ML18153A710

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Safety Evaluation Granting Requests for Relief RR-2,RR-6, RR-7,RR-8,RR-11,SR-002,SR-003,SR-004 & SR-006
ML18153A710
Person / Time
Site: Surry Dominion icon.png
Issue date: 07/19/1995
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML18153A709 List:
References
NUDOCS 9507240316
Download: ML18153A710 (7)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 OF THE THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF

1.0 INTRODUCTION

FOR VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT I DOCKET NUMBER:

50-280 The Technical Specifications for Surry Power Station, Unit I state that the inservice inspection of the American Society of Mechanical Engineers (ASME) ~-

Code Class 1, 2, and 3 components shall be performed in accordance with

~

Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).

10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the 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.

The regulations require that inservice examination of components and system pressure tests conducted during the first ten-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.SSa(b) on the date twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for the Surry Power Station, Unit 1, third IO-year inservice inspection (ISI) interval is the 1989 Edition.

The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.SSa{b) subject to the limitations and modifications listed therein and subject to Commission approval.

9507240316 950719 PDR ADOCK 05000280 G

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e Pursuant to 10 Cf.R 50.SSa(g)(S), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Conunission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6){i), the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.

In a letter dated July 16, 1993, Virginia Electric and Power Company (licensee) submitted to the NRC its Third Ten-Vear Interval Inservice Inspection Program Plan, Revision O and associated requests for relief for the Surry Power Station, Unit 1. Additional information was provided by the licensee in its letters dated June 22, 1994, September 12, 1994, October 19, 1994, and by teleconference on February 23, 1995.

2.0 EVALUATION AND CONCLUSIONS The staff, with technical assistance from its contractor, the Idaho National:

Engineering Laboratory {INEL), has evaluated the information provided by the licensee in support of its Third Ten-Vear Interval Inservice Inspection (ISi)

Program Plan, Revision 0, and associated requests for relief for Surry Power Station, Unit 1.

Based on the contractor's review of the ISi program, no deviations from regulatory requirements or commitments were identified in the Surry Power Station, Unit 1, Third Ten-Year Interval ISI Program Plan, Revision 0.

With respect to the relief requests, the staff adopts the contractor's conclusions and recommendations presented in the Technical Evaluation Report attached, with the exception of Request for Relief No. RR 11.

In Request for Relief RR 11, the Code-requirement IWA-5242(a) states that for systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure-retaining bolted connections for VT-2 visual examination.

The licensee has requested relief from the Code-requirement of removal of insulation for VT-2 visual examination of bolted connections in borated $YStems that are normally tested in sub-atmospheric conditions (Reactor Coolant, Charging, and Safety Injection System).

The licensee has*proposed the following alternative examination: "bolted connections on Class 1 systems containing boric acid to be examined each refueling outage at zero or static pressure. The examination would be performed with insulation removed.

Class 2 bolting will be examined similarly once a period. This alternative only applies to systems that are pressure tested under sub-atmospheric conditions.

In addition the required testing will be conducted with a VT-2 examination without removing the insulation."

The Code **re qui rem~nf to perform a VT-2 with the 1 nsul at ion removed during system pressure te'sting is impractical for systems under sub-atmospheric conditions.

Be*cause Surry, Unit 2 operates with a subatmospheric containment, compliance with the code requirements would require station personnel to reinsulate th* lines as well as disassemble and remove scaffolding from the containment while wearing self-contained breathing apparatus.

Furthermore, the piping will be at normal operating temperature which will create an additional personnel hazard as well as being exposed to increased radiation levels. Compliance with the Code requirement would result in significant personnel hazard.

Removal of insulation from bolted connections and examination for evidence of boric acid during the refueling outage at zero or static pressure should allow detection of any leaks occurring at the bolted connection. Since the same Code corrective actions would be required, the licensee's proposed alternative should provide adequate assurance of the integrity of these connections. Therefore, in view of the burden on the licensee that could result if the Code requirements were imposed on the facility, the licensee's Request for Relief No. RR 11 is granted pursuant to 10 CFR 50.55a{g}{6}{i}.

In summary, in view of the burden on the licensee, that could result if the Code requirements were imposed on the facility, requests for Relief Nos. 2, 6, 7, 8, SR-002, SR-003, SR-004, SR-006, and RR-11 are granted pursuant to 10 CFR 50.55a{g}{6}{i}.

