ML17291A635
| ML17291A635 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/01/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17291A633 | List: |
| References | |
| NUDOCS 9502080232 | |
| Download: ML17291A635 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 Enclosure 1
SAFETY V LUATION BY THE OFFICE OF NUCLEAR REACTOR REGU ATION OF THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AMENDMENT 1 AND ASSOCIATED RE UESTS FOR RELIEF FOR WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO.
2 DOCKET NO. 50-397
- 1. 0 INTRODUCTION The Technical Specifications for WPPSS Nuclear Project No.
2 (WNP-2) state that the inservice inspection of the American Society of 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 required by 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).
Section 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 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 WNP-2 first 10-year inservice inspection (ISI) interval is the 1980 Edition through Winter 1980 Addenda.
In addition, the licensee has adopted the 1980 Edition, Winter 1981 Addenda for IWF-3400; the 1983 Edition, Winter 1983 Addenda for IWA-2300(a)(l) and Category C-F; and the 1986 Edition for IWB-3600 and Generic Letter (GL) 88-01.
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.
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Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement.
After evaluation of the determination, pursuant 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 a letter dated May 27, 1993, the licensee submitted to the NRC its First 10-Year Interval Inservice Inspection Program Plan, Amendment 1 and associated requests for relief for WNP-2.
2.0 EVALUATION AND CONCLUSIONS The staff, with technical assistance from its contractor, the Idaho National Engineering Laboratory (INEL), has evaluated the information provided by the licensee in support of its First 10-Year Interval Inservice Inspection Program
- Plan, Amendment 1 and associated requests for relief for WNP-2.
Based on the information submitted, the staff adopts the contractor's conclusions and recommendations presented in the associated Technical Evaluation Letter Report that is provided in Enclosure 2 to this letter.
Based on the information provided by the licensee, no deviations from regulatory requirements or commitments were identified regarding the first interval Inservice Inspection Program Plan for the h'ashington Public Power Supply System Nuclear Project No. 2.
Requests for Relief Nos. ISI-2-007, ISI-2-008, and ISI-2-009 were administratively incorporated into Amendment 1
of the ISI program plan.
These requests for relief were previously submitted by the licensee and approved by the NRC in its safety evaluations (SEs) dated May 27,
- 1992, May 16,
- 1989, and March 3, 1992, respectively.
By [[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|letter dated June 24, 1993]], the licensee submitted revised Request for Relief No. 2-ISI-001 that addressed the reactor vessel shell welds, and new Request for Relief No. 2-ISI-010 that addressed the reactor pressure vessel nozzle welds.
These requests for relief were evaluated by the NRC in an SE dated June 8, 1994.
In the NRC SE dated June 8,
- 1994, Request for Relief No. 2-ISI-001 was denied and Request for Relief No. 2-ISI-010 was granted.
In a meeting at NRC Headquarters on November 2, 1994, the licensee indicated that in the near future it will submit an alternative to the reactor vessel shell welds examinations pursuant to 10 CFR 50.55a(6)(ii)(A).
The licensee's first 10-year inservice inspection interval ends December 1994.
This interval was recently extended by no more than 6 months in the licensee's letter dated December 1,
1994.
According to the SE dated June 8, 1994, the licensee is to resolve this issue prior to the end of the first period of the second 10-year inservice inspection interval.
Principal Contributor:
T. McLellan Date:
February i, 1995
Enclosure 2
TECHNICAL EVALUATION LETTER REPORT ON THE IRST 10-YEAR I SERVICE INSPECTION INTERVAL MENDMENT 1 WASHINGTON PUBLIC OWER SUPPLY S
STEM NUCLEAR PROJECT 0.
2 DOCKET NO. 50-397
- 1. 0 INTRODUCTION By letter dated May 27,
- 1993, Washington Public Power Supply System (WPPSS) submitted Amendment No.
1 to the first interval Inservice Inspection Program Plan for She h(PPSS Nuclear Project No. 2.
The first 10-year inservice inspection (ISI) interval will end on December 13, 1994.
The Idaho National Engineering Laboratory (INEL) staff has evaluated Amendment 1 to the program in the following sections.
- 2. 0 EVALUATION
'he licensee provided information, as applicable, on changes in Amendment 1 of the Inservice Inspection Program Plan for She washington Public Power Supply System Nuclear Project No. 2.
Revision 0 of the Program Plan was found acceptable for implementation by the NRC.'he Code of record for WNP-2, first 10-year interval, is the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel
- Code,Section XI, 1980 Edition, Winter 1980 Addenda.
