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Requests Relief from Requirements of ASME Section XI Code for IWE & Iwl Repair & Replacement Activities for Surry & North Anna from Effective Date of Subsection IWE & Subsection Iwl Until 970909
	ML18153A411
Person / Time
Site:	Surry, North Anna
Issue date:	05/22/1997
From:	Saunders R; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	97-264, NUDOCS 9706020296
	Download: ML18153A411 (8)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 22, 1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 ASME SECTION XI RELIEF REQUESTS Serial No.97-264

- -NL&OS/ETS *H1 Docket Nos. 50-280, 281 License Nos.

50-338, 339 DPR-32, 37 NPF-4, 7 Surry Power Station Units 1 and 2 are presently in the

third ten year inservice inspection interval and examinations are conducted to the requirements of the 1989 Edition of ASME Section XI. North Anna Power Station Units 1 and 2 are presently in the second ten year inservice inspection interval and examinations are conducted to the requirements of the 1983 and 1986 Editions of ASME Section XI, respectively.

Pursuant to 1 O CFR 50.55a(g), relief is requested from the requirements of the ASME Section XI Code for IWE and IWL repair and replacement activities for both Surry and North Anna from the effective date of Subsection IWE and Subsection IWL until September 9, 1997.

By Federal Register Notice 154 (Volume 61 ), dated August 8, 1996, the Nuclear Regulatory Commission amended its regulations to incorporate by reference the 1992 edition with 1992 addenda of Subsection IWE, and Subsection IWL, with specified modifications and a limitation in 10 CFR 50.55a. The effective date of the amended rule was September 9, 1996.

The rule requires an expedited schedule for the completion of examinations,. specifying that the first containment inspection (of the first interval) must be completed within five years from the effective date of the rule, that is, September 9, 2001.

The rule does not provide time to develop procedures to implement the rules of Subsection IWE and Subsection IWL for repairs and replacements.

Therefore, re. Hef is being requested from the repair/replacement I requirements of the Code until the appropriate implementing procedures can be ~

1, 1 developed.

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R,elief requests for Surry Units 1 and 2 and North Anna Units 1 and 2 are provided in Attachments 1 and 2, respectively. These relief requests have been approved by the applicable Station Nuclear Safety and Operating Committee.

No new commitments are made as a result of this letter. If you have any questions concerning this request, please contact us.

Very truly yours, R. F. Saunders Vice President - Nuclear Engineering Services Enclosure cc:

U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 NRG Senior Resident Inspector North Anna Power Station Mr. R. A. Musser NRG Senior Resident Inspector Surry Power Station

ATTACHMENT 1 ASME SECTION XI RELIEF REQUEST NO. IWE-1 SURRY POWER STATION UNITS 1 AND 2

Virginia Electric & Power Company Surry Power Station Units 1 and 2 Third 10 Year Interval Relief Request IWE-1 I.

IDENTIFICATION OF COMPONENTS All components subject to the rules and requirements for repair and replacement of Class MC pressure retaining components and their integral attachments, and of metallic shell and penetration liner of Class. CC pressure retaining components and their integral attachments in light-water cooled plants as stated in the 1992 edition 1992 addenda of Subsection IWE, "Requirement for Class MC and Metallic Liners of Class CC Components of Light Water Cooled Plants," and IWL, "Requirements for Class CC Concrete Components of Light-Water Cooled Plants", of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code II.

CODE REQUIREMENTS By Federal Register Notice 154 (Volume 61 ), dated August 8, 1996, the Nuclear Regulatory Commission amended its regulations to incorporate by reference the 1992 edition with 1992 addenda of Subsection IWE, and Subsection IWL, with specified modifications and a limitation in 1 O CFR 50.55a. The effective date of the amended rule was September 9, 1996. The rule requires an expedited schedule to complete examinations, specifying that the first containment inspection (of the first interval) must be completed within five years from the effective date of the rule, that is, September 9, 2001. The rule does not provide time to develop procedures to implement the rules of Subsection IWE and Subsection IWL for repairs and replacements.

Ill.

CODE REQUIREMENT FROM WHICH RELIEF IS REQUESTED Relief is requested from the rules of Articles IWE-4000, "Repair Procedures",

and IWE-7000 "Replacements", IWL-4000 "Repair Procedures", IWL-7000 "Replacements", for a period of one year from the effective date of Subsection IWE and Subsection IWL, September 9, 1997.

IV.

BASIS FOR RELIEF In order to meet the repair and replacement requirements of Subsection IWE and Subsection IWL, procedures will have to be developed. These new procedures will take time to develop and implement.

Repair and replacement activities are currently being performed in a controlled process under work orders and maintenance procedures. Materials and work practices are controlled under Virginia Electric and Power Company's Quality

Assurance Program. The work order process specifies post maintenance testing to assure the component will perform its design function.

V. ALTERNATE PROVISIONS It is proposed that repair and replacement of items within the scope of Subsection IWE and Subsection IWL be controlled by maintenance and work order procedures.

These procedures will be used until procedures are developed to satisfy the requirements of Subsection IWE and Subsection IWL.

The new procedures will be developed and implemented by September 9, 1997.

The proposed alternative stated above will ensure that the overall level of plant quality and safety will not be compromised.

VI.

IMPLEMENTATION SCHEDULE This relief request will be implemented upon receiving NRC approval and will expire on September 9, 1997.

ATTACHMENT 2 ASME SECTION XI RELIEF REQUEST NO. IWE-1 NORTH ANNA POWER STATION UNITS 1 AND 2

Virginia Electric & Power Company North Anna Power Station Units 1 and 2 Second 10 Year Interval Relief Request IWE-1 I.

IDENTIFICATION OF COMPONENTS All components subject to the rules and requirements for repair and replacement of Class MC pressure retaining components and their integral attachments, and of metallic shell and penetration liner of Class CC pressure retaining components and their integral attachments in light-water cooled plants as stated in the 1992 edition 1992 addenda of Subsection IWE, "Requirement for Class MC and Metallic Liners of Class CC Components of Light Water Cooled Plants," and IWL, "Requirements for Class CC Concrete Components of Light-Water Cooled Plants", of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code II.

CODE REQUIREMENTS

..By Federal Register Notice 154 (Volume 61 ), dated August 8, 1996, the Nuclear Regulatory Commission amended its regulations to incorporate by reference the 1992 edition with 1992 addenda of Subsection IWE, and Subsection IWL, with specified modifications and a limitation in 10 CFR 50.55a. The effective date of the amended rule was September 9, 1996. The rule requires for an expedited schedule to complete examinations, specifying that the first containment inspection (of the first interval) must be completed within five years from the effective date of the rule, that is, September 9, 2001. The rule does not provide time to develop procedures to implement the rules of Subsection IWE and Subsection IWL for repairs and replacements.

III.