ML17291A135

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Forwards SE Denying Licensee 930624 Relief Request 2-ISI-001 & Granting Relief Request 2-ISI-010 Re Inservice Insps
ML17291A135
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 06/08/1994
From: Quay T
Office of Nuclear Reactor Regulation
To: Parrish J
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
Shared Package
ML17291A136 List:
References
TAC-M87253, NUDOCS 9406170015
Download: ML17291A135 (10)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 8,

1994 Docket No. 50-397 Hr. J.

V. Parrish (Hail Drop 1023)

Assistant Managing Director, Operations Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968

Dear Hr. Parrish:

SUBJECT:

INSERVICE INSPECTION RELIEF REQUESTS WPPSS NUCLEAR PROJECT NO, 2

(TAC NO. M87253)

Your June 24,

1993, and August 26, 1993, letters requested relief from some American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI inservice inspection (ISI) requirements.

Relief request 2-ISI-001 concerns less-than-100-percent volumetric examination of one reactor pressure vessel shell weld.

Relief request 2-ISI-010 involves inaccessible reactor-pressure-vessel-to-nozzle welds.

You also requested we approve a

revision to your ISI Program to use the ASHE Section XI 1989 Edition for examining valve body internals.

We deny relief request 2-ISI-001.

You are required by 10 CFR 50.55a(g)(6)(ii)(A)(5) to give us information about alternatives to the 10 CFR 50.55a(g)(6)(ii)(A) required examinations if you are unable to completely satisfy those requirements.

We did not receive this information.

Please propose alternative augmented reactor vessel shell weld examination requirements if you want us to reconsider relief request 2-ISI-001.

We grant relief for relief request 2-ISI-010 pursuant to 10 CFR 50.55a(g)(6)(i).

We also approve your ISI Program revision pursuant to 10 CFR 50.55a(g)(6)(i),

based on your commitment to implement all related requirements from the 1989 Code edition.

In granting this relief, the NRC has determined that the relief granted is authorized by law, 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

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V. Parrish could result if the requirements were imposed on the facility.

The enclosed safety evaluation contains our evaluations and conclusions for these issues.

Sincerely,

Enclosure:

Safety Evaluation cc w/enclosure:

See next page Theodore R.

Quay, Director Project Directorate IV-3 Division of Reactor Projects III/IV Office of Nuclear React'or Regulation DISTRIBUTION

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V. Parrish could result if the requirements were imposed on the facility.

The enclosed safety.evaluation contains our evaluations and conclusions for these issues.

Sincerely,

Enclosure:

Safety Evaluation cc w/enclosure:

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Theodore R.

Quay, Director Project Directorate IV-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation DISTR I BUT ION Docket File EAdensam JRoe TQuay ACRS (10),

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Nr. J.

V. Parrish could result if the requirements were imposed on the facility.

The enclosed safety evaluation contains our evaluations and conclusions for these issues.

Sincerely, Theodore R. quay, Director Project Directorate IV-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation cc w/enclosure:

See next page

Hr. J.

V. Parrish WPPSS Nuclear Project No.

2 Washington Public Power Supply System (WNP-2)

CC:

Hr. J.

H. Swailes WNP-2 Plant Manager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 G.

E.

C.

Doupe, Esq.

(Hail Drop 396)

Washington Public Power Supply System 3000 George Washington Way P. 0.

Box 968

Richland, Washington 99352-0968 Hr. Warren Bishop, Chairman Energy Facility Site Evaluation Council P. 0.

Box 43172 Olympia, Washington 98504-3172 Mr. H. K. Kook (Hail Drop PE20)

WNP-2 Licensing Manager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 Hr. Paul R.

Bemis (Hail Drop PE20)

Regulatory Programs Manager Washington Public Power Supply System P. 0.

Box 968

Richland, Washington 99352-0968 Regional Administrator, Region IV U.S.

Nuclear Regulatory Commission Harris Tower

& Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Chairman Benton County Board of Commissioners P. 0.

Box 190

Prosser, Washington 99350-0190 Hr.

R.

C. Barr U. S. Nuclear Regulatory Commission P. 0.

Box 69

Richland, Washington 99352-0968 H.

H. Philips, Jr.,

Esq.

Winston 8 Strawn 1400 L Street, N.W.

Washington, D.C.

20005-3502

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'AFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR FIRST 10-YEAR INTERVAL INSERVICE INSPECTION RELIEF RE UESTS WASHINGTON PUBLIC POWER SUPPLY SYSTEM WPPSS WPPSS NUCLEAR PROJECT NO.

2 DOCKET NUMBER 50-397

1. 0 INTRODUCTION The WPPSS Nuclear Project No.

