ML17250B067
| ML17250B067 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/16/1989 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TAC-74099, NUDOCS 8911220062 | |
| Download: ML17250B067 (11) | |
Text
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- Docket No. 50-244 November 16, 1989 Dr. Robert C. Mecredy General
- Manager, Nuclear Production Rochester Gas 5 Electric Corporation 89 East Avenue Rochester, New York 14649
, Bear Dr. Mecredy:
SUBJECT:
R.E.
GINNA THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM - REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 74099)
The NRC with assistance from its contractor, Idaho National Engineering Laboratory
( INEL), is reviewing and evaluating the Third Ten-Year Interval Inservice Inspection (ISI) Program for the R.
E. Ginna Nuclear Power Station.
Additional information is needed for completion of our review and evaluation.
We request that the list of questions (Enclosure
- 1) be responded to within thirty days after receipt of this letter in order to meet the projected schedule for an approval of the Ginna ISI program.
We request you to identify and prioritize all relief requests by number, contained in your July 21, 1989 submittal, which may impact the May 1990 refueling outage.
We also request that copies of these types of transmittals to and from the NRC regarding the R.E.
Ginna Third Ten-Year Interval Inservice Inspection Program be forwarded to Mr. Boyd Brown of INEL to aid in expediting the review and evaluation.
Sincerely,
/s/
Allen Johnson, Project Manager Project Directorate I-3 Division of Reactors Projects I/II Office of Nuclear Reacto~ Regulation t
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Harry H. Voigt, Esquire
- LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire
- Avenue, N.W.
Suite 1100 1!ashington, D.C.
20036 Resident Inspector R.E.
Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road
- Ontario, New York 14519 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms.
Donna Ross Division of Policy Analysis 5 Planring New York State Energy Office Agency Buildina 2
Empire State Plaza
- Albany, New York 12223 Mr. Bruce A. Snow, Superintendent Nuclear Production Rochester Gas 5 Electric Corporation 89 Fast Avenue Rochester, New York 14649-0001 Charlie Donaldson, Esq.
Assistant Attorney Genera>
New York Department of Law 120 Broadway New York, New York 10271
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Docket No.
50-244 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE 1
R.
E.
GINNA THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM -
REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 74099) 1
~
Sco e Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2,
and Class 3 meet the requirements, except design and access provisions and 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 the components.
This section oF the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein.
The components
'(including supports) may meet requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein.
Based on the start date of January 1,
1990 for the third 10-year interval, the Inservice Inspection
( ISI) Program Plan has been prepared to meet the requirements of the 1986 Edition of the ASME Code Section XI.
As required by 10 CFR 50.55a(g)(5), if the Licensee determines that certain Code examination requirements are impractical and relief is
requested, the Licensee shall submit information to the Nuclear Regulatory Commission (NRC) to support that determination.
The staff has reviewed the available information in the R.
E. Ginna Nuclear Power Station Third 10-Year Interval ISI Program Plan, submitted July 21,
- 1989, and the requests for relief from the ASHE Code Section XI requirements which the Licensee has determined to be impractical.
2.
Additional Information Clarification Re uired Based on the above review, the staff has concluded that the following information and/or clarification is required in order to complete the review of the ISI Program and relief requests:
A.
Provide a list of the ultrasonic calibration standards being used during the third 10-year interval ISI at R.
E.
Ginna Station.
This list should include the calibration standard identifications, material specifications, and sizes.
B.
With regard to limitations due to metallurgical properties of cast stainless steel (SA351 Grade CFBA), the staff has continued to monitor the development of new or improved examination techniques.
As improvements in these areas are achieved, the staff is requiring that these new techniques be made part of the ISI examination procedures.
Discuss the ISI examination procedures for the ultrasonic examination of the R.
E.
Ginna Primary Coolant System
- and, in particular, the improved examination techniques which may have been incorporated.
C.
Relief Request Nos.
1 and 2:
Relief is requested to defer the volumetric examinations of the RPV shell-to-flange weld (Relief Request No.
1) and the RPV nozzle-to-vessel welds and nozzle inside radius sections (Relief Request No. 2) to the end of the inspection interval.
As stated in Table IWB-2500-1, Examination Category B-A, of Section XI of the Code, the examination of shell-to-flange welds may be performed during the first and third inspection periods in conJunction with the nozzle examinations of Examination Category B-D.
At least 50/ of shell-to-flange welds shall be examined by the end of the first inspection period, and the remainder by the end of the third inspection period.
If partial examinations are conducted from the flange face, the remaining volumetric examinations required to be conducted from the vessel wall may be performed at or near the end of each inspection interval.
As stated in Table IWB-2500-1, Examination Category B-D, of Section XI of the Code, at least 25/ but not more than 50/
(credited) of the nozzles shall be examined by the end of the first inspection period, and the remainder by the end of the inspection interval.
The Code states that it is not permissible to defer the examination of the RPY nozzle inside radius sections to the end of the inspection interval.
Inspections of the RPY nozzle-to-vessel welds may be partially deferred under the following conditions:
If examinations are conducted from inside the component and the nozzle weld is examined by straight beam ultrasonic method from the nozzle
- bore, the remaining examinations required to be conducted from the shell inside diameter may be performed at or near the end of each inspection interval.
It is proposed in these relief requests to perform the shell-to-flange examinations, both nozzle-to-vessel examinations (from the nozzle bore and from the shell inside diameter),
and the nozzle inside radius examinations at or near the end of the interval.
