ML18142A360

Application for Amend to Licenses DPR-32 & DPR-37,deleting Tech Spec 4.15 Re High Energy Pipe Break Insp Program.Insp Will Be Conducted Under ASME Code,Section XI Inservice Insp Program

ML18142A360
Person / Time
Site:	Surry
Issue date:	04/12/1985
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Varga S Office of Nuclear Reactor Regulation
Shared Package
ML18142A361	List: ML18142A360 ML18142A362
References
85-199, TAC-43113, TAC-43114, NUDOCS 8504230409
Download: ML18142A360 (10)

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e Nuclear Operations Department Post Office Box 26666 OneJames River Plaza Richmond, Virginia 23261 April 12, 1985 VIRGINIA POWER Mr. Harold R. Denton, Director Serial No.85-199 Office of Nuclear Reactor Regulation NO/JDH:acm Attn: Mr. Steven A. Varga, Chief Docket Nos. 50-280 Operating Reactors Branch No. 1 50-281 Division of Licensing License Nos. DPR-32 U. S. Nuclear Regulatory Commission DPR-37 Washington, D. C. 20555 Gentlemen:

VIRGINIA POWER SURRY POWER STATION UNIT NOS. 1 AND 2 PROPOSED TECHNICAL SPECIFICATION CHANGE-SUPPLEMENT In our letter dated October 28, 1980 (Serial No. 862), we requested several changes to the Technical Specifications for Surry Power Station Unit Nos. 1 and 2. Among the changes proposed was one pertaining to breakpoints to be incorporated in the High Energy Pipe Break Inspection Program (Technical Specification 4.15). In a subsequent letter dated Sep-tember 21, 1983 (Serial No. 529), we advised you that changes had occurred in the break point information to be incorporated in the inspection pro-gram. We also informed the NRC Surry Project Manager at that time that we would be supplementing the original submittal. The supplemental informa-tion is attached.

The proposed change dele1:es Technical Specification 4. 15 completely. In its place, acceptable inspection will be conducted under the ASME Code Section XI ISI program. A discussion of the proposed change is included as Attachment 1. The Technical Specific.ation changes are included as Attachment 2.

This request has been reviewed and approved by the Station Nuclear Safety and Operating Committee and by the Safety Evaluation and Control Staff.

It has been determined that this request involves neither an unreviewed safety question as defined in 10CFR50.59, nor a significant hazards con-sideration as defined in 10CFR50.92.

8504230409 850412 PDR ADOCK 05000280 P PDR

e e Because the NRC took action on the other portions of the original amend-ment application, an additional Application Fee of $150 is enclosed. If you have any questions or need additional inform~tion, please contact us immediately.

Very truly yours, J,c~-

w. L. Stewart Attachments:

1. Discussion of Proposed Technical Specification Changes

2. Proposed Technical Specification Changes

3. Application Fee cc: Dr. J. Nelson Grace Regional Administrator Region II Mr. D. J. Burke NRC Resident Inspector Surry Power Station Mr. Charles Price Department of Health 109 Governor Street Richmond, Virginia 23219

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e COMMONWEALTH OF VIRGINIA)

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CITY OF RICHMOND )

The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by W. L, Stewart who is Vice President -

Nuclear Operations, of Virginia Power. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.

\~ i?S" Acknowledged before me this day of ~(~\---:\

, 19 My Commission expires: 'ft-~f-,u c.._h, \

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Nodiry Public (SEAL)

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e e ATTACHMENT 1 DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGES

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e DISCUSSION OF PROPOSED TECHNICAL SPECIFICATION CHANGE The original Technical Specification 4.15, dated September 21, 1973 was implemented for main steam and feedwater piping systems located outside containment and considered high energy flow paths. A concern had mani-fested over the continued integrity of piping systems not covered by Surry Technical Specification 4. 2, "Reactor Coolant System Component Inspections," which is limited to the reactor coolant pressure boundary.

As explained in the technical basis of T.S. 4.15, a potential exists with-in high energy piping for flaw growth and leakage due to cyclic loading and resultant metal fatigue. These safety implications were recognized and the technical specification was adopted.

Since the adoption of this technical specification, code requirements have expanded into areas not associated with the reactor coolant pressure boundary. As defined in Regulatory Guide 1.26, February 1976, paragraph C .1. (d), a Quality Group B classification has been assigned to the affected piping. This corresponds to Class 2 identification under the ASME Boiler and Pressure Vessel codes. The requirement of 10CFR50. 55a (b)(2) to update to ASME Section XI, 1980 edition, winter 1980 addenda at the Surry units has created a duplication of inspection.