2 (WNP-2) Technical Specifications require the utility to perform inservice inspection (ISI) and testing of American Society of Mechanical Engineers (ASHE)

Code Class 1, 2, and 3 components in accordance with ASHE Boiler and Pressure Vessel Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components,"

including applicable Addenda as required by 10 CFR 50.55a(g),

except where the NRC grants specific written relief pursuant to 10 CFR 50.55a(g)(6)(i).

Paragraph 50.55a(a)(3) of Title 10 of the Code of Federal Regulations allows the utility to use alternatives to paragraph (g) requirements when the NRC authorizes the alternatives.

The NRC may do this if (1) the proposed alternatives provide acceptable levels of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the quality and safety levels.

Paragraph 50.55a(g)(4) of Title 10 of the Code of Federal Regulations specifies that ASHE Code Class 1, 2, and 3 components (including supports) shall meet ASHE Code,Section XI requirements to the extent practical within the limitations of component design,

geometry, and construction material.

The regulations (10 CFR 50.55a(g)(4)(ii)) require that component inservice examinations and system pressure tests comply with the requirements in the latest ASHE Code Section XI edition and addenda referred to 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.

ASHE Code Section XI 1980 Edition, through Winter 1980 Addenda applies to the WNP-2 first 10-year ISI interval.

Components (including supports) may meet the requirements in subsequent ASHE Code editions and addenda referred to in 10 CFR 50.55a(b),

subject to the limitations and modifications listed therein, if approved by the NRC.

Paragraph 50.55a(g)(5)(iii) of Title 10 of the Code of Federal Regulations allows WPPSS (the licensee) to request relief from ASHE Code requirements.

To do this, the licensee must (1) determine that conforming to an ASHE Code Section XI examination requirement is not practical for its facility, and (2) submit information to the NRC supporting that determination.

Paragraph 50.55a(g)(6)(i) allows the NRC to grant relief and impose certain alternative examination requirements after evaluating the licensee's determination.

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The licensee submitted revised Relief Request 2-ISI-001 and new Relief Request 2-ISI-010 in a [[letter::05000397/LER-1992-034, :on 920713,determined That Nonwater Tight Penetration Seals in ECCS Pump Rooms Could Result in Common Mode Failure from Flooding.Inadequate Penetration Seals in ECCS Pump Rooms Except for Door Seals Reworked|June 24, 1993, letter]] for the WNP-2 first 10-year ISI interval that ends in December 1994.

Additionally, the licensee submitted a proposed ISI program revision regarding ASME Class 1 valve body examinations in a August 26, 1993, letter.

2.0 EVALUATION AND CONCLUSIONS The NRC staff and the Idaho National Engineering Laboratory (INEL) technical assistance contractor evaluated the licensee's information supporting its Relief Request Nos. 2-ISI-001 and 2-ISI-010, and proposed ISI program revision.

Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the Technical Evaluation Summary attached.

Relief Re uest No. 2-ISI-001 The licensee did not propose an alternative to the regulatory requirement for the RPV shell weld or propose to complete the remaining examinations from the inside of the reactor vessel in Relief Request No. 2-ISI-001.

The licensee is required to propose such an alternative to the Code requirements pursuant to 10 CFR 50.55a(g)(6)(ii)(A)(5).

The licensee has not proposed such alternatives as yet.

The staff notes, further, that 10 CFR 50.55a(g)(6)(ii)(A)(3) allows a licensee with fewer than 40 months remaining in the ISI interval in effect September 8,

1992 (WNP-2's interval ends December 1994), to defer the augmented reactor vessel examination specified in 10 CFR 50.55a(g)(6)(ii)(A) to the end of the first period of the next inspection interval, under certain conditions.

Therefore, this item remains open until the first period of the next inspection interval.

The licensee is required to address this issue either (1) by proposing to complete the remaining inspections from the inside of the reactor vessel or (2) by proposing an alternative to the Code requirement that provides an acceptable level of quality and safety if they are unable to complete the examinations.

Relief Re uest No. 2-ISI-010 The licensee requested relief from the Code-required 100% volumetric examination for 27 reactor pressure vessel nozzle welds in Relief Request No. 2-ISI-010.

In addition, the licensee proposed to examine the accessible portion of each nozzle weld in accordance with ASNE Code Section XI as augmented by Regulatory Guide 1. 150, Revision 1, Appendix A.

The accessible portion of these welds is considered to be a reasonably large and representative examination

sample, which reasonably assures continued nozzle integrity.

Therefore, we grant Relief Request No. 2-ISI-010 pursuant to 10 CFR 50.55a(g)(6)(i).

Pro osed ISI Pro ram Revision The licensee's proposed revision to updating the program from the current Code of record (ASNE Section XI, 1980 Edition, Winter 1980 Addenda) to ASHE Section XI, 1989 Edition for Class 1 valve body internal examinations is approved, based on the licensee's commitment to implement all related requirements from the later Code.

Attachment:

Technical Evaluation Report Principal Contributor:

T. K. HcLellan Date:

3une 8, i994