ML17265A738

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SE Approving Licensee Requests for Relief 37,38,39,40 & 41 for Re Ginna Nuclear Power Plant for Third & Fourth 10-year Inservice Insp Interval
ML17265A738
Person / Time
Site: Ginna Constellation icon.png
Issue date: 08/16/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML17265A736 List:
References
NUDOCS 9908190034
Download: ML17265A738 (17)


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UNITED ST. 4T "S NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 cs

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SAFETY EVALUATIONBY THE OFFICE OF N't"LEARREACTOR REGULATION ON THE THIRD AND FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL REQUEST FOR RELIEF NOS. 37 38 39 40 AND 41 ROCHESTER GAS AND ELECTRIC CORPORATION R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244

1.0 INTRODUCTION

The U.S. Nuclear Regulatory Commission (NRC) amended its regulations to incorporate by reference the 1992 edition with 1992 addenda of Subsections IWE and IWLof Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) and was published in the Federal Re<lister dated August 8, 1996 (61 FR 41303).

Subsections tWE and IWLprovide the requirements for inservice inspection (ISI) of Class CC (concrete containment), and Class MC (metallic containment) of light-water cooled power plants.

The effective date for the amended rule was September 9, 1996, and it requires the licensees to incorporate the new requirements into their ISI plans and to complete the first containment inspection by September 9, 2001.

Alternatives to Code requirements may be used by nuclear licensees when authorized by the Commission if the proposed alternatives to the requirements are such that they are shown'to provide an acceptable level of quality and safety in lieu of the Code requirements [10 CFR 50.55a(a)(3)(i)], or if compliance with the Code requirements would result in hardship or unusual difficuitywithout compensating increase in the level of quality and safety [10 CFR 50.55a(a)(6)(i)].

A licensee may also submit requests for relief from certain Code requirements when a licensee has determined that conformance with certain Code requirements is impractical for its facility

[10 CFR 50.55a(g)(5)(iii)]. Pursuant to 10 CFR 50.55a(a)(6)(i), the Commission may grant such relief and may impose such alternative requirements as it determines is authorized by law and willnot 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.

By the three letters dated January 11, 1999 (References 1, 2 and 3) and the letter dated June 21, 1999 (Reference 4), the licensee, Rochester Gas and Electric Corporation, proposed several alternatives to the requirements of Subsections IWE and IWLof Section XI of the ASME Code for its R. E. Ginna nuclear power plant. The NRC's findings with respect to the licensees's requests are discussed in this evaluation.

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~ 2.0 EVALUATION 2.1 Relief Re uest RR-37 2.1.1 Code Re uirement IWE-2500, Table IWE-2500-1, Examination Category E-D requires seals and gaskets on airlocks, hatches, and other devices to be visually examined, VT-3, once each interval to assure containment leak-tight integrity. Relief is requested from performing the Code-required visual examination, VT-3, on the referenced metal containment seals and gaskets.

2.1.2 Basis for Relief:

10 CFR 50.55a was amended to require the use of the 1992 Edition, 1992 Addenda, of Section Xf when performing containment examinations and was published in the Federal ~Rs ister (61 FR 41303). The penetrations discussed below contain seals and gaskets.

A. Electrical Penetrations Electrical penetrations use a header plate attached to a containment penetration nozzle flange with redundant 0-rings between the header plate and flange face.

Modules through which electrical conductors pass are installed in the header plate.

One type, manufactured by Amphenol, uses seals and gaskets to assure leak-tight integrity. A second type, manufactured by Conax, uses a set of compression fittings. Replacement modules for the Amphenol penetrations use a combination of 0-rings and compression fittings. Each penetration is pressurized with dry nitrogen to maintain and monitor integrity and to prevent the intrusion of moisture into the penetration.

These seals and gaskets cannot be inspected without disassembly of the penetration to gain access to the seals and gaskets.

B. Containment Personnel and Equipment Hatches The personnel and equipment hatches utilize an inner and outer door with gasket surfaces to ensure a leak-tight integrity. These hatches also contain other gaskets and seals such as the handwheel shaft seals, electrical penetrations, blank flanges, and equalizing pressure connections which require disassembly to gain access to the gaskets and seals.

Seal and gasket joints receive a 10 CFR Part 50 Appendix J test. As noted in 10 CFR Part 50, Appendix J, the purpose of Type B tests is to measure leakage of containment or penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies.

Examination of seals and gaskets require the joints, which are proven adequate through Appendix J testing, be disassembled.