As delineated in 10CFRS0.55 a(b)(2)(iv)(A) and (B), Surry used the 1974 edition, summer 1975 addenda of ASME Section XI for "the extent of exam-ination" for category C-F, pressure retaining welds in piping. Examina-tion requirements, examination method, acceptance standard, and frequency of examination are under the rules of the 1980 edition, winter 1980 adden-da of ASME Section XI. A chart is provided (Enclosure I) comparing both Technical Specification 4.15 and the code. Although differences exist between the two, the concepts utilized to develop the present code contain the accepted risks allowed by the governing authority. Previous break points located outside the Class 2 boundary on the feedwater system are not considered critical safety points. They are not associated with con-tainment isolation, or the auxiliary feedwater system used during emergency steam generator operation. In addition, guidelines presented in Regulatory Guide 1. 26 designate these points Quality Group "D" with no corresponding ASME class. It should be noted that the examination history has revealed no reportable indications on any of the original T.S. welds during the entire first interval.

It is our contention that acceptable inspection is provided by the ASME Boiler and Pressure Vessel Code and continuation of Technical Specifica-tion 4.15 represents impractical duplication. Thus, we propose to delete Technical Specification 4.15.

The proposed change to Technical Specifications 4.15 has been reviewed and it is concluded that:

(a) The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety and previously evaluated in the Safety Analysis Report is not increased since the system is still proven to be operational by the Inservice Inspection program.

- -- -:------------------. e (b) The potential for an accident or malfunction of a different type than previously evaluated in the Safety Analysis Report is not created. The level of integrity and the function of the system is not changed by performing the inspection in accordance with Inservice Inspection Program instead of Technical Specifications 4.15.

(c) The required margin of safety in the basis of the Technical Specifications is not reduced because the system is proven to be operable by the Inservice Inspection Program.

Therefore, no unreviewed safety question as defined in 10CFRS0.59 exists.

Similarly, we have concluded that no significant hazards consideration as defined in 10CFRS0.92 exists. The Commission has provided examples of proposed amendments likely to involve significant hazards considerations (48 FR 14870). Example (iii) states: "A significant relaxation in limit-ing conditions for operation not accompanied by compensatory changes, conditions, or actions that maintain a commensurate level of safety ... ").

The proposed change is similar to the example in that it deletes an exist-ing surveillance requirement. However, unlike the example, compensatory actions in the form of an equivalent ISI program will be taken, thus assuring a commensurate level of safety is maintained. Therefore, no sig-nificant hazards consideration exists.

e e Enclosure I Page 1 of 3 ITEM TECHNICAL SPECIFICATION CODE REQUIREMENTS

1. Examination 20 welds identified in Main steam classifi-requirements T.S. figure 4.15 ed ASME CLASS II as per Reg. Guide 1.26 (Includes all twelve original welds)

- 12 welds on Main Steam - Feedwater classifi-System. ed ASME CLASS II as per Reg. Guide 1.26 (Includes three of the eight original welds.)

- 8 welds on Feedwater System.

- Welds located outside containment.

2. Examination - Volumetric examination. - Surface examination Method Visual inspection during Volumetric examina-normal operation tion

- VT-2 examination during a system pressure t:est.

- VT-2 examinataion during a system hydrostatic pressure test.

3. Examination - Volumetric exam to the - Surface,volumetric, Acceptance requirements of sub- and VT-2 examinations criteria section ISC 100 through to the requirements 600 of the 1972 Winter of the 1980 edition, Addenda of ASME Section Winter 1980 addenda XI. of ASME Section XI

- Visual exam evaluates all leaks and allows no through-wall flaw leakage.

e e Page 2 of 3

4. Examination - Volumetric; each 10 year - Surface; each 10 Frequency and interval 1/3 of the year interval:

extent of identified welds during examination each 1/3 of the inspection 1st period (3 1/3 interval with cumulative yrs) 16%-34%

100% coverage of all welds. category CF item CS.21 welds.

- Visual; weekly walkdowns 2nd period (3 1/3 at all weld locations. yrs) 50%-67%

category CF item CS.21 welds.

3rd period (3 1/3 yrs) 100% category CF item CS.21 welds.

(Note: 4th interval requires 100%

completion by second period.)

- Volumetric; same as surface.

- VT-2 system pressure test; each period (3 1/3 yrs for every interval (10 yrs).

- VT-2 system hydro-static pressure test; once every interval (10 yrs).

- Volumetric and surface requires completion of 100% of one multiple stream per interval.

(IWC-2411 74-S75),

additional examina-tions as required by IWC 2430 for failures.

• e Page 3 of 3

5. Repairs, post- - In accordance with the - Station's repair/

repair examina- rules of ASME Section replacement program tions and pressure XI code. based upon ASME Section XI 1980 edition, winter 1980 addenda.

• e ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES