ML17263A579
| ML17263A579 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/11/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17263A578 | List: |
| References | |
| NUDOCS 9404180396 | |
| Download: ML17263A579 (14) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 S
Y UA BY TH 0 FICE OF'UCLEAR R
C 0 'EGULATION OF TH IRO 10-YEAR INTERVA INS RVIC NSPECTION R
VEST FOR RELIEF NOS.
2 ANO 26
~FO ROCHESTER GAS ANO ELECTRIC R.
E.
G NA NUCLEAR PO ANT OOCKET NUMBER 50-244
- 1. 0 INTROOUCTION e
The Technical Specifications for R.E. Ginna Nuclear Power Plant state that the inservice inspection and testing of the American Society'f Mechanical Engineers (ASME) Code Class. 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as requir ed by paragraph'0:55a(g) of Title 10 of the Code of Federal Regulat'ions, 10 CFR 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
Paragraph 50.55a(a)(3) states that alternatives 'to the"requirements of paragraph (g) may be used; when. authorized by the, NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the. level-of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4),
ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the 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.
The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months before the start of the 120-month interval, subject to the limitations and modifications listed therein.
The applicable edition of Section XI of the ASME Code for the Ginna Nuclear Power Plant, Third 10-Year Inservice Inspection (ISI) interval is the 1986 Edition.
The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject 9404i8039b 9404ii PDR 151DOCK,05000244 P
0
to the limitations and modifications listed therein and subject to Commission approval.
Pursuant to 10 CFR 50.55a(g)(5)(iii), if the licensee determines that conformance wiA an exami'nation* requirement of Section XI'of the ASME Code is not pract'ical for its faciljty, the licensee shall 'submit information to the Commission to support that determination and make a request for relief from the ASME Code requirement.
After evaluating the determination,'ursuant to 10 CFR 50.55a(g)(6)(i),
the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law; will not endanger life, property, or the common defense and security; and are otherwise in the public interest, giving due consideration to the.,burden upon.the licensee that could result if the requirements were imposed.
In letters dated December 9,
- 1993, and January 7,
1994, the licensee, Rochester Gas and Electric, proposed an alternative to the Code that is.contained in, both Requests for Relief 25 and 26.
These requests for relief apply for the Third 10-Year ISI Interval.
2.0 EVALUATION AND CONCLUSIONS The NRC staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory, evaluated the information submitted by the:
licensee to support its proposed alternatives contaihed in Request for Relief 25 and 26.,
The, alternatives contained in Request for Relief 25 and 26 are technically the same.
The licensee proposed the following for both requests:
In lieu of performi,ngthe hydrostatic pressure.test required by IWA-4400 for w'elded repairs or installation of replacement items in the Service Water System (Class 3)
[RR No.- 25],
and Component Cooling Water System (Class 3)
[RR No. 26] by welding; the following examinations and tests shall be performed.
cg a 1)
[Nondestructive examination]
NDE shall be performed in accordance with the methods and acceptance criteria of Subsection ND of the 1986 Edition of Section III.
In addition, when the surface examination method is used in accordance with ND-5222 for a butt
- weld, an additional surface examination shall be performed on the root (pass) layer.
I 2)
Prior to or immediately upon return to service, a VT-2 visual examination shall be performed in conjunction with a system inservice or functional test, using the 1986 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure and temperature.
3)
Use of this Case [Relief Request 25 and 26] shall be documented on an NIS-2 Form.
The staff reviewed the information submitted, agrees with and adopts the contractor's conclusions and recommendations presented in the Technical Evaluation Summary attached.
The proposed alternatives contained"in Request for Relief 25 and 26 will provide an acceptable level of quality and safety if an additional surface examination, as proposed, is performed on the root pass of the weld.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i),
the proposed alternatives contained'in both requests for-relief are authorized for the 1994 refueling outage.
Principal Contributor:
T. HcLellan Date:
April 11, 1994
ATTACHMENT TH T
HN CA A
AT ON SUMMA
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OW 0- 4
- 1. 0 J5IRR01 I
By letter dated Oecember 9, 1993, and a subsequent clarification letter dated January 7,
1994, the licensee, Rochester Gas 5 Electric, submitted, Requests for Relief Nos.
25 and 26 for the third 10-year inservice inspection (ISI).
interval that ends in Oecember 1999.