For electrical penetrations, this would involve a pre-maintenance Appendix J test, determination of cables at electrical penetrations if enough cable slack is not available, disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, re-termination of the cables if necessary, post maintenance testing of the cables, and a post maintenance Appendix J test of the penetration.

The work required for the containment hatches would be similar except for the determination, re-termination, and testing of cables.

This imposes the risk that equipment could be damaged.

The 1992 Edition, 1993 Addenda, of Section XI recognizes that disassembly of joints to perform these examinations is not warranted.

Note 1 in

Examination Category E-D was modified in the 1995 Edition of Section XI to state that seal or gasket connections need not be disassembled solely for performance of examinations.

However, without disassembly, most of the surface of the seals and gaskets would be inaccessible.

t For those penetrations that are routinely disassembled, a Type B test is required upon final assembly and prior to start-up.

Since the Type B test willassure the leak-tight integrity of primary containment, the performance of the visual examination would not provide an increase in the level of safety and quality.

Seals and gaskets are not part of the containment boundary under current Code rules (NE-1220 (b)). The airlocks and hatches containing these materials are tested in accordance with 10 CFR Part 50, Appendix J.

If increased leakage is identified during these Appendix J tests, the cause of leakage would be investigated.

If increased leakage were due to degradation of the seal or gasket material, corrective measures would be applied and the component retested.

Repair or replacement of seals and gaskets is not subject to Code (1992 Edition, 1992 Addenda) rules in accordance with Paragraph IWA-4111(b)(5) of ASME Section XI~

2.1.3 Staff Evaluation of RR-37

- Although the staff agrees that ASME Code rules for repair and replacement do not apply to seals and gaskets, the staff does not fullyagree with the licensee's statement that penetration seals and gaskets are not part of the containment pressure boundary.

However, the staff finds that the licensee's alternative examination of the containment penetration seals and gaskets (including those of electrical penetrations) would verify the leak-tight integrity of the seals and gaskets during the Type B testing as required by 10 CFR Part 50, Appendix J. Moreover, the licensee proposes to use, in lieu of performing the VT-3 examinations for containment penetration seals and gaskets, the current program for leakage testing containment penetrations in accordance with 10 CFR Part 50, Appendix J.

The staff finds that because the seals and gaskets associated with these penetrations are not accessible for examination when the penetration is assembled, containment penetrations seals and gaskets must be disassembled and reassembled for the purpose of performing the VT-3 visual examination.

These activities (disassembly and reassembly of seals and gaskets) associated with a VT-3 visual examination would introduce the possibility of component damage that would not otherwise occur. The periodic test of penetrations in accordance with 10 CFR

.Part 50; Appendix J willdetect local leaks at containment peak accident pressure and measure leakage across the leakage-limiting boundary of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies.

If unacceptable leakage is identified during the test, corrective measures would be taken.

Also, the staff realizes'that the 1992 Edition, including the 1993 Addenda of ASME Code,Section XI has recognized that disassembly of joints for the sole purpose of performance of the visual examination is unwarranted.

Requiring the licensee to disassemble components for the sole purpose of inspecting seals and gaskets would place a significant hardship on the licensee without a compensating increase in the level of quality and safety.

On the basis discussed above, the staff concludes that the alternative proposed by the licensee willprovide reasonable assurance of the leak-tight integrity of the containment penetration seals and gaskets during the Type B testing required by 10 CFR Part 50, Appendix J. Therefore, the request for relief is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specific requirements of the Code would result in hardship without a compensating increase in the level of quality and safety.

2.2 Relief Re vest RR-38 2.2.1 Code Re uirement:

Paragraphs IWE-2420(b) and IWE-2420(c) of the 1992 Edition, 1992 Addenda of ASME Section XI require that when component examination results require evaluation of flaws, evaluation of areas of degradation, or repairs in accordance with Article IWE-3000, and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next inspection period listed in the schedule of the inspection program of Paragraph IWE-2411 or Paragraph IWE-2412, in accordance with Table IWE-2500-1, Examination Category E-C. Relief is requested from the requirements of Paragraphs IWE-2420(b) and IWE-2420(c) to perform successive examination of repairs.

2.2.2 Basis for Relief 10 CFR 50.55a was amended to require the use of the 1992 Edition, 1992 Addenda of Section Xl when performing containment examinations and was published in the Federal Receister (61 FR 41303). The purpose of a repair is to restore the component to an acceptable condition for continued service in accordance with the acceptance standards of Article IWE-3000.

