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements of Article-5000 of Section XI, 1977 Edition through Summer 1978 Addenda. This is done pursuant to 10CFR50.55a, Paragraph (g)(4)(iv) which says, "Portions of editions or addenda may be used provided that all related requirements of the res-pective editions or addenda are met." By adopting the more current rules, Ginna's inservice inspection program invokes a greater margin of safety by applying a clear and definitive Code.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exem tion VI

1. IDENTIFICAT10N OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS Ginna has three Quality Group A valves which will require a visual examination of their internals. These valves are in the safety injection system and the residual heat removal system.

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through the Summer 1975 Addenda requires that valves exceeding four-inches in diameter be examined visually during each inspection interval. Specifically, the area of exami-nation includes valve internal pressure boundary surfaces.

Rochester Gas S Electric, believes that this visual exami-nation adds little or no value to the overall safety of the plant and subjects plant personnel to unnecessary radiation exposure. Therefore, a request for relief from this require-ment is sought.

2. BASIS FOR RELIEF This basis for relief request is founded on the following two points:

C TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAG$

18 Attachment A Exemptions OF

1) to complete the subject examination, unnecessary expenditures of man-hours and man-rem are required.

with essentially no compensating increase in plant safety, and

2) the structural integrity afforded by valve casing material utilized will not significantly degrade over the lifetime of the valve.

Based on data compiled from a plant similar in age and design to Ginna, it is expected that approximately 100 man-hours and 5 man-rem exposure would be required to disassemble, inspect, and reassemble these valves. Performing this visual exami-nation under such adverse conditions, high dose rates (30-40 R/hr), and poor as-cast surface conditions, realistically pro-vides little additional information as to the valve's casing integrity.

The valves material, a high strength cast stainless steel (ASTM A351-CF8), is widely used in the nuclear industry and has performed extremely well. The presence of some delta ferrite (typically 5% or more) substantially increases re-sistance to intergranular stress corrosion cracking. The delta ferrite also. helps the material to resist pitting corrosion in chloride containing environments.

Rochester Gas 6 Electric feels that adequate safety margins are inherent in the basic valve design and that the public's health and safety will not be adversely effected by not per-forming a visual examination of the valve internal pressure boundary surfaces.

3. 'LTERNATIVE PROVISIONS As stated above, Rochester Gas 6 Electric does not believe that the visual examination required each ten year interval is warranted. However, as standard maintenance practice dictates, when these valves are disassembled for maintenance purposes, a visually examination of the internals and internal pressure boundary surfaces will be performed, to the extent practical.

I J

s 40 OOC TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAG$

18 Attachment A Exemptions OF Exem tion VII

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS In each of the two 27.5 inch inside diameter recirculation loops, Ginna has a Quality Group A reactor coolant pump. The function of these two pumps is to provide forced circulation through the core during normal reactor operation.

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through the Summer 1975 Addenda requires that one of these recirculation pumps be examined visually during each inspection interval. Specifically, the area of examination includes all pump internal pressure boundary surfaces.

Rochester Gas 6 Electric believes that this visual exami-nation adds little or no increase to the overall safety of the plant and subjects plant personnel to unnecessary radi-ation exposure. Therefore, a request for relief from this requirement is sought.

2. BASIS FOR RELIEF The basis for this relief request is founded on the following two points:

1) to complete the subject examination, large expendi-tures of man-hours and man-rem are required with essentially no compensating increase in plant safety, and

2) the structural integrity afforded by pump casing material utilized will not significantly degrade over the lifetime of the pump.

Based on the data compiled from a plant similar in age and design to Ginna, it is expected that approximately 1000 man-hours and 50 man-rem exposures would be required to dis-assemble, inspect, and reassemble one pump. Performing this Visual examination under such adverse conditions, high dose rates (30-40 R/hr), and poor as-cast surface condition, realistically provides little additional information as to the pump's casing integrity.

