ML17263A885

Responds to ,Which Discussed Two Issues Involving ISI Program (1990-1999)

ML17263A885
Person / Time
Site:	Ginna
Issue date:	12/15/1994
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
TAC-M84044, TAC-M86225, NUDOCS 9412280089
Download: ML17263A885 (6)

Text

PRIORITY 1

(ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS')

ACCESSION NBR:9412280089 DOC.DATE: 94/12/15 NOTARIZED:

NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.

Rochester Gas 6 Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.

Project Directorate I-3 P

R

SUBJECT:

Responds to 930908 ltr,which discussed two issues involving ISI Program (1990-1999).

I DISTRIBUTION CODE:

A047D COPIES RECEIVED:LTR ENCL J SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief f om ASME Code GL-89-04 0

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

05000244 R

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACTTHE DOCUMENTCON fROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELI5II.'PATE YOUR. JAME PRO%I DISTRIBUTIONLISTS I'OR DOCUMENTS YOU DON"I'LED!

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LTTR 14 ENCL 13

4ND ROCHESIER GASANDELECIRICCORPORATION ~ 89 EASTAVENUE ROCHESTER N. Y M6d9 0001 AREA CODE716 5'-2700 ROBERT C. MECREDY Vice President Hvcteoroperotions December 15, 1994 U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Allen R. Johnson Project Directorate I-3 Washington, D.C.

20555

Subject:

Ginna Nuclear Plant Inservice Program Quality Assurance Manual, Appendix B

ASME Section XI Required Examination Revision to Relief Request 13 R.E.

Ginna Nuclear Power Plant Docket No. 50-244 Ref. (a):

Letter from W. R. Butler (NRC), to R.

C. Mecredy (RG&E),

"R.E. Ginna Nuclear Power Plant, Third 10-Year Interval Inservice Inspection Program Plari and Associated Requests for Relief (TAC NOS. M84044 and M86225), dated September 8,

1993.

Dear Mr. Johnson:

This letter is'written in response to your Reference (a) letter in which you discussed two issues involving the Interval Inservice Inspection (ISI)

Program (1990-1999).

RG&E has reviewed your comments on the Third Interval ISI Program and the associated Relief Request 13 as follows:

Pressure testing of piping that penetrates the Reactor Containment, when the piping and isolation valves that are part of the containment system are Class 2 and the balance of the piping system is outside the scope of section XI.

This issue was recently balloted, and approved for use, by the ASME Boiler and Pressure Vessel Code Committee,Section XI, as Code Case N-522.

This Code Case was positively balloted by the NRC representative.

RG&E desires to implement this Code Case into our Inservice Testing

Program, and is thus submitting a revised relief request in accordance with the provisions of 10CFR50.55a(a)(3)(i).

RG&E requests that this Relief Request be reviewed and approved prior to the Refueling Outage beginning in March 1996.

941228008rst 941215 PDR ADOCK 05000244 9

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2.

Removal of insulation, during hydrostatic tests, from bolted connections used in piping systems (containing boric acid) for controlling reactivity.

After further review, RG&E has determined that the previous Relief Request should be withdrawn.

RG&E will remove paragraph 1.10.3.2 from Section 1 of the Third Interval ISI Program.

An approved revision of Section 1 will be forwarded to you as part of the annual review of the ISI program.

This submittal is intended to replace the original Relief Request 13 in its entirety.

If you require any further information in regard to these issues please contact me.

Very ruly yours, Robert C. Mecr y

REJ/356 xc:

Mr. Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

RELIEF REQUEST NO.

13 (REV.

1)

I.

Components for Which Relief is Requested:

Piping that penetrates the containment vessel, when the piping and isolation valves that are part of the containment system are Class 2 and the balance of the piping system is outside the scope of Section XI.

II.

ASME Requirement from Which Relief is Requested:

Relief is requested from the requirements specified in IWA-1320(d),

Table IWC-2500-1, Examination Category C-H of the 1986 Edition, no addenda.

Table IWC-2500-1, Category C-H, requires two inservice or functional tests (IWC-5221) and a hydrostatic test (IWC-5222) per inspection interval.

III. Basis There are two types of piping systems that pass through the containment

vessel, safety related and non-safety related.

The piping (and valves) that penetrate the containment vessel are required to be Class 2 (IWA-1320(d)).

For the non-safety related

systems, only the containment penetration portion of the piping would be Class-2 and require a special pressure test.

The only safety function of this piping is in support of the containment system when containment isolation is

required, therefore, testing in accordance with Appendix J rules would be appropriate.

IV.

Proposed Alternate Method:

Implement ASME, Boiler

& Pressure Vessel Code Case N-522, "Pressure Testing of Containment Penetration Piping".

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