ML17309A633

Forwards 1998 Submittal of Changes to TS Bases,Reflecting Changes Per Commission Requirements for Period of 961216- 980521.W/list of Effective Pages

ML17309A633
Person / Time
Site:	Ginna
Issue date:	05/21/1998
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17265A295	List: ML17265A294 ML17309A633
References
NUDOCS 9805280189
Download: ML17309A633 (48)

Text

CATEGORY REGULAJ. RY INFORMATION DISTRIBUTI SYSTEM (RIDS)

ACCESSION NBR 9805280189 DOC DATE f98 05/21 NOTARIZED: NO DOCKET ¹ FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME MECREDY,R.C.

AUTHOR AFFILIATION Rochester Gas & Electric Corp. Xm F~

RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.

SUBJECT:

Forwards 1998 submittal of changes to TS bases, reflecting changes per Commission requirements for period of 961216-980521.W/list of effective pages.

A DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution I ENCL Q SIZE:

T NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72) . 05000244 E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-1 LA 1 1 PD1-1 PD 1 1 VISSING,G. 1 1 INTERNA . FILE CENTER 0 1 1 NRR/DE/ECGB/A 1 1

-RJ/DE/'EMe 1 1 NRR/DRCH/HXCB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 TERNAL: NOAC 1 1 NRC PDR 1 1 D

0 M

E i N

NOTE TO ALL "RZDSN RECZPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR'ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPZES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 12 'g

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Q AND ROCHESTER GAS AND EIECTRIC CORPORAT1ON ~ 89 EASTAVFNUE, ROCHESTFR, N. Y 14d9.0001 ARFA CODE'716 Q6-2700 ROBERT C. MECREDY May 21, 1998 Vice President Nvcfeor Operations U.S. Nuclear Regulatory Commission Document Control desk Attn: Guy S. Vissing Project Directorate I-1 Washington,,D.C. 20555

Subject:

Submittal of Changes to Technical Specification Bases R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Vissing:

In accordance with Technical Specification 5.5.13, Technical Specification (TS) Bases Control Program, Rochester Gas and Electric has prepared its 1998 submittal of changes to the Technical Specification Bases. Enclosed are 6 copies of the revised pages, together with a list of effective pages. Change bars indicate those revisions which have been incorporated.

The information presented in this submittal reflects changes to the Bases pursuant to commission requirements for the period of December 16, 1996 through May 21, 1998.

Ve ly yours, Robert C. Mecredy xc: Mr. Guy S. Vissing (Mail Stop 14B2)

Project Directorate I-1 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 9805280i89 98052i PDR ADQCK 05000244 P PDR

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

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pf>> w Distril 5.txt

<<s Distribution Sheet Priority: Normal I

From E-RIDS3 Action Recipients: Copies:

Internal Recipients:

FILE CENTER Ol Paper Copy External Recipients:

Total Copies: 1 Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003698053

Subject:

R E Ginna. Request relief, Containment lnsp Body:

'DAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS. The Document may also be viewed by searching for Accession Number ML003698053.

DF01 - Direct Flow Distribution: 50 Docket (PDR Avail)

Docket: 05000244 Page 1

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Dr. Robert C. Mecredy March 21, 2000 Vice President, Nuclear ations Rochester Gas and Elect Corporation 89 East Avenue Rochester, NY 14649 SUBJECT'EQUESTS FOR RELIEF NOS. 09 THROUGH 13 FROM THE AMERICAN SOCIETY OF MECHANICALENGINEERS BOILER AND PRESSURE VESSEL CODE (ASME CODE) SECTION XI REQUIREII/IENTS FOR THE R. E. GINNA NUCLEAR POWER PLANT FOURTH 10-YEA4 INTERVAL INSERVICE INSPECTION PROGRAM (TAC NO. MA6996)

Dear Dr. Mecredy:

By letter dated October 8, 1999, you requested Relief Requests Nos. 1 through 15 from certain ASME Code Section inservice examination requirements for the fourth 10-year interval inservice inspection program. Based on the information provided in the Relief Request Nos. 09 through 13, the staff concludes that for Relief Request Nos. 12 and 13, the licensee's proposed alternatives will provide an acceptable level of quality and safety. Therefore, the proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(i) For Relief Request Nos. 09, 10

~

and 11, the staff concludes that compliance with the Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, and that the 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). Enclosure 1 contains the staff's evaluation and Enclosure 2 contains the summary of relief requests. Therefore, Relief Requests 09 through 13 from the Code requirements are granted for the fourth 10-year interval.

