ML18153A131
| ML18153A131 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/25/1997 |
| From: | Edison G NRC (Affiliation Not Assigned) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| TAC-M97686, NUDOCS 9705010060 | |
| Download: ML18153A131 (6) | |
Text
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,Mr. J.P. O'Hanlon
- Senior Vice President Nuclear 1 Virginia Electric and Power Company 1nnsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, Virginia 23060 April 25, 1997
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING THE SURRY POWER STATION, UNIT 2 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUEST FOR RELIEF (TAC NO. M97686)
Dear Mr. O'Hanlon:
The purpose of this letter is to request additional information so that we can complete our review of your ISI *relief request submitted January 2, 1997.
Your relief request, designated SR-18 through SR-24, relates to weld examination coverage requirements of ASME Code,Section XI.
The NRC staff is reviewing your submittal and requires additional information (enclosure) to complete its review.
Please respond within 30 days of receipt of this letter.
In order to expedite the review process, please send a copy of your response to NRC's contractor, INEEL, at the following address:
Docket No. 50-281 RAI Michael T. Anderson INEEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, (Original Signed By)
Gordon E. Edison, Senior Project Manager Project Directorate II-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosure:
cc w/encl:
See next page Distribution
=D.oGket-sF:ci le PUBLIC PDII-1 RF S. Varga OGC ACRS J. Johnson, RII SR97686.RAI
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Mr. J. P. O'Hanlon Virginia Electric and Power Company cc:
Mr. Michael W. Maupin, Esq.
Hunton and Williams Riverfront Plaza, East Tower 951 E~ Byrd Street Richmond, Virginia 23219 Mr. David Christian, Manager Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Sup.ervi sors of Surry County Surry County Courthouse*
Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P. 0. Box 1197 Richmond, Virginia 23209 Regional Administra.tor, Region II U. S. Nuclear Regulatory Commission IOI Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Robert B. Strobe, M.D., M.P.H.
State Health Commissioner Office of the Commissioner Virginia Department of Health P.O. Box 2448 Richmond, Virginia 23218 Surry Power Station Office of the Attorney General Commonwealth of Virginia 900 'East Main Street Richmond, Virginia 23219 Mr. M. L. B6wling, M~nager Nuclear Licensing & Operations Support Innsbrook Technical Center Virginia Electric and Power Company 5000 Dominion Blvd.
Glen Allen, Virginia 23060 Mr. Al Belisle U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W. Suite 2900 Atlanta, Georgia 30323-0199 Mr. W. R. Matthews, Manager
. North Anna Power Station P. 0. Box 402 Mineral, Virginia 23117 i
VIRGINIA ELECTRIC l POWER COMPANY SURRY POWER STATION, UNIT 2 DOCKET NUMBER 50-281
- ENCLOSURE Request for Additional Information - Third IO-Year Interval Inservice Inspection {ISi) Requests for Relief Scope/Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in the ASME Code Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.
This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during a 120-month inspection interval comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.
The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.
The staff has reviewed the available information provided in your January 2, 1997, submittal, including the requests for relief from the ASME Code Section XI requirements that VEPCO has determined to be impractical.
Additional Information Required Based on the above review, the staff has concluded that the following information and/or clarification is required to complete thi review of the ISI requests for relief:
A.
- The regulations provide that a licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR 50.55a(a)(3)(i) or 10 CFR 50.55a(a)(3)(ii). Under 10 CFR 50.55a(a)(3)(i), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e.,
essentially, be equivalent to the original requirement in terms of quality and safety. Under 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examination, and development of sophisticated tooling that would result in only minimal increases in examination coverage.
A licensee may also submit a request for relief from ASME requirements.
In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in §50.4, information to support that determination.
When a licensee determines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned, or a comporient would have to be replaced to enable 2
inspection, the licensee should cite 10 CFR 50.SSa{g){S){iii). The NRC may, giving due consideration to the burden placed on the licensee, impose an alternative examination require~ent.
Based on.the initial review of VEPCO's submittal, it appears that the appropriate paragraph of the regulations has not been referenced for Request for Relief SR-018.
Relief was requested pursuant to 10 CFR 50.SSa{g){S){iii), but disassembly of a component constitutes a burden, not an impracticality. Typically; disassembly of components for the sole purpose of performing examinations is considered a hardship. Please review this request for relief and provide the appropriate ref~rence of the regulations, along with
. documentation supporting the regulatory bas.is.
B.
In Request for Relief SR-019, VEPCO requested to perform a surface examination of the fillet weld of a reinforcement plate/saddle weld in lieu of the weld obstructed by the saddle plate.
An additional part of the proposed alternative is the performance of the system leakage test. Considering that direct access to the Code-required weld is not possiblei how will an effective leakage test be P.erformed? _ Does the saddle plate include telltale holes which could
.be used to detect leakage from the underlying weld?
C.
In Request for Relief SR-022, VEPCO states that the Code-coverage requirements cannot be met for.the surface examination of safety injection (SI) pump casing Weld 2-06 in Safety Injection Pump 2-SI-P-lA.
In light of the limited examination of Weld 2-06, please*
describe examinations performed on the.other SI pump casing welds that would support the conclusion that generic degradation is not occurring.
D.
In Request for Relief SR-023, VEPCO states that the Code-coverage requirements cannot be ~et for the volumetric examination of two pressurizer nozzles inside radius sections.
The proposed alternative is to perform a best-effort volumetric examination and a visual 3
,r, examination of the IR sections prior to the end of the inspection interval. However, no indication of the coverage that can be obtained was provided.
Please provide estimates of the Code-required volume that can be examined.
In addition, provide a discussion regarding the type of visual examination that is proposed.
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