0 TITLE APPEND IX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program

,GINNA STATION For the 1980-1989 Interval PAG$

18 Attachment A Exemptions OF The reactor coolant pump casing material, a high strength cast stainless steel (ASTM A351-CF8), is widely used in the nuclear industry and has performed extremely well. The presence of some delta ferrite (typically 5% or more) sub-stantially increases resistance to intergranular stress corrosion cracking. The delta ferrite also helps this material resist pitting corrosion in chloride containing environments.

Rochester Gas 6 Electric feels that adequate safety margins are inherent in the basic pump design and that the public's health and safety will not be adversely effected by not per-forming a visual examination of the pump internal pressure boundary surfaces.

3. ALTERNATIVE PROVISIONS As stated above, Rochester Gas 6 Electric does not believe that the visual examination required each ten year interval is warranted. However, as standard maintenance practice dictates, when a pump of this type is disassembled for main-tenance purposes a visual examination of the pump internals and internal pressure boundary surfaces will be performed, to the extent practical.

Exem tion VIXI

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda, Categories C-C and C-E requires a surface examination be performed on 100% of the vessel supports and 10% of the supports for piping, pumps, and valves. Xn the 1977 Edition of Section XI, Summer 1978 Addenda, the Code requires 100% of the required areas for each support attachment be examined.

Rochester Gas 6 Electric believes that the later Edition and Addendas of Section XI provides more assurance of the over- .

all structural integrity of Ginna's Quality Group B systems.

Therefore, a request for relief from the earlier requirement is sought.

TITLE DAZE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 10 18 Attachment A Exemptions OF

2. BASIS FOR RELIEF Rochester Gas It'lectric will be adopting the requirements of Categories C-C and C-E of Section XI, 1977 Edition through Summer 1978 Addenda. This is done pursuant to 10CFRS0.55a, Paragraph (g)(4)(iv) which says, "Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met." By adopting the more current rules, Ginna's inservice inspection program provides greater assurance for-system integrity.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exem tion IX

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda requires that repairs be made either to ASME Section XI or the Code applicable to the construction of the component. However, in the 1977 Edition of Section XI, Summer 1978 Addenda, the Code allows the user to apply later Edition of the Construction Code or ASME Section III, either in its entirety or portions thereof.

Rochester Gas 6 Electric feels the earlier repair rules are not as definitive nor adaptable as the later Edition and Addenda of Section XI, and believes. that by adapting the later repair rules Ginna's system can be assured of greater integrity. Therefore, a request for relief from the earlier requirement is sought.

2. BASIS FOR RELIEF Rochester Gas S Electric will be adopting the requirements of Article-4000 of Section XI, 1977 Edition through Summer 1978 Addenda. This is done pursuant to 10CFR50.55a, Paragraph (g)

(4)(iv) which says, "Portions of editions or addenda may be used provided that all related requirements of the respective

g J 40 OOC TITLE DATE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 11 18 Attachment A Exemptions OF editions or addenda are met." By adopting the more current rules, Ginna's inservice inspection program invokes a more definitive and adaptable repair program thereby ensuring greater integrity to safety related systems.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exem tion X

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code,Section XI 1974 Edition through Summer 1975 Addenda Category C-D requires that 10% of the pressure retaining bolting exceeding one inch in diameter be nondestructively examined. In the 1977 Edition of Section XI, Summer 1978 Addenda, the Code re-quires that 100% of the pressure retaining bolting exceeding two inches in diameter be nondestructively examined.

Rochester Gas 6 Electric believes that the later Edition and Addendas of Section XI provides more assurance of the overall structural integrity of Ginna's Quality Group B systems.

Therefore, a request for relief from the earlier requirement is sought.

2. BASIS FOR REL1EF Rochester Gas S Electric will be adopting the requirements of Category C-D of Section XI, 1977 Edition through Summer 1978 Addenda. This is done pursuant to 10CFR50.55a, Paragraph (g)

(4)(iv) which says, "Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met." By adopting the more current rules, Ginna's inservice inspection program provides greater assurance for system integrity.