For Relief Requests Nos. 1 through 8, 14 and 15, we are continuing our review and we will provide our determination upon completion of the review.

Sincerely,

/RA/

Marsha K. Gamberoni, Acting Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244

/'.

Enclosures:

1. Safety Evaluation

2. Summary of Reliefs Granted cc w/encls: See next page DISTRIBUTION:

IFile Center Little M. Tschiltz PUBLIC G. Vissing M. Oprendek, RGN-I PDI-1 R/F OGC E. Adensam (e-mail) G. Hill (2)

M. Gamberoni (A) ACRS with attachment/enclosure OFFZCE PDZ-1/PM DOCUMENT NAME: GAPDI-1EGInnahRELA6996.WPD To receive a copy of this document, indicate in the box:

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"C -" Copy PDZ-1/

without attachment/enclosure E Copy NAME Gvissin :lcc SLitt MGamber 6 DATE 02/ /00 02/ /00 / /0 / /00 OFFICIAL RECORD COPY srNieh, Jr., Sr. Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, NY 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. F. William Valentino, President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Nicholas S. Reynolds Winston 8 Strawn 1400 S Street N.W.

Washington, DC 20005-3502 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe'County Office of Emergency Preparedness 111 West Falls Road, Room 11 Rochester, NY 14620 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223

I

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

~rrfrrs SAFETY EVALUATIONBY THE OFFICE OF NUCLEAR REACTOR REGULATION OF RELIEF REQUESTS FROM THE AMERICAN SOCIETY OF MECHANICALENGINEERS ASME SECTION XI REQUIREMENTS FOR CONTAINMENTINSPECTION ROCHESTER GAS AND ELECTRIC CORPORATION R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244

1.0 INTRODUCTION

In the Federal Register dated August 8, 1996 (61 FR 41303), the Nuclear Regulatory Commission (NRC) amended its regulations to incorporate by reference the 1992 edition with 1992 addenda of Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). Subsections IWE and IWL provide 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. However, a licensee may propose alternatives to or submit a request for relief from the requirements of the regulation pursuant to 10 CFR 50.55a(a)(3) and (g)(5).

By letter dated October 8, 1999 (Reference 1), Rochester Gas and Electric Corporation, the licensee, proposed several alternatives to the requirements of Subsections IWE and IWL of Section XI of the ASME Code for its R. E. Ginna Nuclear Power Plant. The NRC's findings with respect to authorizing the alternatives or denying the proposed requests are discussed in this evaluation.

2.0 EVALUATION 2.1 Relief Re vest No. 09 2.1.1 Code Re uirements ASME Section XI Code, 1992 Edition, 1992 Addenda, IWE-2500, Table IWE-2500-1, Category E-D, Item Numbers E5.10 and E5.20 requires seats and gaskets on airlocks, hatches, and other devices to be visually examined, VT-3, once each interval to assure containment leak-tight integrity.

Enclosure 1

I t 2.1.2AS ecific Relief Re uested Relief is requested from performing the Code-required visual examination, VT-3, on the seals and gaskets of Class MC pressure retaining components and metallic liners of Class CC components. This relief is requested for the first inspection interval for the IWE Containment Inspection Program (1996 through 2008).

2.1.3 Basis for Relief 10 CFR 50.55a was amended in the Federal ~Re ister (61 FR 41303) to require the use of the 1992 Edition, 1992 Addenda, of Section XI when performing containment examinations. 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.

s 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, retermination 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, retermination, 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.

~For thyrse penetrations that are routinely disassembled, a Type B test is required upon final assembly and prior to start-up. Since the Type B test will assure the leak tight integrity of primary containment, the performance of the visual'examination would not provide an increase in the level of safety or quality.