In addition, the licensee has adopted the 1980 Edition, Winter 1981 Addenda for IWF-3400; the 1983 Edition, Winter 1983 Addenda for IWA-2300(a)(l) and Category C-F; and the 1986 Edition for IWB-3600 and Generic Letter (GL) 88-01.
These Code editions and addenda have been incorporated as allowed by 10 CFR 50.55a(b).
The INEL staff has reviewed Amendment 1 to the Inservice Inspection Program.
Amendment 1 replaces Revision 0 of the ISI Program Plan in its entirety.
As stated by the licensee, the changes made in Amendment 1 consist primarily of editorial, retyping, and additions or modifications to existing commitments, where NRC approval has already been granted.
All changes in this amendment that modified or changed existing commitments made to the NRC were reviewed and approved under separate submittals; Significant changes to the ISI program have been noted below.
A.
Pro ram Chan es (a)
The licensee updated its commitment to GL 88-01 in "Alternated Schedule for IGSCC Inspections,"
which was reviewed and approved by the NRC by letter dated January 19, 1993.
'Safety Evaluation Report On 1st Ten-Year Interval Inspection Program and On Requests for Relief From Certain Requirements, transmitted by letter dated March 27, 1987.
(b) Volume 2 of the ISI Program originally contained "Weld and Component Diagrams" and "Inspection Schedule."
In Amendment 1, Volume 2 contains "Inspection Schedule" and Volume 3 contains "Weld 5 Component Diagrams."
Code Cases The licensee has adopted three additional Code cases that are approved by the NRC for general use by reference in Regulatory Guide 1. 147, Inservice Inspection Code Case Acceptability.
These are:
(a)
Code Case N-416, Alternative Rules for Hydrostatic Testing of Repair or Replacement of Class 2 Piping; (b)
Code Case N-460, Alternative Examination Coverage of Class 1 and Class 2 h(elds; and (c)
Code Case N-498, Alternative'Rules for 10-Year Hydrostatic Pressure Testing for Class 1 and 2 Systems.
Re uests for Relief (a)
The licensee updated the ISI Program with two additional requests for relief that had been previously submitted yd approved.
These are Request for Relief ISI-2-008 and ISI-2-009 (b) The licensee has made the following commitments to submit requests for relief in Amendment 1 (as stated):
(1)
Relief Request 2-ISI-001 will be modified after the vessel examinations are completed at R8 or R9 to reflect requirements in August 6,
- 1992, 10 CFR 50.55a.
This regulation revoked all relief requests for the RPV [reactor pressure vessel] shell welds and requires plants to perform 100X examination.
WNP-2 can perform lOOX examination on almost all of these welds.
The exact percentages will be known at the conclusion of the examination during R8 or R9.
(2)
A new relief request will be submitted to NRC prior to December 13, 1994, to identify the volume of RPV nozzle welds that could be examined.
The extent of these examinations was reported in the 1992 ISI Summary Report, which was submitted to the NRC.
NOTE:
By [[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|letter dated June 24, 1993]], the licensee submitted revised relief request 2-ISI-001 that addressed the reactor vessel shell IWA-5244, Buried Piping; NRC approval, date:
Hay 16, 1989 Use of Code Case N-498 for hydrostatic testing; NRC approval date:
March 3, 1992 welds, and new relief request 2-ISI-010 that addressed the RPV nozzle welds.
These relief requests were evaluated by the NRC in a Safety Evaluation (SE) dated June 8, 1994.
In the NRC SE dated June 8, 1994, request 2-ISI-001 was denied because the licensee did not address the requirements of 10 CFR 50.55a(g)(6)(ii)(A) with respect to proposed alternatives; relief request 2-ISI-010 was granted.
In a meeting at NRC Headquarters on November 2, 1994, the licensee indicated that in the near future it will submit an alternative to the reactor vessel shell welds examinations pursuant to 10 CFR 50.55a(6)(ii)(A).
The licensee's first ten-year inservice inspection interval ends December
- 1994, and as indicated in the NRC SE dated June 8, 1994, the licensee must res'olve this issue prior to the end of the first period of the second ten-year inservice inspection interval which will occur in April 1998.
(c) The snubber testing program has been removed from the ISI Program.
The ISI Program Plan now references the Technical Specifications where the snubber testing program is described.
This change was made to eliminate any chance of making conflicting commitments in the ISI Program.
The safety-related snubber list remains in the ISI Program Plan as Table 6-2.
This change was documented in Request for Relief ISI-2-007, approved in its final form by the NRC in a letter dated May 27, 1992.
- 3. 0 CONCLUSION The INEL staff has reviewed Amendment 1 to the first interval Inservice Inspection Program Plan for the washington Public Power Supply System Nuclear Project No. 2.
Based on this review, no deviations from regulatory requirements or commitments were identified.
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