ML17255A576

Rev 0 to Inservice Insp Program for 1980 - 1989

ML17255A576
Person / Time
Site:	Ginna
Issue date:	06/30/1979
From:	Curtis A ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17255A573	List: ML17255A572 ML17255A575 ML17255A576
References
NUDOCS 8312280396
Download: ML17255A576 (29)

Text

A t44 QUALITY ASSURANCE NfLNUAL StISCTlYt DOT%

( ROCP~STER GAS 6 ELECTRIC CORPORATION January 1, 1980 GINNA STATION M'PNtD Cf Yzy~

TI7LE Appendix B HvltWlD SY Ginna Station 7P Inservice Inspection Program For the 1980-1989 Interval Att%0VtD lY:

Exemotion I

1. IDENTIFICATION 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.

I 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 ~ BAS ZS 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 hydzostatically tested. The remaining section of the system is only isolatable by means of butterfly valves which were no 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.

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• TfTLK APPENDIX B 5knuary 1, 1980 QUALITY. ASSV RANCE Ginna Station MANUAL nservice Inspection Program For the 1980-1989 Interval PA/ 18 6INNA STATION 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.

Exemption ZZ

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUZRZHENT The

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erence rules of Article of Section which produce level be 5

a response V recommended greater than that 20%,

investigated to the extent that, the operator UT indi-of the ref-can evaluate the shape, identity, and location of all such reflectors in terms of the acceptance/rejection standards of Section XI.

The ASHE Boiler and Pressure Vessel Code, Section XZ, 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 appli"able. However, if neither in the 1977 Edition of Section XZ, 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 & Electric will be adopting the requirements of IViA-2232 of Section XI of the 1977 Edition of Section XZ, through the Summer 1978 Addenda. This is done pursuant to

APPENDIX B 5knuary 1, 1980 QUALITY ASSURANCE Ginna Station

( MANUAL GINNA STATION nservice Inspection Program For the 1980-1989 Interval Attachment A - Exemptions PAGj CF 18 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 du ing examinations have been sufficiently reliable to detect flaws.

b) Rochester Gas 6 Electr'c has committed to record all indication greater than 50% of reference level, thereby establishing a permanent history which can

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be subsequently examined.

c) Rochester Gas & 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.

ExemTition IIZ

1. ZDENTZF ZCATION OF COMPONENTS AND IMPRACTZCAL 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 ex'amination.

I The ASME Boiler and Pressure Vessel Code, Section XZ, 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

TlTLF.: APPENDIX B Shnuary 1, 1980 QUAL)TY ASSURANCE Ginna Station MANUAL Inservice Inspection Prcgram GINNA STAT10N For the 1980-1989 Interval PAG) 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. BASIS FOR RELIEF 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.

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

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

Exemption IV I

1. IDENTIF ICATION OF COMPONENTS AND IMPRACTICAL CODE i REQU IP ~MENTS 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 exac ly two-inches in diameter is shifted from category B-G-1 to B-G-2 by revision of the category definition.

TITI.E APPENDIX B URnuary 1, 1980 QUALITY ASSURANCE Ginna Station IIANUAL Znservice Znspection Program PAG)

For the 1980-1989 Zn erval 18 Attachment A - Exemptions GINNA STATION OF Rochester Gas E 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. BASIS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements of Section XZ of the 1977 Edition of Section XZ 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 respect've edit'ons or addenda are met."

Adoption of this exemption has a minimal impact, since it in-cludes only a small percentage of the {}uality Group A bolting and will in no way gffect plant safety margins.

3~ ALTERNATIVE PROVZS ZONS No alternative or augmented examinations are necessary in this case.

Exem tion V

1. ZDENTZF ICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS The ASME Boiler and Pressure Vessel Code, Section XZ, 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 inspec"ion, but also demand clarity in their appli-cation.

