ML17292A396
| ML17292A396 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/01/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17292A395 | List: |
| References | |
| NUDOCS 9608070304 | |
| Download: ML17292A396 (5) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AF VA U T ON Y TH OFFICE OF NUCLEAR REACTOR REGULATIO RE AT D TO HE INSERVICE INSPECTION PROGRAM RE UEST FOR RELIEF W
S INGTON PUBLIC POWER SUPP Y SYSTE UCL AR PROJECT NO.
2 WNP-4 DOCKET NO. 50-397
1.0 INTRODUCTION
The Code of Federal Regulations, 10 CFR 50.55a, requires that inservice inspection (ISI) of certain ASHE Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASHE Boiler and Pressure Vessel (B&PV) Code applicable Edition and Addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to paragraph 10 CFR 50.55a(g)(6)(i),
or alternatives approved pursuant to 10 CFR 50.55a(a)(3).
In proposed alternatives, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety; or (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
In requesting relief, the licensee must demonstrate that the requirement is impractical for its facility.
NRC guidance contained in Generic Letter (GL) 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions," provided alternatives to the Code requirements determined to be acceptable to the staff.
Section 50.55a authorizes the Commission to grant relief from ASME Code requirements upon making the necessary findings.
This safety evaluation covers a proposed alternate snubber examination
- method, as described in Relief Request 2ISI-11 Revision 0, dated December
- 1994, enclosed in Washington Public Power Supply System's letter dated December 27,
- 1994, as supplemented by letter dated Hay 15, 1995.
The licensee's ISI program is based on the requirements of Section XI of the ASME Boiler and Pressure Vessel
- Code, 1989 Edition.
The 1989 Edition of the ASME Boiler and Pressure Vessel
- Code,Section XI, Subarticle IWF-5300, Paragraph (a) requires that inservice snubbe~
examinations be performed in accordance with the first Addenda to ASHE/ANSI OH-1987, Part 4, using the VT-3 visual examination method described in paragraph IWA-2213.
l.l IUUAUAT I
The licensee requests relief from the visual inspection requirements of the ASHE Boiler and Pressure Vessel
- Code,Section XI, Subarticle IWF-5300, Paragraph (a) for snubbers at Washington Public Power Supply System Nuclear Project No.
2 (WNP-2).
9608070304 96080k A
PDR ADGCK 05000397 8
Licensee's Basis for Re uested Relief Snubber visual examinations are currently performed under WNP-2 Technical Specification (TS) 3/4.7.4.
TS 3/4.7.4 was previously amended to revise the visual inspection requirements to be consistent with the guidance contained in GL 90-09.
The GL 90-09 alternative guidance alleviated expenditure of unnecessary resources and reduced radiological exposure for the WNP-2 snubber visual inspection schedules.
The implementation of ASME/ANSI OM-1987 would return the WNP-2 snubber examination program to the state which existed prior to the publication of GL 90-09, effectively cancelling the benefits afforded by the GL.
The current WNP-2 TS provides a level of quality and safety equal to or greater than the requirements of the Code.
The Code requires shortened examination interval's of a failure mode grouping of snubbers that have the characteristics of the snubbers which failed visual inspections.
- However, the TS program requires all snubbers in the population placed in the shortened inspection interval.
Licensee's Pro osed Alternate Method The licensee
- proposes, as an alternative to the visual examinations required by the ASME Boiler and Pressure Vessel
- Code,Section XI, Subarticle IWF-5300, Paragraph (a), to perform WNP-2 snubber visual inspections in accordance with TS 3/4.7.4.
Discussion The staff developed GL 90-09, in part, to reduce unnecessary radiological exposure.
GL 90-09 provides an alternate schedule for snubber visual inspections that maintains the same confidence level as the existing inspection intervals and allows for inspections and corrective actions during plant outages.
The GL 90-09 guidance inspection interval is based on the number of unacceptable snubbers of the last inspection in proportion to the size of the various snubber populations or categories.
The required current interval for visual inspection is based only on the number of unacceptable snubbers found during the last inspection without regard to the snubber population.
Licensees with a large population of snubbers find that the visual inspections are excessively restrictive, expend a significant amount of resources, and subject plant personnel to unnecessary exposure.
The visual inspection provides for detection of impaired functional ability caused by physical
- damage, leakage, corrosion, or'egradation from environmental exposure or operating conditions.
The staff determined that the visual
-inspection schedule of GL 90-09 is an acceptable alternative and encouraged licensees to request changes to their TS to be consistent with this guidance.
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By letter dated January 18, 1991, the licensee submitted a request for an amendment to WNP-2 TS 3/4.7.4 with regard to snubber surveillance.
The amendment revised the snubber visual examination requirements to be consistent with the guidance contained in GL 90-09.
The proposed amendment to the TS was approved and issued as Amendment 91 to the WNP-2 TS by NRC letter dated Apri1 1 1, 1991.
WNP-2 TS 3/4.7.4 specifies a snubber surveillance program that includes visual inspection and functional test requirements to demonstrate snubber operability performance.
The visual inspection requirements of TS 3/4.7.4 provide an acceptable level of quality and safety and.are acceptable as an alternative to ASME Boiler and Pressure Vessel
- Code,Section XI, Subarticle IWF-5300, Paragraph (a) requirements.
3.0 CONCLUSION
S The staff concludes that the licensee's proposal to perform snubber inservice visual inspections in accordance with WNP-2 TS 3/4.7 '
is acceptable as an alternate method to the inservice examination requirements of the ASME Boiler and Pressure Vessel
- Code,Section XI, Subarticle IWF 5300, Paragraph (a).
Accordingly, the staff authorizes use of the alternative proposed by the licensee pursuant to 10 CFR 50.55a(a)(3)(i),
in that the alternative provides an acceptable level of quality and safety.
Principal Contributor:
F. Grubelich Date:
August 1, 1996
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