The Idaho National Engineering Laboratory (INEL) has evaluated the sub)ect requests for relief in the following sections.
2.0 EBLUUM The information provided by the licensee in support of the requests for relief and alternatives contained therein has been evaluated below.
The applicable Code for the R.
E. Ginna Nuclear Power Plant, Unit I, third 10-year ISI interval is the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1986 Edition.
A.
R Re i N
ub fcle WA-4400 nd Sub a
a ra h
ostat c Press re Test on as 3
Re aired Re laced Com onents n Portions o
the Servic Mater S stem Code Re ir me t:
IWA-4400(a) states that after repairs by welding on the pressure-retaining
- boundary, a system hydrostatic test shall be performed in accordance with IWA-5000.
IWA-5000 specifies that the hydrostatic testing for Class 3 systems shall be performed to IWO-5223(a).
IWO-5223(a) states that "The system hydrostatic test
pressure shall be at least
- 1. 10 times the system pressure P, for systems with Design Temperature of 200 or less,"...[or]... "For systems (or portions of systems) not provided with safety or relief valves, the system design pressure P shall be substituted for P,."
icense
's Code i
R e t:
The licensee requested relief from
'performing the Code-required hydrostatic pressure test for repairs or replacements on the Class 3 Service Water System (SWS) for the 1994 refueling outage.
s f R
(as stated):
"Industry studies have shown that the hydrostatic pressure test specified in IWO-5223(a) is not an integrity test of the weld, but is in fact a leakage test run at a high pressure.
Using surface examination methods on different passes of the weld or volumetric examinations methods on a
completed weld provide more comprehensive results in the determination of the integrity of the weld.
In addition, a system inservice or functional test and VT-2 examination will be performed on the completed welds.
"The SWS is a moderate energy system which does not have safety or relief valves installed for purposes of over pressure protection.
The system operates at a nominal 75 psig, which is only 90 psig below the Code required hydrostatic test pressure of 1.10 X P~.
The Code required hydrostatic test would not offer any significant increase in the ability to determine the leak-tightness of the repairs over testing performed at system nominal operating pressure.
The structural integrity will be ensured by the controls instituted in the repair or replacement procedures and verified with nondestructive examination (NDE).
Since the system is in constant operation, its integrity is continually monitored.
In addition, the redundancy in SWS gives added assurance of meeting heat load requirements."
icensee's Pro osed Alte ative xaminatio (as stated):
"In lieu of performing the hydrostatic pressure test required by IWA-4400 for welded repairs or installation of replacement items in the Service Water System (Class
- 3) by welding, the following examinations and tests shall be performed.
I)
NDE shall be performed in accordance with the methods and acceptance criteria of Subsection ND of the 1986 Edition of Section III.
In
- addition, when the surface examination method is used in accordance with NO-5222 for a butt weld, an additional 'surface examination shall be performed on the root (pass) layer.
2)
Prior to or immediately upon return to service, a VT-2 visual examination shall be performed in conjunction with a system inservice or functional test, using the 1986 Edition of Section XI,
in accordance with IWA-5000, at nominal operating pressure and temperature.
3)
Use of this case shall be documented on an NIS-2 Form."
- ElLlltl a:
Th C d q I th t ft p I~
p1 t by welding on the subject Class 3 system, a system hydrostatic test shall be performed at 1. 10 times design pressure.
In lieu of the Code-required hydrostatic test, the licensee has proposed a surface examination of the repair/replacement weld root pass, and a
VT-2 visual examination during a system inservice or functional pressure test.
The pressure test will be performed in accordance with IWA-5000, at nominal operating pressure and temperature.
The licensee will document the use of Relief Request No.
25 on the NIS-2 form.
The quality of repair/replacement welds will be controlled through replacement procedures and the NDE required by Subsection ND of the 1986 Edition of Section III.
The licensee stated that the operation of the SWS is continually monitored, and added assurance of meeting heat load requirements is provided by system redundancy.
The licensee's proposed alternative to the Code-required'hydrostatic test for repairs/replacements during the 1994 refueling outage, in'onjunction with the monitoring and redundancy of the SWS should provide an acceptable level of quality and safety provided that an additional surface examination is performed on the root (pass) layer regardless of the type of weld.
Therefore, pursuant to 10 CFR 50.55a(3)(i), it is recommended that the proposed alternative be authorized for the 1994 refueling outage.