Seals and gaskets are not part of the containment pressure 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 degrada-tion 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.

The visual examination of seals and gaskets in accordance with IWE-2500, Table IWE-2500-1 is a burden without any compensating increase in the level of safety or quality.

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 difficulty without a compensating increase in the level of quality and safety. Testing the seal and gasket joints in accordance with 10 CFR Part 50, Appendix J will provide adequate assurance of the leak-tight integrity of the seals and gaskets.

2.1.4 Alternative Examinations The leak testing of seal and gasket joints will be in accordance with 10 CFR Part 50, Appendix J. No additional alternative examinations to the visual examination, VT-3, of the seals and gaskets will be performed.

2.1.5 Justification for the Grantin of Relief This relief request (RR) is similar to RR E-1 submitted by Davis-Besse as one of the Electric Power Research Institute "Containment Inspection Program Guide" pilot plant RRs. This RR will minimize Ginna operating and maintenance cost without decreasing the level of quality and safety.

2.1.6 Staff Evaluation of Relief Re vest No. 09 Although the staff agrees that ASME Code rules for repair and replacement do not apply to seals and gaskets, the staff does not fully agree with the licensee's statement that penetration seals and gaskets are not part of the containment pressure boundary. However, the staff finds that the alternative examination of the containment penetration seals and gaskets (including those of electrical penetrations) proposed by the licensee 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, in lieu of performing the VT-3 examinations for containment penetration seals and gaskets, the licensee proposes to use the current program for leakage testing containment penetrations in accordance with 10 CFR Part 50, Appendix J.

The staff finds that because the seats and gaskets associated with these penetrations are not accessible for examination when the penetration is assembled, containment penetrations seals

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"and gaskets must be disassembled and reassembled for the purpose of performing the VT-3 visual examination. These activities (disassembly of the joint, removal and examination of the seals and gaskets, reassembly of the joint, retermination of the cables if necessary, post-maintenance testing of the cables, and a post-maintenance Appendix J test of the penetration) 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 will detect 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 will provide reasonable assurance of the leak-tight integrity of the containment penetration seals and gaskets during the Type B testing requiredby10 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 No.10 2.2.1 Code Re uirements Paragraphs IWE-2420(b) and IWE-2420(c) of the 1992 Edition, 1992 Addenda of ASME Section XI requires 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.

2.2.2 S ecific Relief Re uested Relief is requested from the requirements of ASME Section XI Code, 1992 Edition, 1992 Addenda, Paragraphs IWE-2420 (b) and IWE-2420(c) to perform successive examination on repairs. This relief is requested for the first inspection interval for the IWE Containment Inspection Program (1996 through 2008).

2.2.3 Basis for Relief 10 CFR 50.55a was amended in the Federal ~Rs ister (61 FR 41 303) to require the use of the 1992 Edition, 1992 Addenda, of Section XI when performing containment examinations. 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 repair 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 requir'ements 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 its resolution to public Comment ff3.3, the NRC stated within SECY 96-080 dated April 17, 1996:

"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 rhore frequent examination would not be needed."

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 repairs 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.

2.2.4 Alternate Examinations Successive examinations in accordance with paragraphs IWE-2420(b) and IWE-2420(c) are not required for repairs made in accordance with Article IWA-4000.

2.2.5 Justification for the Grantin of Relief This RR is similar to RR E-6 submitted by Davis-Besse as one of the EPRI "Containment Inspection Program Guide" pilot plant RRs. This RR will minimize Ginna operating and maintenance cost without decreasing the level of quality and safety.

2.2.6 Staff Evaluation of Relief Re uest No. 10 In lieu of meeting ASME Section XI, Subarticles IWE-2420(b) and (c) that require successive examinations of repaired areas in accordance with Table IWE-2500-1, the licensee proposes to use the process and acceptance examinations and evaluations required by the Code for repairs.

'he Staff finds 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 will provide 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 components 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 No.11 2.3.1 Code Re uirements ASME Section XI, 1992 Edition with the 1992 Addenda, Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item E8.20 requires for a bolt torque or tension testing of bolted connections that have not been disassembled and reassembled during the inspection interval.