Rochester Gas & Electric feels the earlier later hydrostatic test requirements are not as definitive as the 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.

j, APPENDIX B january 1, 1980 QUALlTY ASSURANCE Ginna Station

( MANUAL GlNNA STATION Inservice Inspection Program For the 1980-1989 Interval Attachment A - Exemptions OF 18

2. BAS IS FOR REL IEF Rochester Gas h Electric will be adopting the requirements of Article-5000 of Section XZ, 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.

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

Exemption VZ

l. IDENTIFICATION 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 ASHE 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 & 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:

APPENDIX B Uh,nuary 1, 1980 QUALITY ASSURANCf Cinna Station MANUAL Inservice Inspection Program For the 1980-1989 Interval PAC) 18 GINNA STATION 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 vill not significantly degrade over the lifetime of the valve.

Based on data compiled from a plant similar in age and design to Ginna, 5 man-rem it is expected exposure vould that approximately 100 man-hours and 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 pre vides little additional information as to the valve's casing integrity.

The valves material, a high strength cast stainless steel (AS'351-CPS), 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 & 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 o the 'valve internal pressure boundary surfaces.

3. ALTERNATIVE PROVISIONS As stated above, Rochester Gas 6 Electric does not bel'eve I 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 visual~examination of the internals and internal pressure boundary surfaces will be performed, to the extent practical.

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~ &IOP YtTLE: hPPENDIX B 8Knu ary 1, 198 0 QUALITY ASSURANCE Ginna Station .:

MANUAL Inservice Inspection Program For the 1980-1989 Interval PAG$

Attachment A - Exemptions GINNA STATION cF

'xemption VII 1~ IDENTIFICATION OF COHPONENTS AND IH PRACTICAL CODE REQUIREHENTS 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 ASHE Boiler and Pressure Vessel Code,Section XI, 1974 Ed'tion 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 & Elect ic believes that this visual exami-II nation adds little or no increase to the overall safety o-the plant and subjects plant personnel to unnecessary radi-ation exposure. Therefore, a request for relief from this I

requirement is sought.

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

1) te 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.

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TfTLE: APPENDIX B january 1, 1980 QVALlTY ASSURANCE Ginna Station MANUAL Znservice Inspection Program PAQ)

For the 1980-1989 Interval 18 GlNNA STAT(ON Attachment A - Exemptions oc 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 ferr'te (typically 5% or more) sub-stantially increases resistance to intergranular stress corrosion cracking. The delta ferrite also helps this material resist pitting corrosion in cnloride conta'ning environments.

Rochester Gas & 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 I As stated above, Rochester Gas 6 Electric does not believe that the visual examination required each ten year inte val 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.

Exemption VZIZ IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQU IREMENTS The ASME Boiler and Pressure Vessel Code, Section XZ, 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 pip'ng, pumps, and valves. In the 1977 Edition of Section XZ, Summer 1978 Addenda, the Code requires 1008 of the required areas for each support attachment be examined.

Rochester Gas a 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.

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a ml eoc TlTLE DAIE APPEND ZX B january 1, 1980 QUALITY ASSURANCE Ginna Station ..

Inservice Inspection Program

< MANUAL GINNA STATION For the 1980-1989 Interval Attachment A - Exemptions PACE 10 OF 18

2. BASIS FOR RELIEF Rochester Gas 6 Electric will be adopting the requirements o Categories C-C and C-E of Section XI, 1977 Edi 'on 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 o 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.

Exemption IX

( 1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIREMENTS

)

The ASME Boiler and Pressure Vessel Code,Section XI, 1974 I Edition through Summer 1979 Addenda requires that reoairs be made either to ASNE Section XX or the Code applicable to the construction of the component. However, in the 1977 Edition of Section XZ, Summer 1978 Addenda, the Code allows the user to apply later Edition of the Construction Code or ASME Section IIZ, 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 XZ, and believes that by adapting the later repai rules Ginna's sys em can be assured of greater integrity. Therefore, a request for relief from the earlier requirement is sought.