Paragraph IWA-4150 requires the owner to conduct an evaluation of the suitability of the r'epair including consideration of the cause of failure.

If the repair has restored the component to an acceptable condition, it is overly conservative to require successive examinations.

Other paragraphs of the ASME Code recognize this requirement as overly conservative.

If the repair was not suitable, then the repair does not meet Code requirements and the component is not acceptable for continued service.

Neither Paragraph IWB-2420(b), Paragraph IWC-2420(b), nor Paragraph IWD-2420(b) requires a repair to be subject to successive examination requirements.

Furthermore, if the repair area is subject to accelerated degradation, it would still require augmented examination in accordance with Table IWE-2500-1, Examination Category E-C. The successive examination of repairs in accordance with Paragraphs IWE-2420(b) and IWE-2420(c) constitutes a burden without a compensating increase in quality or safety.

In response to public comment ¹3.3, the NRC stated (SECY-96-080 dated April 17, I 996):

"The purpose of IWE-2420(b) is to manage components found to be acceptable for continued service (meaning no repair or replacement at this time) as an Examination Category E-C component...

If the component had been repaired or replaced, then the more frequent examination would not be needed."

e Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii).

Compliance with the original requirements of this section would result in hardship or unusual difficultywithout a compensating increase in the level of quality and safety.

The requirement to perform successive examinations following r'epairs has been removed in the 1997 Addenda of ASME Section XI. This addenda has been approved by the ASME Main Committee and has been published.

2.2.3 Staff Evaluation of RR-38 The staff agrees with the licensee that if the repair has restored the component to an acceptable condition, it is overly conservative to require successive examinations and successive examination of repairs in accordance with the Code constitutes a burden or hardship without a compensating increase in quality or safety.

The staff agrees with the licensee's statement that when repairs are complete, IWA-4150 requires licensees to evaluate the suitability of the repair. When a repair is required because of the failure of an item, the evaluation shall consider the cause of failure to ensure that the repair is suitable.

Considering that the failure mechanism is identified and corrected as required and the repair receives preservice examinations, as required, the proposed alternative willprovide reasonable assurance of structural integrity. In addition, IWB-2420(b), IWC-2420(b), and IWD-2420(b) do not require the successive inspection of repairs for Class 1; 2 and 3 cdLrlponents as required in IWE-2420(b) for metal containment.

Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the specific Code requirements would result in hardship without a compensating increase in the level of quality and safety.

2.3 Relief Re uest RR-39 2.3.1 Code Re uirement x

ASME Section XI, 1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item E8.20.

Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval. Relief is requested from ASME Section XI 1992 Edition with 1992 Addenda Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item E8.20.

Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval.

2.3.2 Basis for Relief 10 CFR 50.55a was amended to require the use of the 1992 Edition, 1992 Addenda of Section Xt when performing containment examinations and was published in the Federal Rsceiste.

rr61 FR 41303).

Bolt torque or tension testing is required on bolted connections that have not been disassembled and reassembled during the inspection interval. Determination of the torque or tension value would require that the bolting be untorqued and then re-torqued or re-tensioned.

The performance of the Type B test itself proves that the bolt torque or tension remains adequate to provide a leak rate that is within acceptable limits. The torque or tension value of bolting only becomes an issue if the leak rate is excessive.

Once a bolt is torqued or tensioned, it is not subject to dynamic loading that could cause it to experience significant change.

Verification of torque or tension values on bolted joints that are proven adequate through Appendix J testing and visual inspection is adequate to demonstrate that design function is met.

Torque or tension testing is not required on any other ASME Section XI, Class 1, 2, or 3 bolted connections or their supports as part of the inservice inspection program.

Also, all penetrations at R. E. Ginna Nuclear Power Plant are seated with pressure (not unseated).

Relief is requested in accordance with 10 CFR 50.55a(a)(3) (ii). Compliance with the original requirements of this section would result in hardship or unusual difficultywithout a compensating increase in the level of quality and safety.

2.3.3 Alternative Examinations The following examinations and tests required by Subsection IWE ensure the structural integrity and leak-tightness of Class MC pressure retaining bolting and no additional examinations are proposed:

(1) Exposed surfaces of bolted connections shall be visually examined in accordance with requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item No. E8.10, (2) Bolted connections shall meet the pressure test requirements of Table IWE-2500-1, Examination Category E-P, All Pressure Retaining Components, Item E9.40, and (3) A general visual examination of the entire containment once each inspection period shall be conducted in accordance with 10 CFR 50.55a(b)(2)(x)(E).