2.3.2 S ecific Relief is Re uested Relief is requested from performing the bolt torque or tension test in accordance with Table IWE-2500-1, "Examination Categories," Examination Category E-G, "Pressure Retaining Bolting," for bolted connections that have not been disassembled and reassembled during the inspection interval. This relief is requested for the first inspection interval for the IWE Containment Inspection Program (1996 through 2008).

2.3.3 Basis for Relief 10 CFR 50.55a was amended in the Federal ~Re ister (61 FR 41 303) to require the use of the 1992 Edition, 1992 Addenda, of Section XI when performing containment examinations. 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 retorqued or retensioned. 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.

2.3.4 Alternate Examinations 4

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

(1) ~

'xposed 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 r

(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).

2.3.5 Justification for the Grantin of Relief This RR is similar to RR E-7 submitted by Davis-Besse as one of the EPRI "Containment Inspection Program Guide" pilot plant relief requests. This RR will minimize Ginna operating and maintenance cost without decreasing the level of quality and safety.

2.3.6 Staff Evaluation of Relief Re uest No. 11 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 a leak-tight seal exists and that the pressure 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 finds that compliance with ASME Code requirements will cause a hardship or an unusual difficulty because untorquing and subsequent re-torquing bolted connections which are verified to have acceptable leakage through 10 CFR Part 50, Appendix J testing does not provide an increase in the level of quality and safety. The staff also finds that the alternative approach proposed by the licensee (the test required by 10 CFR Part 50, Appendix J to verify the leak-tight integrity of bolted connections for containment vessel leak-tight integrity) will provide a reasonable assurance of the containment leak-tight integrity. On this basis, the staff concludes that the alternative proposed by the licensee is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

7 4

'.4 Relief Re uest No.12 2.4.1 Code Re uirements 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.

2.4.2 S ecific Relief Re uested Relief is requested from performing the VT-2 visual examination in connection with system pressure testing following repair, replacement or modification under Article IWE-5000. This relief is requested for the first inspection interval for the IWE Containment Inspection Program=

(1996 through 2008).

2.4.3 Basis for Relief 10 CFR 50.55a wae amended in the Federal Reriieter (61 FR 41 303) to require the uee of the 1992 Edition, 1992 Addenda, of ASME Section XI when performing containment examinations.

Paragraph IWE-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 identifies a aVT-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 construction/installation code. In addition to the construction code NDE, applicable ASME Section XI NDE pre-service NDE are 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.

Table IWE-2500-1, Examination Category E-P, identifies the examination method of 10 CFR Part 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 accordance with 10 CFR Part 50, Appendix J) will provide an acceptable level of quality and safety.

,4~ J"

'he 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 should be published in 1998.

2.4.4 Alternate Examinations Testing shall be conducted in accordance with 10 CFR Part 50, Appendix J, in lieu of Paragraph IWE-5240 of ASME Section XI, as well as performing an IWE detailed visual examination (VT-1) of the repaired or replaced area.

2.4.5 Justification for the Grantin of Relief For repairs, replacements or modifications that are performed under ASME Section XI Code, applicable construction code (or installation code) NDE are performed and must meet the acceptance criteria of the construction/installation code. In addition to the construction code NDE, applicable ASME Section XI NDE pre-service NDE are 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. This RR will minimize Ginna operating and maintenance cost without decreasing the level of quality and safety.

2.4.6 Staff Evaluation of Relief Re uest No. 12 As an alternative to 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 as well as performing an IWE detailed visual examination (VT-1) of the repaired or replaced area.

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 /installation 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 Part 50, Appendix J for the containment vessel pressure retaining boundary following each repair, replacement, or modification and does 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 will perform an IWE detailed visual examination (VT-1) 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 No.13 2.5.1 Code Re uirements 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.

2.5.2 S ecific Relief Re uested 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. This relief is requested for the first inspection interval for the IWE Containment Inspection Program (1996 through 2008).