2. BAS IS FOR RELIEF Rochester Gas 6 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

a iJQi s A NC TITLE OAIE APPENDIX B january 1, 1980 QUAL)7Y ASSURANCE Ginna Station .

MANUAL Znservice Inspection Progra, PACE For the 1980-1989 Interval 11 18 Attachment A - Exemptions G INN A STAT l ON OF ed'tions or addenda are met. By adopting the more cuzren-rules, Ginna's inservice inspection program invokes a more definitive and adaptable repair program thereby ensuring greater integrity to safety related systems.

3. ALT"RNATZVE PROVISIONS No alternative or augmented examinations are necessary in this case.

Exemotion X 1 IDENT ZFICATZON OF COMPONENTS AND IMPRACTICAL CODE REQU ZREMENTS 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 XZ, Summer 1978 Addenda, the Code re-quires that 100% of the pressure retaining bolting exceeding two inches in diameter be nondestructively examined.

Rochester Gas & Electric believes that the later Edition and Addendas of Section XZ provides more assurance of the overall structural integrity of Ginna ' Quality Gzoup B systems.

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

2. BAS ZS FOR REL ZEF Roches ez Gas 6 Electric will be adopting. the requirements o 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." 'y adopting the more current rules, Ginna's inservice inspection program provides greater assurance for system integrity.

TITLE APPENDIX B Yknuary 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL nservice Inspection Program GINNA STATION For the 1980-1989 Interval PA/2 18 Attachment A - Exemptions OF

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

Exemption XI

1. IDENTIFICATION OF COMPONENTS AND IMRPACTICAL,CODE REQU IRAQI"wax TS The ASIDE 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-5-1 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 inspec ion program provides greate" assurance fo" system integrity.

3. ALTERNA..IVE PROVISIONS No alter'native or augmented exam'nations are necessary in this case;

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TITLE DATE APPENDIX B January 1, 1980 QUAL1TY ASSURAN CE Ginna Station MANUAL nservice Inspection Program PAGE GINNA STATION For the 1980-1989 Interval 13 Attachment A - Exemptions OF Exemption XII

1. IDENTIFICATION OF COMPONENTS AND IMPRACTICAL CODE REQUIR:"MENTS The ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition through Summer 1975 Addenda requires that arrange-ments be made w'ith 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 & 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 & Electric request that Ginna's Station Quality Assurance Program be used in lieu of Code adminis-trative functions.

2. BASIS FOR RELIEF Rochester Gas & Electric's program for the inservice in-spection, governed by the R. E. Ginna Station Quali.y 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 & Electric, (i.e., Ginna Station, Engineering, General Maintenance, Electric Meter and Laboratory and Purchasing).

Approved procedu es will be implemented to control the in-standards for examination evaluation. These procedures 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.

~ I oOC TiTLE DATE APPENDIX B january 1, 1980 QUALITY ASSURANCc Ginna Station MANUAL Inservice Inspection Program PAGE GtNNA STATlON For the 1980-1989 Interval 14 18 Attachment A - Exemptions OF In addition, procedures are developed by Ginna Station to I

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 quali ied staf f 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 inspec ion agency are in compliance with the Code.

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

Exemption XIII

1. IDENTIFICATION OF COMPONENTS AND IMPRACT ICAL CODE REQU IREMEhTS The ASME Boiler and Pressure Vessel Code, Section XZ, 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 revise'd to add clarity and guidance to the Code.

~ t ~0 C,'AZE TITLE APPEND IX B January 1, 1980 QUALI1 Y ASSURANCE Ginna Station MANUAL Inservice Inspection Program PAGE G I N N A 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 Ecition through Summer 1978 Addenda. They believe that by adopting the late" "Records and Reports" rules, Ginna's overall Zn' se"v'ce Zns ec"ion Program can be of better quality. There-fore, a request for relief from the earlier requirement is sought'oches er Gas & Electric will be aaopting the requirements o Ar"icle-6000 of. Section XZ, 1977 Edition through Summer 1978 Adcenca. This is done pursuant to 10CFR50.55a, Paragraph (g)

(4) (iv) which says, "Portions of editions or addenda mav be used providec that all related requirements of the respec ive edi 'ons 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 PROVIS ZONS No alternative or augmented examinations are necessary in this case.