2.3.4 Staff Evaluation of RR-39 ASME Section XI, 1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item E8.20 requires bolt torque or tension testing on bolted connections that have not been disassembled and reassembled during the inspection interval ~ This examination is used to aid in the determination that leak-tight seals exists and that the structural integrity of the subject bolted connections is maintained.

The licensee proposes to use the 10 CFR Part 50, Appendix J, Type B test as an alternative to the Code requirement to verify the integrity of penetrations with bolted connections.

The staff agrees with the licensee that bolt torque or tension testing on bolted connections that have not been disassembled and reassembled during the inspection interval would require the

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burden of bolti'ng be un-torqued and then re-torqued or re-tensioned, whereas the leak testing via 10 CFR Part 50, Appendix J, testing (pressure testing) would adequately verify the leak-tight integrity of the containment.

The staff finds that compliance with ASME Code requirements willcause a hardship or an unusual difficultybecause un-torquing and subsequent re-torquing bolted connections involves unnecessary radiation exposure and costs to perform the work. The staff also finds that the alternative approach proposed by the licensee (the test required by 10 CFR Part 50, Appendix J, (pressure testing) to verify the leak-tight integrity of bolted connections for containment vessel leak-tight integrity) willprovide a reasonable assurance of the containment leak-tight integrity, which is the basic purpose of the ASME Code requirements.

On this basis, the staff concludes that the alternative proposed by the licensee is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

2.4 Re uest Relief RR-40 2.4.1 Code Re uirement:

Paragraph IWE-5240 of the 1992 Edition, 1992 Addenda of ASME Section XI requires that the requirements of Paragraph IWA-5240 for visual examination, VT-2, are applicable following repair, replacement or modification. Relief is requested from performing the VT-2 visual examination in connection with system pressure testing following repair, replacement or modification under Article IWA-5000.

2.4.2 Basis for Relief 10 CFR 50.55a was amended to require the use of the 1992 Edition, 1992 Addenda of ASME Section XI when performing containment examinations and was published in the Federal

~Re ister (61 PR 41303).

Paragraph tWE-5210 states that except as noted within Paragraph IWE-5240, the requirements of Article IWA-5000 are not applicable to Class MC or Class CC components.

Paragraph IWE-5240 states that the requirements of Paragraph IWA-5240 (corrected from IWA-5246 to IWA-5240 in the 1993 Addenda) for visual examinations are applicable.

Paragraph IWA-5240 describes a VT-2 visual examination.

VT-2 examinations are conducted to detect evidence of leakage from pressure-retaining components, with or without leakage collection systems, as required during the conduct of a system pressure test.

In addition, personnel performing VT-2 examinations are required to be qualified in accordance with Subarticle IWA-2300 of ASME Section XI.

For repairs, replacements or modifications that are performed under ASME Section XI Code, applicable construction code (or installation code) non-destructive examinations (NDE) are performed and must meet the acceptance criteria of the constructionfinstailation code.

In addition to the construction code NDE, applicable ASME Section XI pre-service NDE is also performed.

This construction code and Section XI pre-service NDE requirements'provide additional assurances that the repairs, replacements or modifications are sound and leak-tight.

Table IWE-2500-1, Examination Category E-P, identifies the examination method of 10 CFR 50, Appendix J and does not specifically identify a VT-2 visual examination.

10 CFR Part 50, Appendix J provides requirements for testing as well as acceptable leakage criteria. These tests are performed by Appendix J "Test" personnel and utilize calibrated equipment to determine acceptability. Additionally, 10 CFR 50.55a(b)(2)(x)(E) requires a general visual examination of the containment each period that would identify any structural degradation that may contribute to leakage.

A VT-2 visual examination will not provide additional assurance of safety beyond that of current Appendix J practices.

Relief is requested in accordance with 10 CFR 50.55a(a)(3)(i).

The proposed alternative (pressure testing in accordar.ce with 10 CFR Part 50, Appendix J) willprovide an acceptable level of quality and safety.

The reference to paragraph IWA-5240 has been removed in the 1997 Addenda of ASME Section XI. This addenda has been approved by the ASME Main Committee and has been published in 1998.

