ML17262A898
| ML17262A898 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/16/1992 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TAC-M74099, NUDOCS 9206170256 | |
| Download: ML17262A898 (9) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 June 16, 1992 Docket No. 50-244 Dr. Robert C. Mecredy Vice President, Nuclear Production Rochester Gas 5 Electric Corporation 89 East Avenue Rochester, New York 14649
Dear Dr. Mecredy:
SUBJECT:
ROCHESTER GAS 8L ELECTRIC CORPORATION'S APRIL 24,
- 1991, AND MAY 6,
- 1991, LETTERS REGARDING REVISIONS OF THE GINNA NUCLEAR POWER STATION QUALITY ASSURANCE MANUAL, APPENDIX B, INSERVICE INSPECTION PROGRAM FOR THE 1990-1999 INTERVAL (TAC NO. M74099)
In your letter of April 24, 1991, you supplied clarifications of two items in the "Third Ten-year Inservice Inspection Interval Plan," Appendix B to the "Quality Assurance Program" for the R.E. Ginna Nuclear Power Plant (plan).
In another letter of Hay 6,
- 1991, you forwarded Revision 1 to the plan.
The staff of the U. S. Nuclear Regulatory Commission (NRC) reviewed the original version (Revision 0) of this plan and found it to be in compliance with Section 50.55a of Title 10 of the Code of Federal Regulations (10 CFR 50.55a) as stated in our safety evaluation report attached to our letter to you of August 6, 1990.
You also requested that request for relief no. 4, which was granted in the safety evaluation report be rescinded and stated that when the NRC approved the American Society of Mechanical Engineers (ASHE) Code Case No. N-481, you would adopt this Code Case into your ISI plan.
Withdrawal of request for relief no.
4 is acceptable to the staff.
The NRC staff, with technical assistance from the Idaho National Engineering Laboratory (INEL), has reviewed and evaluated your submittals.
Upon reviewing your April 24, 1991, letter, the staff found a misunderstanding between our staff on the meaning of request for relief no. 3.
Although this request is not made to a specific paragraph of the ASHE Code, you requested, "that Ginna's Station Quality Assurance Program be used in lieu of Code administrative functions."
In this request for relief you state, "the Code requires that certain administrative functions be performed by the 'Enforcement Authority'nd the
'Authorized Nuclear Inservice Inspector'ANII]."
You justified this request for relief by your statement that, "this state
[New York) has not endorsed ASHE Codes and therefore
[New York] does not provide administrative controls and functions such as
'Enforcement Authority,'Authorized Nuclear Inservice Inspector'nd
'Reporting Systems.'"
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2 dune 16, 1992 The staff approved this relief request to allow you to assume the duties of the enforcement authority because the State of New York does not have such an authori ty.
With the authority allowed by the granted relief, you were to enable the ANII to accomplish his or her duties required by the Code.
The staff expected that you would accomplish certain administrative functions which would include those needed to meet the requirements of Section XI, IWA-6220(d)(1) and (2) of the 1986 Edition of the ASME Code.
The staff did not intend to prevent or restrict the ANII from performing his or her duties.
When the staff first granted the relief requested, for the first 10-year interval inservice inspection in our letter of May 17, 1977, it specifically stated that as a basis for the relief granted, an ANII would be provided by Hartford Steam Boiler Inspection and Insurance Company.
The performance of administrative functions by a licensee is not a substitute for the Code-required third party duties and actions of the ANII.
The staff endorsed the technical evaluation report (TER) prepared by INEL and attached to the August 6, 1990, letter in which a basis for granting this relief was that, "The functions of the authorized nuclear inservice inspector
. will be performed by personnel from the Hartford Steam Boiler Inspection and Insurance Company."
You did not request relief from the duties of the ANII such as those specified in IWA-2110(f) and (g).
These included the duty that the inspector shall certify the examination records only after verifying that the requirements have been met and that the records are correct, and that the inspector shall verify that repairs are performed in accordance with the requirements of the owner's repair program.
IWA-6220(d)(10) requires the NIS-1 and NIS-2 forms to be included in the required inservice inspection summary reports.
These forms provide for the signature of the ANII.
These forms are also specified in Mandatory Appendix II of Section XI, which does not provide for any alternative means of presenting data.
The staff viewed the procedures, approval
- methods, and review requirements discussed in request for relief no.
3 as part of a facility licensee's
- normal, internal approach to meeting Code requirements.
The licensee performs these internal actions to support and supplement its efforts to meet Code requirements, but not to replace the efforts.