2.5.3 Basis for Relief 10 CFR 50.55a was amended in the Federal ~Re ister (51 FR 41303) to require the use of the 1992 Edition, 1992 Addenda, of Section XI when performing containment examinations. In addition to the requirements of Subsection IWL, the rulemaking also imposes the requirements of Subsection IWA of the 1992 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 will be demonstrated capable of resolving these minimum indications to the satisfaction of the RPE and the authorized nuclear insurance inspector (ANII), as allowed in IWA-2240, "Alternative Examinations." 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. The NRC staff received seven comments that were consolidated into Public Comment ¹2.3 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

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. 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.

2.5.4 Alternate Examinations When performing remotely 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 provided, that the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination.

2.5.5 Justification for the Grantin of Relief This RR is similar to RR L-1 submitted by Calvert Cliffs as one of the EPRI "Containment Inspection Program Guide" pilot plant RRs. RR L-1 (for Calvert Cliffs) was subsequently approved by the NRC. Refer to a letter from the NRC (S. Bajwa) to Baltimore Gas and Electric (C. Cruse), dated November 16, 1998. This RR will minimize Ginna operating and maintenance cost without decreasing the level of quality and safety.

2.5.6 Staff Evaluation of Relief Re vest No. 13 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-221 0 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 will be 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 in the staff's response to

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. 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.

On the basis discussed above, 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 (RR Nos. 09 through 13), the staff concludes that for RR Nos. 12 and 13, the licensee's proposed alternatives will provide an acceptable level of quality and safety. Therefore, the proposed alternatives are authorized pursuant to 10 CFR 50.55a(a)(3)(i). For RR Nos. 09, 10 and 11, 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: Ihrch 21, 2000

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"4.0 REFERENCE Letter, R. C. Mecredy, RG&E to G. S. Vissing, NRC, "Ginna Nuclear Power Plant Inservice Inspection - ASME Section XI Required Examinations, Relief Requests," dated October 8, 1999.

Summary of Relief Requests R. E. Ginna Nuclear Power Plant Relief 10 CFR 50.55a- Recommended Request No. ASME Code Issue Identification NRC Action Remarks IWE/IWLSection 09 IWE-2500,Table VT-3 Examination on Seals and authorized IWE-2500-1 E-D Gaskets (a)(3)(ii) 10 IWE-2400(b) and Successive Examination after Repairs (a)(3)(ii) authorized I WE-2400(c)

Table IWE-2500-1, Torque/Tension Test of Pressure (a)(3)(li) authorized E-G, E8.20 Retaining Bolting 12 IWE-5240 VT-2 Examination of after System (a)(3)(i) authorized Pressure Test 13 IWL-2310 Visual Examination and Personnel (a)(3)(i) authorized Qualification Enclosure 2

Distri73.txt Distribution Sheet pal L Priority: Normal From: Stefanie Fountain Action Recipients: Copies:

Internal Reci ients:

1 Paper Copy External Recipients:

NOAC Paper Copy Total Copies:

Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003685319

Subject:

Ginna - Request for Additional Information - R.E. Ginna Nuclear Power Plant Quality Ass urance Program Description Body:

ADAMS DISTRIBUTION NOTIFICATION.

Electronic Recipients can RIGHT CLICK and OPEN the first Attachment to View the Document in ADAMS. The Document may also be viewed by searching for Accession Number ML003685319.

DF01 - Direct Flow Distribution: 50 Docket (PDR Avail)

Docket: 05000244 Page 1 APasg egg

n t Dr. Robert C. Mecredy Februar~17, 2000 Vice President, Nuclear ~rations Rochester Gas and EiectMCorporation //r'Czar o~ 7frfLCV>S'Syyr 89 East Avenue T /vR~ gyp Roc/ester, NY 14649

SUBJECT:

REQUEST FOR ADDITIONALINFORMATION - R. E. GINNA NUCLEAR POWER PLANT QUALITYASSURANCE PROGRAM DESCRIPTION (TAC NO. MA7874)

Dear Dr. Mecredy:

We have received your submittal dated December 20, 1999, which, pursuant to 10 CFR 50.54(a)(3), requests review and approval of proposed changes that reduce commitments in your Quality Assurance Program for Station Operation (QAPSO) previously approved by the Nuclear Regulatory Commission. The review is being performed by the Quality Assurance, Vendor Inspection, Maintenance and Allegations Branch in the Office of Nuclear Reactor Regulation. Your response to the enclosed request for additional information is required in order for the staff to complete its review.