2.4.3 Alternate Examinations In response to the staff's concern raised during the conference call on June 16, 1999, the licensee revised the "Alternate Examinations" submitted on June 21, 1999 (Reference 4). The revised "Alternate Examinations" is as follows:

"Testing shall be conducted in accordance with 10 CFR 50, Appendix J, in lieu of Paragraph IWE-5240 of ASME Section XI as well as performing an IWE detailed visual examination of the repaired or replaced area (VT-1)."2.4.4 Staff Evaluation of RR-40 In lieu of the requirements of Paragraph IWA-5240 of ASME Section XI for the visual examination, VT-2, to be applied following repair, replacement or modification, the licensee proposed that testing shall be conducted in accordance with 10 CFR Part 50, Appendix J.

The staff agrees with the licensee's statement that for repairs, replacements or modifications that are performed under ASME Section XI, the applicable construction/installation code NDE are performed and must meet the acceptance criteria of the construction finstallation code.

In addition to the construction code NDE, applicable ASME Section XI pre-service NDE is also performed.

These construction code and Section XI pre-service NDE requirements provide additional assurances that the repairs, replacements or modifications are sound and leak-tight.

Also, Table IWE-2500-1 (Examination Category E-P) requires only an examination method of 10 CFR Part 50, Appendix J for the containment vessel pressure retaining boundary following each repair, replacement, or modification and doe" not specifically identify a VT-2 visual examination.

In addition, 10 CFR Part 50, Appendix J provides requirements for testing including acceptable leakage criteria and the tests are performed by Appendix J "Test" personnel by utilizing calibrated equipment to determine acceptability.

Moreover, 10 CFR 50.55a(b)(2)(x)(E) requires a general visual examination of the containment each period that would identify any structural degradation that may contribute to leakage.

Furthermore, the licensee willperform an IWE detailed visual examination of the repaired or replaced area.

From the discussion above, staff finds that the licensee's proposed alternative, together with the NDE performed for repairs, replacements or modifications, provides an acceptable level of quality and safety. Therefore, the alternative proposed by the licensee is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

2.5 Relief Re uest RR-41 2.5.1 Code Re uirement ASME Section XI, 1992 Edition, 1992 Addenda, IWL-2310, Visual Examination and Personnel Qualification and IWA-2210, Visual Examinations, requires specific minimum illumination and maximum direct examination distance for all concrete surfaces.

Relief is requested from Paragraph IWA-2210, Visual Examination Requirements, for minimum illumination and maximum direct examination distance of Class CC components under Paragraph IWL-2310.

2.5.2 Basis for Relief 10 CFR 50.55a was amended to require the use of the 1992 Edition, 1992 Addenda, of Section Xt when performing containment examinations and was published in the Federal Receister

4 (61 FR 41303).

In addition to the requirements of Subsection IWL, the rulemaking also imposes the requirements of Subsection IWAof the 199" Edition, 1992 Addendum, of ASME Section XI for minimum illumination and maximum direct examination distance of Class CC components, specifically for the examination of concrete under Paragraph IWL-2510. When remotely-performing the visual examinations required by Subsection IWL Paragraph IWL-2510, the maximum direct examination distance specified in Table IWA-2210-1 may be extended, and the minimum illumination requirements specified in Table IWA-2210-1 may be decreased.

IWA-2210 allows for remote examination as long as the remote examination procedure is demonstrated to resolve the selected test chart characters.

The registered professional engineer (RPE) will identify minimum size of indications of interest.

For remote visual examination, the procedure and equipment to be used willbe demonstrated capable of resolving these minimum indications to the satisfaction of the RPE and the authorIzed nuclear insurance inspector(ANII), as allowed in IWE-2240, "Alternative Examination." The record of demonstration will be available to regulatory authorities.

Accessibility to higher portions of the dome and the containment building itself make it a hardship to obtain the maximum direct examination distance and minimum illumination requirements.

The installation of extensive temporary scaffold systems or a climbing scaffold system to access these portions of the containment would*be necessary.

These scaffolds would provide limited access due to containment geometry restrictions as well as structural and equipment interferences.

The installation and removal of these scaffolds would increase both worker radiation exposure and personnel safety in order to meet Paragraph IWA-2210 requirements.

As part of the rulemaking change process, the NRC staff received seven comments that were consolidated into Public Comment ¹ 2.3 in Part III of Attachment 6A to SECY-96-080.

The staff response to these concerns is as follows:

"Comments received from ASME members on the containment committees indicate that the newer, more stringent requirements of IWA-2210 were not intended to be used for the examination of containment and were inadvertently included in Subsection IWL. The NRC agrees that remote examinations are the only practical method for inspecting much of the containment surface area.

10 CFR 50.55a(b) (2) (x) (B) has been added to the final rule which contains alternative lighting and resolution requirements which may be used in lieu of the requirements contained in IWA-2210-1."