It is stated in Relief Request No. I that the required shell-to-flange examination is impractical if performed during the periods specified as it can only be accomplished from the flange surface.
It is stated in Relief Request No.
2 that examinations from the nozzle bore and the nozzle inside radius examinations can only be performed on two (outlets) of,the six major nozzles without removal of the core barrel.
It is further stated that the mechanized examination of the two accessible nozzle and inside radius sections is quite expensive, and the nozzle-to-vessel examination is only a partial examination from the nozzle bore.
The information provided in Relief Request Nos.
I and 2 is considered to be inadequate justification for the determination of impracticality because there are portions of these welds that are accessible for examination.
Inconvenience and the cost of a particular examination are not justifications for granting relief.
Please provide detailed technical information which demonstrates that the Code requirement is impractical based on reasons other than inconvenience and cost.
The staff has noted that other similar plants have not requested this relief.
D.
Relief Request No. 6:
Relief is requested from performing the Code-required hydrostatic test of the radioactive waste holdup tank in the waste disposal system.
It is stated in the relief request that the waste disposal system and waste holdup tank
~ma be required to function in all modes of reactor operation including cold shutdown and refueling.
Please provide specific discussion regarding the safety concern of performing the Code-required hydrostatic test during the refueling mode.
E.
Relief Request No. 9:
It is stated in the relief request that to maintain a pressure differential of 800 psig and the required pressure on the secondary
- side, the primary system must be heated up to a minimum of 160'F which would result in a problem with heat balance and a potential operational problem during implementation of the test procedure, It is further stated that the administrative controls necessary to assure a proper and safe test and the
complexity required for the test procedure result in a situation that should be minimized.
What is the technical impracticality of heating up the primary side of the Steam Generator to maintain the 800 psig differential and the Code-required test pressure on the secondary side?
F.
Relief Request No.
11:
Discuss the "full operational pressure" of the Boric Acid Filter and associated piping and the "safe working pressure" of the Boric Acid Filter housing flange gaskets versus the Code-required hydrostatic test prcssure'.
Relief Request No.
13:
Relief.is requested from performing the Code-required hydrostatic test of the non-ISI classified systems that contain lines penetrating primary containment and do not carry radioactive gases or fluids.
The Licensee proposes to test these lines jn accordance with 10 CFR 50 Appendix J, Reactor Containment Leakage Testing for Water Cooled Power Reactor commensurate with the safety function the line performs in accordance with Technical Specification surveillance requirements.
Additionally, at least once each period, exposed portions of the lines penetrating primary containment will be examined during normal system operation, The Licensee states that the safety function of these lines is to become peart of the containment isolation system during periods'when containment isolation is required; therefore, the pressure testing requirements should be based on the containment system design not the associated process system design requirements.
List the specific lines for which relief is requested and provide detailed technical justification, for each of the lines, which demonstrates the impracticality of performing the Code-required hydrostatic pressure test.
H.
Relief Request No.
15:
Section XI, Table IWC-2500-1, Examination Category C-F-1 (Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping) and Examination Category C-F-2 (Pressure Retaining Welds in Carbon or Low Alloy Steel Piping),
Items C5. 10 and C5.50, respectively, require both 100% volumetric, and surface examinations of Class 1 piping welds 3/8 inch or greater nominal wall thickness for piping greater than 4 inch nominal pipe size as defined by Figure IWC-2500-7.
The Licensee states
(< 3/8 inch nominal wall thickness) will be examined to the requirements of Table IWC-2500-1, Examination Categories C-F-1 and C-F-2, Items C5. 10 and C5.50, respectively.
These examinations are identified in the Class 2
Allocation Tables as Augmented Examinations and also are included under the Examination Categories C-F-1 and C-F-2 in the Program Plan Tables.
With the statements made in the relief request, it appears that the Code-requirements will be met and that augmented examinations will be performed.
If this is the case, Relief Request No.
15 is not required.
Please clarify the specific requirement from which relief is being requested.
If the Code requirement is not being met, provide detailed technical information to justify the determination of impracticality.
Also, confirm that the augmented welds are not included as part of the Code-required sampling.
I.
Relief Request No.
16:
Section XI, Table IWB-2500-1, Examination Category B-K-1, Item B10. 10 requires a
100% volumetric or surface examination, as applicable, of Class 1 piping integrally welded attachments as defined by Figures IWB-2500-13, -14, and -15.
Table IWC-2500-1, Examination Category C-C, Item C3.20 requires a
100% surface examination of Class 2 piping integrally welded attachments as defined by Figure IWC-2500-5.
V
~
It is stated in Relief Request No.
16 that surface examinations shall be performed on integral attachments on Class 1 and Class 2
piping once per interval in accordance with IWB-2500-1, Examination Category B-K-I, and IWC-2500-1, Examination Category C-C, respectively.
It is further stated that support attachments to the pressure boundary such as gussets and stanchions should have a
surface examination performed to ensure the safety and integrity of the Class 1
and Class 2 systems.
With the statements made in the relief request, it appears that the Code-required surface examination of 100% of the length of each attachment weld is being met and that, therefore, Relief Request No.
16 is not required.
Please provide clarification with regard to the specific Code requirement from which relief is being requested.
If the Code requirement is not being met, detailed technical information must be provided to justify the determination of impracticality.
The schedule for timely completion of this review requires that the Licensee
- provide, by the requested
- date, the above requested information and/or clarifications with regard to the R.
E.
Ginna Nuclear Power Station Third 10-Year Interval ISI Program Plan.