ML17333A762
| ML17333A762 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/30/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17333A761 | List: |
| References | |
| NUDOCS 9702050255 | |
| Download: ML17333A762 (4) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASMINGTON, D.C. 2055&0001 Y
VALUAT ON BY T OF C
0 NUCLEAR R ACTOR REGULA ON E UES S
FOR RELI F TO US ASME ANS OH CO E 1995 FOR SNUBBER TESTING INDIANA MICHIGAN POWER COMPANY DONALD C.
COOK NUCLEA LANT UN NOS.
ND 2 DOCKET NOS. 50-3 5 AND 50-316 T.il
~IIITRO UUTIIIR The Code of Federal Regulations, 10 CFR 50.55a, requires that inservice inspection (ISI) of certain ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME 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 requesting relief, the licensee must demonstrate that the requirement is impractical for their facility.
In proposed alternatives, the licensee must demonstrate that (i) the proposed alternatives provide an acceptable level of quality and safety or (ii) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Additional requirements for the ISI of snubbers are contained in the Technical Specifications (TS).
In addition to reiterating the requirements of 10 CFR 50.55a, the TS provide specific requirements for: visual inspections, visual inspection acceptance criteria, functional tests, hydraulic snubbers functional test acceptance criteria, and snubber service life monitoring.
Section 50.55a authorizes the Commission to grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's finding with respect to granting or not granting the relief request as part of the licensee's ISI program is contained in this Safety Evaluation (SE).
This SE evaluates a letter dated June 14,
- 1996, from the Indiana Michigan Power Co., requesting approval to use the ASME/ANSI OM Code-1995, Subsection ISTD, as an alternative to the ASME B&PV Code,Section XI, requirements.
The licensee's snubber testing program, third ten-year ISI interval, is based on the requirements of Section XI of the ASME B&PV Code, 1989 Edition and Addenda through 1988.
The 1989 Edition of the ASME B&PV Code,Section XI, defers snubber examination and testing requirements to ASME/ANSI OMa-1988, Part 4.
R.R EEELIEF RE UE T By letter dated June 14, 1996, the licensee requested relief from performing snubber examination and performance testing in accordance with the ASME B&PV
- Code,Section XI, requirements as defined in ASME/ANSI OMa-1988, Part 4, except for steam generator snubbers.
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2.1 icensee's ro osed Alternative During the snubber testing program third ten-year ISI interval the licensee proposes to use ASME/ANSI OM Code-1995, Subsection ISTD, in lieu of ASME OMa-1988, Part 4, requirements for snubber examination and testing, except for the steam generator
- snubbers, for the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2.
2.2 ce see's asis for Re uested e ief The NRC staff developed Generic Letter (GL) 90-09, "Alternative Requirements For Snubber Visual Inspection Intervals and Corrective Actions," to provide an alternative to the existing excessively-restrictive inspection schedule for snubber visual inspections.
The Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2 Technical Specifications have been revised to incorporate the GL 90-09 inspection schedule recommendations.
The ASME/ANSI OM Code-1995, Subsection ISTD, includes the guidance of GL 90-09 and is consistent with the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2 revised TS.
The flexibilityprovided in the inspection schedule requirements of the ASME/ANSI OM Code-1995, Subsection ISTD, will result in a reduction of the occupational radiation exposure by as much as 50X.
The ASME/ANSI OM Code-1995, Subsection ISTD, provides an acceptable level of quality and safety and will have no adverse impact on public health and safety.
3.0 VALUATION The staff developed GL 90-09 to provide 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 on 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.
The staff determined that the visual inspection schedule of GL 90-09 is an acceptable alternative and encouraged licensees to amend the TS to include GL 90-09 snubber visual inspection criteria.
By letter dated May 1,
- 1992, as supplemented June 18, 1993, the licensee submitted a request for an amendment to the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2 TS, to change the snubber visual inspection intervals and corrective actions in the TS surveillance requirements to the alternative criteria provided in GL 90-09.
The proposed amendments to the TS were approved and issued as Amendment Nos.
173 and 156 for Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2, respectively, by NRC letter dated July 9, 1993.
The staff has determined that the proposed use of ASME/ANSI OM Code-1995, Subsection ISTD, provides an acceptable level of quality and safety since it is consistent with the guidance provided by the staff in GL 90-09.
- However, although the ASME/ANSI OM Code-1995 was approved by the Board of National Standards and Codes and issued by ASME on February 28, 1995, it has not been generically approved for use by the NRC.
Ongoing 10 CFR 50.55a rulemaking
involving the OH Code is expected to be endorsed for publication in the Code of Federal Regulations in 1998.
Accordingly the staff's approval of this relief request is granted on an interim basis pending staff review and approval of the ASIDE/ANSI OH Code-1995 on a generic basis.
At such time, the interim nature of the staff's approval will cease.
0 CONC The staff concludes that an interim approval of the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i),
in that the proposed alternative will provide an acceptable level of quality and safety.
Principal Contributor:
F. Grubelich Dated:
january 30, 1997
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