49 QOC TITLE APPENDIX B V8nuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program GINNA STATION For the 1980-1989 Interval PAGf 2 18 Attachment A Exemptions OF

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exem tion XI

1. IDENTIFICATION OF COMPONENTS AND IMRPACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code,Section XI 1974 Edition through Summer 1975 Addenda, Category B-K-1 requires that 25% of weld length of the integrally welded external supports be volumetrically examined. In the 1977 Edition of Section XI, Summer 1978 Addenda, the Code requires that 100%

of weld length of the integrally welded external supports be examined.

Rochester Gas 6 Electric believes that the later Edition and Addendas of Section XI provides more assurance of the overall structural integrity of Ginna's Quality Group A systems.

Therefore, a request for relief from the earlier require-ment is sought.

2. BASIS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements of Category B-K-1 of Section XI, 1977 Edition through Summer 1978 Addenda. This is done pursuant to 10CFR50.55a, Paragraph (g)

(4) (iv) which says, "Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met." By adopting these more current rules, Ginna's inservice inspection program provides greater assurance for system integrity.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

DAZE TITLE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program '"'13 G INNA STATION For the 1980-1989 Interval 18 Attachment A Exemptions OF Exem tion XII

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda requires that arrange-ments be made with an Authorized Inspection Agency to provide inspection services. In addition, the Code requires that certain administrative functions be performed by the "En-forcement Authority" and "Authorized Inspector".

Rochester Gas 6 Electric's Ginna Nuclear Generating Plant is located in the state of New York. This state has not endorsed ASME Codes and therefore does not provide adminis-trative organization and controls such as "Enforcement Authority", "Authorized Inspector" and "Reporting Systems".

However, Ginna Station's Quality Assurance Program does pro-vide for these administrative control requirements. There-fore, Rochester Gas It'lectric request that, Ginna's Station Quality Assurance Program be used in lieu of Code adminis-trative functions.

2. BASIS FOR RELIEF Rochester Gas 6 Electric's program for the inservice in-spection, governed by the R. E. Ginna Station Quality As-surance Manual, contains the requirements and responsibilities for implementation of the program and procedures. The pro-cedures have been prepared and approved .by the responsible organizations within Rochester Gas 6 Electric, (i.e., Ginna Station, Engineering, General Maintenance, Electric Meter and Laboratory and Purchasing).

Approved procedures 'will be implemented to control the standards for examination evaluation. These procedures in-clude the identifications of the organization performing the inspection, description of the method of inspection to be used, acceptance and rejection criteria, and requirements for providing evidence of completion and certification of the inspection activity.

TITI.E DATE APPENDIX B january 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 14 18 Attachment A Exemptions OF In addition, procedures are developed by Ginna Station to prescribe the disposition of nonconformances. The procedures implemented for the repairs, the retest procedures and the test results will be reviewed by the Plant Operating Review Committee. The members of this committee include technically qualified staff personnel.

Examination techniques have been established in accordance with written requirements and incorporated into written pro-cedures. Qualifications for nondestructive test personnel are in compliance with Regulatory Guide 1.58 "Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel".

Records and reports of the inservice inspection will be developed and maintained by Rochester Gas & Electric and in-clude such items as examination plans and schedules, exami-nation 'of results and corrective actions.

The functions of the ASME authorized inspector, namely their reviews and verifications, will be performed by personnel of the Hartford -Steam Boiler Inspection and Insurance Company.

The qualifications of the inspectors, inspections specialists and inspection agency are in compliance with the Code.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are required in this case.

Exem tion XIII

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda, Article-6000 stipulates rules for records and reports of Class 1, 2 and 3 components of nuclear power plants. These rules have subsequently been revised to add clarity and guidance to the Code.

40 OOC TITLE DATE APPENDIX B january 1, 1980 QUALITY ASS U RAN C E Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 15 18 Attachment A Exemptions OF Rochester Gas & Electric feels the earlier rules of Article-6000 are not as definitive as the rules of the 1977 Edition through Summer 1978 Addenda. They believe that by adopting the later "Records and Reports" rules, Ginna's overall In-service Inspection Program can be of better quality. There-fore, a request for relief from the earlier requirement is sought.

