ML18153A437

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Forwards Request for Addl Info to Complete Review of Requested Relief from Requirements of ASME Section XI Code for IWE & Iwl Repair & Replacement Activities for Plants in Order to Develop Appropriate Implementing Procedures
ML18153A437
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 09/02/1997
From: Saunders R
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
97-264A, NUDOCS 9709090267
Download: ML18153A437 (5)


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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 2, 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 REQUEST FOR ADDITIONAL INFORMATION Serial No.

NL&OS/ETS Docket Nos.

License Nos.

97-264A R1 50-280, 281 50-338, 339 DPR-32, 37 NPF-4, 7 In our May 22, 1997 letter (Serial No.97-264), Virginia Electric and Power Company requested interim relief from the requirements of the ASME Section XI Code for IWE and IWL repair and replacement activities for both Surry and North Anna in order to develop the appropriate implementing procedures. In a telephone conference call on June 25, 1997, the NRC staff requested additional information to complete their review of this relief request. The additional information is provided in the Attachment to this letter.

If you have any questions concerning this request, please contact us.

Very truly yours, R. F. Saunders Vice President - Nuclear Engineering and Services Attachment Commitments made by this letter:

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U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. J. Morgan

  • NRC Senior Resident Inspector North Anna Power Station Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station

e A1TACHMENT REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST IWE-1 AND IWL-1 NORTH ANNA AND SURRY

Additional Information for IWE-1 and IWL-1 Question No. 1: Provide the procedures and processes for carrying out repair and replacement activities ranging from

planning, implementation, inspection to documentation.

Response

Repair and replacement activities will be controlled using the same procedures and processes used to control and document similar activities on other Systems, Structures, and Components (SSCs), including repair and replacement activities on ASME Class 1, 2, and 3 components. The following are examples of these procedures and processes:

PROCEDURE VPAP-0307 VPAP-0901 VPAP-0902 VPAP-0904 VPAP-1103 VPAP-2001 VPAP-2002 VPAP-2003 TITLE(PROCESS)

Repair and Replacement of ASME Section XI Components Control of Special Processes Control of Welding Materials Control of Protective Coatings ASME Section XI Visual Examination Program (VT-1, 2, & 3)

Station Planning and Scheduling Work Requests and Work Order Tasks Post Maintenance Testing Program Revisions to VPAP-0307 and VPAP-1103 to specifically address IWE/IWL requirements are being processed and will be in place prior to any IWE/IWL repair and replacement activities being conducted.

Procedures and programs currently in place provide assurance that IWE/IWL repair or replacement activities are adequately controlled and documented.

Question No. 2: Provide details about pressure and leak testing after repair and replacement.

Response

Any pressure or leak test required as a result of a repair or replacement will be governed, controlled, and documented in accordance with the requirements of Appendix J to 10 CFR Part 50. Surry and North Anna Station Engineering Procedure provides guidance for preparation and performance of containment integrated leakage rate testing. VPAP-0307 provides the mechanism for repair and replacement activities.

VPAP-1103 facilitates documentation of examination related to IWE/IWL components.

As noted above, VPAP-0307 and VPAP-1103 revisions are being processed.

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1 QueJtion No. 3: Provide the edition of the ASME Section XI Code (if applicable) used

  • for repair and replacement.

Response

The applicable ASME Section Code Editions are as follows:

Plant SPS 1 and 2 NAPS 1 NAPS2 Code Edition 1989 Edition 1983 Edition, S83 Addenda 1986 Edition Question No. 4: Discuss compliance with quality assurance criteria as contained in Appendix B to 10 CFR Part 50.

Response

The programs, procedures, and processes identified above, as well as, other administrative procedures, are currently in place and provide control: 1) of the current design of the containment; 2) of planning, tracking, and implementation of inspection and repair activities on the containment system, structure and components; 3) of special processes (e.g., welding, coating etc.), inspections (e.g., visual, surface, volumetric examinations) and special tests (e.g., system pressure tests and hydros) and

4) of the disposition of nonconforming conditions and the documentation of the inspection, repair and replacements activities.

Each of these programs and procedures have been developed to meet the Appendix B criteria. These controls are proven, reliable methods refined with experience, which assure containment repairs or replacements are implemented and documented effectively and do not adversely affect containment integrity.