However, as specified within 10 CFR 50.55a(b)(2)(x)(B) of the final rule, this alternative applies only to Subsection IWE, and not to Subsection IWL.

Relief is requested in accordance with 10 CFR 50.55a(a)(3) (ii). Compliance with the original requirements of this section would result in hardship or unusual difficultywithout a compensating increase in the level of quality and safety.

2.5.3 Alternative Examinations When performing remotely the visual examinations required by IWL-2510, the maximum direct examination distance specified in Table IWA-2210-1 may be extended, and the minimum illumination requirements specified in Table IWA-2210-1 may be decreased provided that the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination.

2.5.4 Staff Evaluation of RR-41 As described in "Basis for Relief" section above, because the accessibility to higher portions of the dome and the containment building itself will make it a hardship to obtain the maximum direct examination distance and minimum illumination requirements, the licensee proposed an alternative to the requirements for the measurement of illumination and examination distance for visual examinations specified in ASME Section XI, 1992 Edition, 1992 Addenda, IWL-2310, "Visual Examination and Personnel Qualification," and IWA-2210, "Visual Examination." The alternate examinations state'that the Code required maximum direct examination distance may be increased and the minimum illumination may be decreased provided that the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination.

The visual examinations on containment are performed to determine if damage or degradation, including cracks, wear, corrosion, erosion or other physical damage, warrant additional evaluation or repair of the structure.

In order for the visual examinations to be performed in such a way as to detect critical flaws, proper lighting is essential.

IWA-2210 allows for remote examination as long as the remote examination procedure is demonstrated to resolve the selected test chart characters.

The licensee, when the alternative approach is taken, explained that the RPE will identify minimum size of indications of interest.

For remote visual examination, the procedure and equipment to be used willbe demonstrated capable of resolving these minimum indications to the satisfaction of the RPE and the ANII,as allowed in IWE-2240, "Alternative Examination."

In addition, the licensee noted the staff's response to public comments on SECY-96-080 that the NRC agrees that remote examinations are the only practical method for inspecting much of the containment surface area.

The alternative examination provides that the conditions or indications for which the visual examinations are performed can be detected at the chosen distance and illumination.

Therefore, because these conditions for which the examinations are performed willcontinue be detectable, the staff finds that the alternative examinations proposed by the licensee provide an acceptable level of quality and safety and are, therefore, authorized pursuant to 10 CFR 50.55a(a)(3)(i).

3.0 CONCLUSION

Based on our review of the information provided in the requests for relief (Relief Requests RR-037 through RR-41), the staff concludes that for Relief Requests RR-40 and 41, the licensee's proposed alternatives willprovide an acceptable level of quality and safety. Therefore, the proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(i).

For Relief Requests RR-37, 38 and 39, the staff concludes that compliance with the Code requirements would result in a burden without a compensating increase in the level of quality and safety, and that licensee's proposed alternatives will provide reasonable assurance of containment pressure integrity. Therefore, these proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

Principal Contributor: T. Cheng Date:

August 16, 1999

4.0 REFERENCES

(1)

Letter, Robert C. Mecredy, RG&E to Guy S. Vissing, NRC, "Inservice Inspection Program, ASME Section XI, Required Examinations for First 10-Year Interval for Containment (IWE and IWL), Requests for Relief Nos. 37, 38, and 39 for R. E. Ginna Nuclear Power Plant,"

dated January 11, 1999.

(2)

Letter, Robert C. Mecredy, RG8E to Guy S.,Vissing, NRC, "Inservice Inspection Program, ASME Section XI, Required Examinations for First 10-Year Interval for Containment (IWE and IWL), Requests for Relief No. 40 for R. E. Ginna Nuclear Power Plant," dated January 11, 1999.

(3)

Letter, Robert C. Mecredy, RG&E to Guy S. Vissing,,NRC, "Inservice Inspection Program, ASME Section XI, Required'Examinations for First 10-Year Interval for Containment (IWE and IWL), Requests for Relief No. 41 for R. E. Ginna Nuclear Power Plant," dated January 11, 1999.

(4)

Letter, Robert C. Mecredy, RG&E to Guy S. Vissing, NRC, "Inservice Inspection Program, ASME Section XI, Requir'ed Examinations for First 10-Year Interval for Containment (IWE and IWL), Requests for Relief No. 40 for R. E. Ginna Nuclear Power Plant," dated June 21, 1999.

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