Based on our need for the additional information, we do not regard the changes described in your proposed Revision 27 to the QAPSO acceptable pursuant to 10 CFR 50.54(a)(4).

Therefore, you should refrain from implementing these changes until you have been formally notified otherwise.

We have discussed these questions with your staff. Your staff has indicated that you could respond within 30 days from receipt of this letter.

If you have any questions concerning this subject, please call me at (301) 415-1441.

Sincerely,

/RA/

Guy S. Vissing, Sr. Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosure:

Request for Additional Information 4'tilt(an cc w/encl: See next page DISTRIBUTION'ile Center G. Vissing PUBLIC L. Berry PDI-1 R/F T. Quay S. Black D. Dorman E. Adensam (e-mail) OGC M. Gamberoni (A) ACRS S. Little M. Oprendek, RGN-I r'i'DZ-1/SC(A)

DOCUMENT NAME: GAGAPDI-15GinnahRAIA7874.WPD To receive a copy of this document, Indicate in the box: 'C = Copy without attachment/enclosurq 'E' Copy with attachment/enclosure 'N' No co OFFICE PDI-1/PM PDZ-1/L HQMB/BC NAME Gvissin tlcc SLitt T ua MGamberoni DATE 02/ /00 02/ /00 02/ /00 02/ /00 OFFICIAL RECORD COPY

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lf UNITED STATES J

• ~ NUCLEAR REGULATORY COMMISSION AY '" f)f WASHINGTON, D.C. 20555-0001

~ JIIlk February 17, 2000 o~

~s J/P///S Dr. Robert C. Mecredy Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649

SUBJECT:

REQUEST FOR ADDITIONALINFORMATION - R. E. GINNA NUCLEAR POWER PLANT QUALITYASSURANCE PROGRAM DESCRIPTION (TAC NO. MA7874)

Dear Dr. Mecredy:

We have received your submittal dated December 20, 1999, which, pursuant to 10 CFR 50.54(a)(3), requests review and approval of proposed changes that reduce commitments in your Quality Assurance Program for Station Operation (QAPSO) previously approved by the Nuclear Regulatory Commission. The review is being performed by the Quality Assurance, Vendor Inspection, Maintenance and Allegations Branch in the Office of Nuclear Reactor Regulation. Your response to the enclosed request for additional information is required in order for the staff to complete its review.

Based on our need for the additional information, we do not regard the changes described in your proposed Revision 27 to the QAPSO acceptable pursuant to 10 CFR 50.54(a)(4).

Therefore, you should refrain from implementing these changes until you have been formally notified otherwise.

We have discussed these questions with your staff. Your staff has indicated that you could respond within 30 days from receipt of this letter.

If you have any questions concerning this subject, please call me at (301) 415-1441.

Sincerely, Guy S. Vissing, Sr. Pr ect Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosure:

Request for Additional Information cc w/encl: See next page

R.E..Ginna Nuclear Power Plant Ho K. Mich, Jr., Sr. Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, NY 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. F. William Valentino, President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Nicholas S. Reynolds Winston & Strawn 1400 S Street N.W.

Washington, DC 20005-3502 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 111 West Falls Road, Room 11 Rochester, NY 14620 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223

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-, ',ROCHESTER GAS AND ELECTRIC CORPORATION - GINNA NUCLEAR POWER PLANT PROPOSED REVISION 27 TO THE QUALITYASSURANCE PROGRAM FOR STATION OPERATION QAPSO REQUEST FOR ADDITIONALINFORMATION Regulatory Guide (RG) 1.123, "Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants," Rev. 1, conditionally endorses ANSI N45.2.13-1976, "Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants," as an acceptable method for complying with the requirements of Appendix B to 10 CFR Part 50 with regards to the control of procurement of items and services during the design, construction, and operations phases of a nuclear power plant. ANSI N45.2.13-1976 applies to "the work of any individual or organization participating in the procurement of those items and services from which satisfactory performance is required." ANSI N45.2.13-1976 also specifies that personnel performing verification activities be certified/qualified in accordance with ANSI N45.2.6, "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants."