The staff views these internal records and reports as internal control documents written to meet internal requirements in areas such as computer database enhancement and budget and cost accounting.
The staff did not understand them to be a replacement of the NIS-1 and NIS-2 forms.
The basis of approving the plan was that all requirements to the Code were met unless relief was specifically granted.
The second issue in your letter of April 24,
- 1991, concerns Section 1.10.3.2 of Appendix 8, which addresses the removal of insulation at bolted joints during pressure testing.
The staff does not agree with your basis for limiting the extent of inspections to bolted connections with ferrous steel fasteners because a non-isolatable leak could occur anywhere in the piping systems for controlling boration.
The Code does not provide the exclusions you are using and you have not requested relief from the Code requirements.
Accordingly, the Code requirements should be satisfied.
f-I" A
3une i6, 1992 The limitations in the plan appear to pr event meeting Code requirements; therefore, the plan must be changed to meet Code requirements.
The staff reviewed your letter of Hay 6,
- 1991, and determined that two of the revisions to the "guality Assurance Program,"
may violate or circumvent requirements of the ASNE Code.
The first change relates to a subject addressed previously, the use of NIS-1 and NIS-2 forms.
These revisions are in your letter, in Attachment II identified as the addition of paragraph 1.6. 1, explaining your intention not to use Section XI, Mandatory Appendix II NIS-1 and NIS-2 forms.
These forms are in a mandatory appendix of Section XI, and the Code makes no provisions for alternative means for presenting data.
Section XI includes provisions in Non-mandatory Appendix B for other forms.
However, you have not requested relief or provided a justification for relief, and thus are required to use the NIS-1 and NIS-2 forms as specified in the Code.
Also in your letter, in Attachment II identified as a modification to paragraph 1.8.2. 1, you commit to using applicable examination requirements of the Construction
- Code, but do not addressSection XI requirements regarding weld repairs, except when the entire weld volume of the existing weld has been removed.
IWA-4500(a) includes the following statement:
"The repaired areas shall be examined to establish a new preservice record.
The examination shall include the method that detected the flaw."
Accordingly, the Code requirement should be satisfied.
The staff reviewed the plan, as stated in the INEL TER, against the applicable Code and appropriate regulations.
The staff considered only the following:
(1) the use of the appropriate edition and addenda of the Code, (2) the acceptability of the examination sample as specified by the Code, (3) the correctness of examination criteria for systems or components as specified in the regulations, (4) compliance with ISI-related commitments found during previous NRC reviews, and (5) compliance of requests for relief from regulatory requirements.
We request that you confirm within 60 days of the date of this letter, the following for the second ten-year inservice inspection interval:
a.
the repairs, modifications, and replacements under Section XI which met the requirements of the Code, and b.
all duties accomplished by the ANII as required by the Code.
Where relief was required and such relief had been requested by you, so note.
Also note those actions which required relief and for which relief was not requested.
If an ANII was not used to the full extent of Code requirements, provide an assessment.
June 16, 1992 The reporting and recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OHB clearance is not required under PL 96-511.
Sincerely, Original signed. by Allen Johnson, Project Manager Project Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc:
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Docket. File.50-244 NRC
& Local PDRs PDI-3 Reading SVarga WLazarus HRushbrook AJohnson JCalvo VNerses OGC (f/info only)
ACRS (10)
J.Lee B. Grimes CYCheng D.Smith E. Gray, Region I J. Linville, Region I R.
Lobel R. HcBrearty, Region I G. Johnson 7D4 See revious concurrence LA:PDI-3 PH: PDI-3 Tech Editor*
MCEB*
Alle ations*
A D:PDI-3*
MRushlss AJohnson:sk JHain*
RHermann JLee VNerses 4 /
/92 LP /i4/92 3/30/92 06/01/92 06/02/92 06/03/92 0FFIGE Re ion I HAHE EGray Re ion I RHcGreart DATE 06 15 92 06 16 92 DOCUMEHT NAME:
GIH 099.LTR
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Dr..Robert C. Hecredy Ginna CC:
Thomas A. Moslak, Senior 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 Hs.
Donna Ross Division of Policy Analysis
& Planning New York State Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223 Charlie Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Nicholas S.
Reynolds Winston
& Strawn 1400 L St.
N.W.
Washington, DC 20005-3502 Hs. Thelma Wideman
- Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7370 Route 31
- Lyons, New York 14489 Hs.
Susan Perry Administrator, Monroe County Office of Emergency Preparedness ill West Fall Road Rochester, New York 14620
0 C