- Note: In a telephone conversation with the licensee on March 3, 1994, the licensee noted that the words, "Relief Request" should be substituted for the word "Case".
8.
e Com b
1 WA-44 0 S
b es tsonC1 s
eai d
the om ne t Coolin W
er S st
'4 ed
~td 4:
IIII-44444 4
t t tb t ft 4 I by Idt 4 the pressure-retaining
- boundary, a system hydrostatic test shall be performed in accordance with IWA-5000.
IWA-5000 specifies that the hydrostatic testing of Class 3 systems shall be performed to IWD-5223(a).
IWD-5223(a) states that "The system hydrostatic test pressure shall be at least
- 1. 10 times the system pressure P, for systems with Design Temperature of 200'r less,"...[or]... "For systems (or portions of systems) not provided with safety or relief valves, the system design pressure P~ shall be substituted for P,."
icen
's ode Re e
ue The licensee requested relief from the Code-required hydrostatic pressure test for repairs or replacements on the Class 3 Component Cooling Water System (CCWS) during the 1994 refueling outage.
ic n
's 8
is (as stated):
"Industry studies have shown that the hydrostatic pressure test specified in IWD-5223(a) is not an integrity test of the weld, but is in fact a
leakage test run at a high pressure.
Using surface examination methods on different passes of the weld or volumetric examinations methods on a
completed weld provide more comprehensive results in the determination of the integrity of the weld.
In addition, a system inservice or functional test and VT-2 examination will be performed on, the completed welds.
"The CCWS is a moderate energy system which does not have safety or relief valves installed for purposes of over pressure protection.
The system operates at a nominal 90 psig, which is only 98 psig below the Code required hydrostatic test pressure of 1. 10 X P~.
The Code required hydrostatic test would not offer any significant increase in the ability to determine the leak-tightness of the repairs over testing performed at system nominal operating pressure.
The structural integrity will be ensured by the controls instituted in the repair or replacement procedures and verified with nondestructive examination (NDE).
Since the system is in constant operation, its integrity is continually monitored.
In addition, the redundancy in CCWS gives added assurance of meeting heat load requirements."
~1
Pro ed t rnative min tion (as stated):
"In lieu of performing the hydrostatic pressure test required by IWA-4400 for welded repairs or installation of replacement items in the Component Cooling Water System (Class 3) by welding, the following examinations and tests shall be performed.
I)
NDE shall be performed in accordance with the methods and acceptance criteria of Subsection ND of the 1986 Edition 'of Section III.
In
- addition, when the surface examination method is used in accordance with ND-5222 for a butt weld, an additional surface examination shall be performed on the root (pass) layer.
2) 3)
Prior to or immediately upon return to service, a VT-2 visual examination shall be performed in conjunction with a system inservice or functional test, using the 1986 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure and temperature.
Use of this Relief Request shall be documented on an NIS-2 form."
Elullgttl:ThCdql tlt ft pi p1 tby welding on the subject, Class 3 system, a system hydrostatic test shall be performed at 1.10 times design pressure.
l In lieu of the Code-required hydrostatic test, the licensee has proposed a surface examination of the repair/replacement weld root pass and a VT-2 visual examination during a pressure test.
-The pressure test will be performed in accordance with IWA-5000, at nominal operating pressure and temperature.
The licensee will document the use of Relief Request No.
26 on the NIS-2 form.
The weld quality of repair/replacement welds will be controlled through replacement procedures and the NDE required by Subsection ND of the 1986 Edition of Section III.
The licensee stated that the operation of the CCWS is continually monitored, and added assurance of meeting heat load requirements is provided by system redundancy.
The licensee's proposed alternative to the Code hydrostatic test requirement for repairs/replacements during the 1994 refueling outage, in conjunction with the monitoring and redundancy of the CCWS, should provide an acceptable level of quality and safety provided that an additional surface examination is performed on the root (pass) layer
ft t
regardless of the type of weld.
Therefore, pursuant to 10 CFR 50.55a(3)(i), it is recommended that the proposed alternative be authorized for the 1994 refueling outage.
3.0 CONC S
In Relief Requests 25 and 26 the licensee has proposed an alternative to the hydrostatic tests of Class 3 repaired/replaced components in portions of the Service Water System and Component Cooling Water System.
With the provisions
.as noted above, the proposed alternatives to the Code requirement should provide an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), it is recommended that the proposed alternatives be authorized for the 1994 refueling outage.
I