In your December 20, 1999, submittal you proposed to eliminate the requirement for Quality Assurance (QA) personnel to perform an in-line review of procurement documents. Your letter also states that in lieu of QA personnel, line organization personnel will perform reviews of procurement documents in accordance with approved procedures and that such personnel will be trained accordingly.

Please clarify and indicate where commitments associated with the review of procurement documents by the line organizations, including their requisite training and qualification, are currently (or will be) identified in the QAPSO.

Table 17.1.7-1, "Conformance of Ginna Station Program to Quality Assurance Standards, Requirements, and Guides" "Remarks," associated with Ginna's commitments to RG 1.33, Rev. 0, need to be clarified. For example, the text in "Substituted Criteria" does not currently reflect Ginna's proposed exception to the provisions in Section 4.3.1, "Personnel," of ANSI N18.7-1976. This table should reflect Ginna's proposal to use the provisions in ANSI/ANS-3.1-1987, Section 4.7, to define the qualification requirements for NSARB members in lieu of ANSI N18.7-1976, Section 4.3.1.

Enclosure

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Chapter 3.6 Chapter 3.6 'Chapter 3.7 Chapter 3.7 (con'd) (con'd) (cond') (con'd)

B 3.6-27 6 B 3.6-67 B 3.7-32 B 3.7-72 8 3.6-28 6 B 3.6-68 B 3.7-33 B 3.7-73 B 3.6-29 6 B 3.6-69 B 3.7-34 B 3.7-74 B 3.6-29a 6 B 3.6-70 B 3.7-35 B 3.7-75 B 3.6-30 6 B 3.6-71 B 3.7-36 B 3.7-76 B 3.6-31 6 B 3.6-72 B 3.7-37 B 3.7-77 B 3.6-32 6 B 3.7-38 B 3.7-78 B 3.6-33 0 Chapter 3.7 B 3.7-39 B 3.7-79 B 3.6-34 6 B 3.7-40 B 3.7-80 B 3.6-35 6 B 3.7-1 0 B 3.7-41 B 3.7-81 B 3.6-36 0 B 3.7-2 0 B 3.7-42 B 3.7-82 B 3.6-37 0 B 3.7-3 0 B 3.7-43 B 3.7-83 B 3.6-38 0 B 3.7-4 0 B 3.7-44 B 3.7-84 B 3.6-39 0 B 3.7-5 0 B 3.7-45 B 3.7-85 B 3.6-40 0 B 3.7-6 0 B 3.7-46 B 3.7 B 3.6-41 0 B 3.7-7 0 B 3.7-47 B 3.7-87 B 3.6-42 0 B 3.7-8 0 B 3.7-48 B 3.7-88 B 3.6-43 0 B 3.7-9 6 B 3.7-49 B 3.7-89 B 3.6-44 0 B 3.7-10 0 B 3.7-50 B 3.7-90 B 3.6-45 0 B 3.7-11 0 B 3.7-51 B 3.7-91 B 3.6-46 0 B 3.7-12 0 B 3.7-52 B 3.7-92 B 3.6-47 6 B 3.7-13 0 B 3.7-53 B 3.7-93 B 3.6-48 0 B 3.7-14 0 B 3.7-54 B 3.7-94 B 3.6-49 0 B 3.7-15 0 B 3.7-55 B 3.7-95 B 3.6-50 0 B 3.7-16 6 B 3.7-56 B 3.7-96 B 3.6-51 1 B 3.7-17 6 B 3.7-57 B 3.7-97 B 3.6-52 0 B 3.7-18 6 B 3.7-58 B 3.7-98 B 3.6-53 10 B 3.7-19 0 B 3.7-59 B 3.7-99 B 3.6-53a 10 B 3.7-20 0 B 3.7-60 B 3.7-100

