ML17333A931
| ML17333A931 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/03/1997 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:0969BC, AEP:NRC:969BC, NUDOCS 9707080337 | |
| Download: ML17333A931 (8) | |
Text
CATEGORY 1 REGULATO' INFORMATION DISTRIBUTION +TEM (RIDE)
ACCFBBION NBR:9707080337 DOC.DATE: 97/07/03 NOTARIZED: NO DOCKET FACILl50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 60-316 Donald C.
Cook Nuclear Power Plant, Unit 2,.Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
indiana Michigan Power Co. (formerly Indiana a Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Requests relief from requirements of section XI of ASME Code for IST of SG snubbers for third ten yr testing interval.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief, from ASME Code GL-8 -04 NOTES:
RECIPIENT ID CODE/NAME PD3-3 LA HICKMANFJ COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME PD3-'3 PD COPIES LTTR ENCL 1
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NUDUCS-ABSTRACT 1
RES/DET/EIB 1
1 EXTERNAL: LITCO ANDERSON NRC PDR 1
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1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK@
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED:
LTTR
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Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 491071395 INOMNA MICNIGAItI POlMQ July 3, 1997 AEP:NRC:0969BC Docket Nos.:
50-315 50-316 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555 Gentlemen:
Donald C.
Cook Nuclear Plant Units 1 and 2
REQUEST FOR ASME CODE RELIEF STEAM GENERATOR SNUBBER TESTING The purpose of this letter is to request relief from the requirements of section XI of the ASME code for the in-service testing of steam generator snubbers for the third ten year testing interval.
In accordance with 10 CFR 50.55a(f)(4)(ii),
Cook Nuclear Plant's third ten year in-service test interval must meet the requirements of ASME section XI, 1989 edition.
The requirements for snubber testing are given in ASME/ANSI OMa-1988, part 4.
We are requesting approval to use the 1995 OM code for steam generator snubber testing.
The 1995 OM code edition has a less restrictive inspection schedule than that given in OMa-1988,.in that it incorporates the alternative inspection schedule recommended in Generic Letter (GL) 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions".
GL 90-09, which was the basis for unit 1 technical specification amendment
- 173, and unit 2 technical specification amendment
- 156, provided a
visual inspection schedule that would reduce occupational radiation exposure and is highly cost effective.
A similar request has been approved for large and small bore piping snubbers (AEP:NRC:0969AT, dated June 14, 1996).
The steam generator snubbers were specifically excluded from the earlier relief request in anticipation of elimination by analysis.
The analysis was not completed due to economic considerations.
The relief request, included as the attachment to this letter, is submitted under provisions of 10 CFR 50.55a(3)(i) as an alternative test that provides an acceptable level" of quality and safety.
We request approval of the relief request by September 15,
- 1997, so it Pg1
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9707080337 970703,7 PDR AOOCK 050OC315 p
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U. S. Nuclear Regulatory Commission Page 2
AEP:NRC:0969BC may be implemented during the unit 2 refueling outage scheduled for September 1997.
E. E. Fitzpatrick Vice President vlb Attachment A. A. Blind A. B. Beach MDEQ -
DW 6 RPD NRC Resident Inspector J.
R. Padgett
ATTACHMENT TO AEP:NRC:0969BC REQUEST FOR ASME CODE RELIEF -
SNUBBER TESTING
Attachment to AEP:NRC:0969BC
'I Page 1
SYSTEM COMPONENT FOR WHICH RELIEF IS RE UESTED Code relief is requested from performing examination and performance testing of nuclear power plant dynamic restraints (snubbers) in accordance with ASME OM code, part 4, version OMa-1988, during the third ten year interval.
This is applicable only for steam generator snubbers manufactured by McDowell-Wellman.
CURRENT CODE RE UIREMENT Per 10 CFR 50.55a(f)(4)(ii),
the Cook Nuclear Plant's third ten year in-service test interval must meet the requirements of the ASME code, 1989 edition.
Section XI references ASME/ANSI OM, part 4, for snubbers.
The 10 CFR 50.55a(b)(2)(viii) states, "the specified
'Revision date or Indicator'or ASME/ANSI OM Part 4...shall be the OMA-1988 Addenda to the OM-1987 Edition."
-PROPOSED ALTERNATE EXAMINATION As an alternative, we are proposing to use ASME OM code, 1995
- edition, subsection
- ISTD, part 4,
during the third ten year interval.
This latest code includes the recommendations of generic letter (GL) 90-09, and it is consistent with our current revised technical specifications (T/Ss).
BASIS FOR RELIEF Recognizing that the existing inspection schedule was excessively restrictive, the NRC staff developed GL 90-09 to provide an alternate schedule for visual inspection.
The T/Ss for Cook Nuclear Plant units 1
and 2
have been revised to incorporate GL 90-09 inspection schedule recommendations.
Pursuant to 10 CFR 50.55a(3)(i), relief should be granted since adoption of ASME OM
- code, 1995
- edition, subsection ISTD for the scheduled steam generator snubber inspection will provide an acceptable level of safety and quality, consistent with GL 90-09.
JUSTIFICATION The proposed program, to use ASME OM code, 1995 edition, subsection ISTD for snubber inspection, complies with the inspection schedule requirements of GL 90-09.
Adoption of this program will comply with our T/Ss, GL 90-09, and ASME OM code, 1995 edition, subsection ISTD.
Use of ASME OM code, 1995 edition, subsection ISTD, will enable us to reduce occupational radiation exposure by as much as 50%
due to the flexibilityprovided in the inspection schedule.
The proposed program of ASME OM code, 1995 edition, subsection ISTD, provides an acceptable level of quality and safety, and will have no adverse impact on public health and safety.
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