2. BASIS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements of Article-6000 of Section XI, 1977 Edition through Summer 1978 Addenda. This is done pursuant to 10CFR50.55a, Paragraph (g)

(4) (iv) which says, "Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met." By adopting the more current rules, Ginna's inservice inspection program invokes more co-herent rules in maintaining examination and test data.

3. ALTERNATIVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exem tion XIV

1. IDENT IF ICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS A hold-up tank in the waste disposal system for Ginna provides a means of storing contaminated water which has been used in the operation of a nuclear power plant. The waste disposal system may be required to function in all modes of reactor operation including cold shutdown and refueling.

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda, requires that the system be subjected to a visual examination under system operating conditions every three and one-third years and a system hydro-static test at 1.1 times the sytem design pressure each ten year interval.

TITLE DATE APPENDIX B Sanuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 16 18 Attachment A Exemptions OF Rochester Gas & Electric believes that hydrostatically testing the rad-waste hold-up tanks puts Ginna's plant in an unsafe condition and therefore a request for relief from this requirement is sought.

2. BASIS FOR RELIEF The design of the waste disposal system is such that con-taminated water is stored in a. hold-up tank until such time that the level of contamination is below the limits for dis-charge. At this time the hold-up tanks may be reavailable for use by emptying the stored liquid.

Several important systems within the chemical volume and control system drain into the waste disposal system hold-up tanks. These are the volume and control tank drains, reactor coolant letdown system, reactor coolant drain tank discharge, and the demineralizer system drains.

If utility a was to hydrostatically test this tank by them with water, the hold-up tank would be rendered useless.

filling The plant would then be potentially put into an unsafe condition for any abnormal plant function and hold-up tanks being available.

if startup occurred without Since this hold-up tank constantly store liquid, any de-gradation of the tank material would show up prior to becoming a problem.

it

3. ALTERNATIVE PROVISIONS A visual examination shall be performed once every 3 1/3 years to verify continued structural integrity.

o~

P

DATE QUALITY ASSURANCE APPENDIX B January 1, 1980

.MANUAL Ginna Station GINNA STATION nservice Inspection Program PAGE For the 1980-1989 Interval 17 OF 18 Attachment A Exem tions Exem tion XV

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS This relief request addresses the Section XI examination categories B-A and B-D for the pressure retaining welds in the and reactor vessel including the nozzle to vessel welds.

Categories B-A and B-B of the 1974 Edition of Section XI, Summer 1975 Addenda requires only a partial examination of the pressure retaining welds in the reactor vessel. However, in the 1977 Edition of Section XI, Summer 1978 Addenda, requires 100% of the weld to be inspected. Also, in the 1974 Edition of Section XI, Summer 1975 Addenda the nozzle to vessel weld category B-D are required to be inspected by dividing the inspection up over the interval which is impractical because only a nozzle bore examination can be performed on two nozzles out of four, the 1977~Edition of Section XI, Summer 1978 Addenda allows for the nozzle to vessel welds to be differed to the end of the inspection interval.

Rochester Gas and Electric concurs with the category requirements as defined of the later Code and Addenda and therefore, a request for relief from the earlier requirement is sought.

2. BASIS FOR RELIEF Rochester Gas and Electric will be adopting the require-ments of Section XI of the 1977 Edition of Section XI through the Summer 1978 Addenda for examination categories B-A and B-D. This is done pursuant to 10CFR 50.55a para-graph (g)(4)(iv) which says "portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

During the first inpection interval 100% of the reactor vessel welds including the nozzle to vessel welds were completed. This request is in keeping with the policy of performing 100% of all welds in the reactor vessel each inspection interval. As well as being a practical approach when examining the nozzle to vessel welds so that the required examinations from two directions may be performed at the same time.

49 90C TITLE APPENDIX B PKnuary 1, 1980 QUALITY ASSURANCE Ginna MANUAL Inspection Program Station'nservice GINNA STATION For the 1980-1989 Interval PAG$

18 Attachment A Exemptions OF Adoption of this exemption applies more current rules to Ginna's inservice inpection program providing greater assur-ance for system integrity.

3. ALTERNATIVE PROVISIONS No alternative or argumented examanination are necessary in this case.

)

a