, B 3.6-54 6 B 3.7-21 1 B 3.7-61 B 3.6-55 0 B 3.7-22 0 B 3.7-62 Chapter 3.8 B 3.6-56 0 B 3.7-23 6 B 3.7-63 B 3.6-57 0 B 3.7-24 0 B 3.7-64 'B 3.8-1 B 3.6-58 0 B 3.7-25 0 B 3.7-65 B 3.8-2 B 3.6-59 0 B 3.7-26 0 B 3.7-66 B 3.8-3 B 3.6-60 0 B 3.7-27 5' B 3.7-67 B 3.8-4 B 3.6-61 0 B 3.7-28 B 3.7-68 B 3.8-5 B 3.6-62 0 B 3.7-29 5 B 3.7-69 B 3.8-6 B 3.6-63 0 B 3.7-30 5 B 3.7-70 B 3.8-7 B 3.6-64 1 B 3.7-31 6 B 3.7-71 B 3.8-7a B 3.6-65 1 B 3.8-8 B 3.6-66 0 B 3.8-8a LEP-vii

Page Rev. Page Rev. Page Rev. Page Chapter 3.8 Chapter 3.8 Chapter 3.9 (con'd) (con'd)

B 3.8-9 B 3.8-50 9 B 3.9-1 0 B 3.8-10 B 3.8-51 0 B 3.9-2 0 B 3.8-11 B 3.8-52 0 B 3.9-3 0 B 3.8-12 B 3.8-53 0 B 3.9-4 6 B 3.8-13 0 B 3.8-54 0 B 3.9-5 10 B 3.8-14 0 B 3.8-55 6 B 3.9-6 0 B 3.8-15 ,0 B 3.8-56 0 B 3.9-7 1 B 3.8-16 7 B 3.8-57 0 B 3.9-7a 1 B 3.8-17 6 B 3.8-58 0 B 3.9-8 6 B 3.8-18 B 3.8-59 0 B 3.9-9 1 B 3.8-19 B 3.8-60 0 B 3.9-10 2 B 3.8-20 B 3.8-61 0 B 3.9-11 2 B 3.8-21 B 3.8-62 0 B 3.9-12 0 B 3.8-22 B 3.8-63' 0 B 3.9-13 2 B 3.8-23 3.8-64 0 B 3.9-14 6 B 3.8-24 B 3.8-65 0 B 3.9-15 0 B 3.8-25 B 3.8-66 6 B 3.9-16 0 B 3.8-26 B 3.8-67 6 B 3.9-17 6 B 3.8-27 B 3.8-68 6 B 3.9-18 6 B 3.8-28 B 3.8-69 6 B 3.9-19 0 B 3.8-29 B 3.8-70 0 B 3.9-20 0 B 3.8-30 B 3.8-71 0 B 3.9-21 0 B 3.8-31 B 3.8-72 0 B 3.9-22 9 B 3.8-32 B 3.8-73 0 B 3.9-22a 10 B 3.8-33 B 3.8-74 0 B 3.9-23 6 B 3.8-34 B 3.8-75 6 B 3.9-24 0 B 3.8-35 B 3.8-76 6 B 3.9-25 0 B 3.8-36 3.8-76a 6 B 3.9-26 0 B 3.8-37 B 3.8-77 0 B 3.9-27 0 B 3.8-38 B 3.8-78 0 B 3.9-28 0 B 3.8-39 B 3.8-79 6 B 3.8-40 B 3.8-80 0 B 3.8-41 B 3.8-81 6 B 3.8-42 B 3.8-82 0 B 3.8-43 B 3.8-83 0 B 3.8-44 B 3.8-84 0 B 3.8-45 B 3.8-85 0 B 3.8-46 10 B 3.8-86 3 B 3.8-46a 10 B 3.8-87 10 B 3.8-47 0 B 3.8-88 3 B 3.8-48 10 B 3.8-89 3 B 3.8-48a 9 B 3.8-90 6 B 3.8-49 0 LEP-viii