ML17263A822
| ML17263A822 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/27/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17263A821 | List: |
| References | |
| NUDOCS 9411020102 | |
| Download: ML17263A822 (3) | |
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'**'AFE UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 Y EVALU ION BY THE OFFICE OF UCLEAR EACTOR REGUL IO 0
THE THIRD E -YEAR INTERVAL INSE V CE INSPECTIO RE UES FOR R
L EF OCHEST GAS AN EL C
R.
E.
GINNA NUCLEA POWER PLANT DOCKET NUMBER 50-244
- 1. 0 INTRODUCTION The Technical Specifications for R.
E. Ginna Nuclear Power Plant state that the inservice inspection and testing of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)
Class 1, 2, and 3
components shall be performed in accordance with Section XI and applicable
- Addenda, as required by paragraph 50.55a(g) of Title 10 of the Code of Federal Regulations, except where specific written relief has been gr anted 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 of this section 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) must 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 ten-year interval and subsequent intervals comply with the requirements in the latest Edition and addenda of Section XI of the ASME Code incorporated by r eference in 10 CFR 50.55a(b) on the date 12 months prior to 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 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 with an examination requirement of Section XI of the ASME 9411020102 941027 PDR ADOCK 05000244 P
,PDR
Code is impractical for its facility, the licensee shall notify the Commission and submit, as specified in Section 50.4, information to support the determination.
Where an examination requirement by Code or addenda is determined to be impractical under 50.55a(g)(5),
the Commission may grant such relief and may impose alternative requirements as it determines to be authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
In a letter dated September 30,
- 1994, Rochester Gas and Electric (RG8E) proposed that'he alternative to the Code authorized in response to Relief Request (RR) 25 for welded repair or replacement of service water system components be extended thr ough the 1995 refueling outage.
RG&E originally submitted RR 25 by letter dated December 9,
1993, for service water system repair work to be conducted during the 1994 refueling outage.
In a letter dated April ll, 1994, from Walter R. Butler (NRC) to Dr. Robert C. Mecredy (RGEE), the NRC staff granted RR 25 for=the 1994 refueling outage.
The September 30, 1994, letter requests that approval of the alternative initially proposed in RR 25 by letter dated December 9,'993, be extended through the 1995 refueling outage.
2.0 ALUATIO ND CO C USIO S
The NRC staff evaluated the information submitted by the licensee to support its proposal that it be authorized to implement alternatives proposed in RR 25 through the 1995 outage.
RGEE's September 30, 1994, letter submitted the same basis for relief as their December 9,
1993, submittal and would apply to areas of the service water system previously covered in RR 25, ASME Section XI, Paragraph IWA-4710(a), for Class 1, 2, and 3 pressure tests, requires:
After a welded repair on a pressure retaining boundary or the installation of a replacement by welding, a system hydrostatic test shall be performed in accordance with IWA-5000.
During replacement activities associated with service water pump discharge check valves 4603 and 4604 and any other Class 3 welded repairs or replacements in the Service Water System through the 1995 refueling outage, the licensee proposed the following:
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)
[RR No. 25] the following examinations and tests shall be performed.
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.
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 Relief Request 25 shall be documented on an NIS-2 Form.
The staff has evaluated the request to extend the period of authorized use of the RR 25 alternative from work performed through the 1994 refueling outage to work performed through the 1995 refueling outage.
The staff finds the use of the proposed alternative during this additional period will assure weld integrity and, thus, provide an acceptable level of quality and safety provided the proposed additional surface examination is performed on the root pass of the weld.
This conclusion is based on the evaluation contained in the staff's Safety Evaluation and Technical Evaluation Summary as completed by the staff's contractor, the Idaho National Engineering Laboratories, forwarded to you by letter dated April ll, 1994.
The licensee's proposal provides an acceptable (equivalent) alternative to the Code required examination after welded repair or replacement activities on Class 3 portions of the service water system, thus an acceptable level of quality and safety is assured for the additional period of time requested.
The proposed extension of the period for use of the alternatives contained in RR 25, including the licensee s proposed additional surface examination performed on the root pass of the weld, will provide an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i),
the proposed alternatives contained in the extension to RR 25 are authorized to support'elded repair or replacement activities for service water system components through the 1995 refueling outage.
Principal Contributors:
C.K. Battige T.K. McLellan S.M. Malik Date:
October 27, 1994