Exemption XZV

1. ZD N .." EC T ZON OF COMPONENTS AND IMP RACT ICAL CODE REQUIREMENTS h

A hold-up tank in the waste disposal system for Ginna provides a mea..s o" 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 mode" of reactor ope at'on including cold shutdown and refueling.

The ASl":- Boiler and Pressure Vessel Code, Section XZ, 1974 Edi"ion th ough Summer 1975 Addenda, requires that the syste...

be subjected to a visual examination under system operating conditions every three and one-third years and a system hydro-sta ic test at 1. 1 times the sytem design pressure each ten year* interval.'

ft TITLE APPENDIX B 3anuary 1, 198G QUALITY ASSURANCE Ginna Station MAt JAL Inservice Inspection Program PAuE GlNNA STAT)QN For the 1980-1989 Interval 16 Attachment A - Exemptions OF Roc.".este Gas & Electric believes that hydrostatically tes=ing the rad-waste hol&up tanks puts Ginna's plant in an unsa e condition and therefore a request for relief f=- m t.".' rec .'ment i's sought.

2. B 8 IS FO'2 RKL ZZF Tho design of the waste disposal system is such that con-taminated wate" is stored in a hold-up tank until such time that the level of contamination is below the limits fo- dis" charge. At this time the hold-up tanks may be reavail'able fo" use bv emptying the stored liquid.

Several important systems with:n the chemical volume and con ol system drain into the waste disposal system hold-up tanks. These are the volume and control tank drains, reac"or coolant letdown system, reactor coolant dra'n tank discharge, and the demineralizer system drains.

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

The plant would then be potentially put into an unsafe cond'tion for any abnc mal plant function and if startup occurred witho"t hold-up tanks being available.

Since this hold-up tank Iconstantly storeiliquid, any de-gradation c the tank material would show up prior to it becoming a problem.

3. AL ER!:ATIV:" PROVISIONS A v'sual exam nation shall be pe formed once every 3 1/3 years to ver' con inued structural integrity.

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DATE QUALITY ASSURANCE APPENDIX B Janua y 1, 1980 MANUAL Ginna Station GINNA STATION nservice Inspection Program PAGE For the 1980-1989 Interval 17 ov 18 Attachment A - m~t'on Exem=tion XV

1. IDENT IC., Ob OF COMPONENTS AND ZHPRAC ICAL CODE R:" lUZRE~IEN' This re'ief request addresses the Section XI examinat'on 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 XZ, Summer 1975 Addenda requires only a partial examination o the pressure retaining welds ir, the reactor vessel. However, i~ the 1977 Edition of Section XI, Summe 1978 Addenda, recuires 100% of the weld to be inspected. Also, in the 1974 Edition of Section XZ, Summer 1975 Addenca 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 XZ, Summer 1978 Addenda allows for the nozzle to vessel welds to be &.Meed 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. BAS S FOR RELIEF Rochester 1"as and Electric wi)l be adopting the requi e-ments of Sec ion XZ o the 1977 Edition of Section XZ 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 reacto" vessel welds including the nozzle to vessel welds were completed. This request is in keeping with the policy of perco ming 100% of all welds in the reactor vessel each inspec ion interval. ,As well as being a practical approach when examining the nozzle to vessel welds so that the recu'red examinations from two directiors may be per o med at the same time.

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~ NKC APPENDIX 3 January 1, 1980 QUALITY ASSURANCE Ginna Station MANUAL Inservice'nspection Program GINNA STATION For the 1980-1989 Interval PAGg Attachment A Exemptions OF Ado"tion of this exemption applies more current rules to Ginna's inservice inpection program providing greater assur-ance fo" system integrity.

3. ALTERNATIVE PROVISIONS No al te native or argumented examanination are necessary in this case.

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