The proposed alternative for request SR-006 is authorized provided that each Class I and 2 piping weld examined receives all of the reference markings at the time of inservice examination to provide assurance of traceability of piping welds and repeatability of examinations.

The relief granted is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. The alternatives, which provide an acceptable level of quality and safety, contained in Requests for Relief Nos.

3, 5, 10, SR-001, SR-007, and SR-008 are authorized pursuant to 10 CFR 50.55a{a}{3}{i}.

With respect to Relief No. 10, the proposed alternative is authorized provided that at least one bolt closest to the source of leakage is removed and evaluated.

Because compliance with the specified requirement would result in hardship or unusual difficulty without a compensatory increase in the level* of quality and safety, the alternative contained in Request for Relief No. SR-005 is authorized pursuant to 10 CFR 50.55a{a){3){ii). Requests for Re 1 i*ef Nos. 4 and 9 were withdrawn by the 1 i censee.

Re 1 i ef is not required for Request for Relief No. SH-I.

By teleconference on February 23, 1995, the licensee stated that it was withdrawing Request for Relief No. RR-1 from its ISi program and will provide documentation to that effect in the near future.

SURRY POWER STATION, UNIT 1 Third 10-Year ISi Interval SR-001 SR-002 R-003 SR-004 SR-005 Reactor Vessel Steam Generator Pressurizer Recirc.

Spray and Safety Injection p~

Ultrasonic Calibration Block B-F BS.10 B-D B3.140 B-D B3.120 C-G C6.10 APP-Ill TABLE 1

SUMMARY

OF RELIEF REQUESTS Nozzle-to-Safe End Butt Welds Weld No.

Drawing No.

1-01DM 11448-WKMS-0100AZ-1 1-17DM 11448-WKMS-0100AZ-1 1-01DM 11448-WKMS-0101AZ-1 1-17DM 11448-WKMS-0101AZ-1 1-01DM 11448-WKMS-0102AZ-1 1-17DM 11448-WKMS-0102AZ-1 Nozzle Inside Radius Sections Mark No.

Coq)Onent No.

1-01ANIR 1-RC-E-1A 1-01BNIR 1-RC-E-1A 1-02ANIR 1-RC-E-1B 1-02BNIR 1-RC-E-1B 1-03ANIR 1-RC-E-1C 1-03BNIR 1-RC-E-1C Surge Nozzle Inside Radius Section ALL Reactor Coolant P~ Casing Welds P~s 1A, 1B, 2A, and 2B Welds 2-01, 2-02, 2-03, and 2-04 Calibration block fabrication requirements surface and vol1.111etric examination Vol1.111etric examination Vol1.111etric examination Surface examination Section XI, Append i X 111 and Section V, Article IV Page 1 of 4 Automated 100X Authorized vol1.111etric exam from the pipe ID surface Visual CVT-1) examination from the nozzle ID Visual CVT-2) examination during pressure test Visual CVT-1) examination if~ is disassenbled and shaft removed for maintenance Granted Granted W/Conditions Granted Use existing calibration Authorized blocks e

SURRY POWER STATION, UNIT 1 Third 10-Year ISi Interval SR-006 All Class IWA-2610 and Class 2 C~nents SR-007 Reactor IWA-2610 Vessel SR-008 Class 1 8-J Piping RR 1 Class 1 8-P 815.51 Safety Injection Piping RR 2 Class 1 8-P 815.51 Residual Heat Removal RR 3 Class 3 IWD-5223 Circulating and Service Water Page 2 of 4 TABLE 1

SUMMARY

OF RELIEF REQUESTS Weld reference system Weld reference Establish weld reference Granted w/

system per system as welds are conditions Paragraph IWA-2610 examined Weld reference system for Reactor Weld reference To use the reference Authorized Vessel and Vessel Nozzle Area system per established by the Paragraph IWA-2610 automated tool 8-J Weld selection criteria Table IW8-2500-1 25%, including all Authorized Category 8-J Notes typical high stress areas SI piping between the following System hydrostatic System pressure test Withdrawn by check valves in the safety test in accordance conducted with pressure licensee injection system:

with IW8*5222 100 psig less than the 1-Sl-79 AND 1-Sl-235, 1-Sl-241 RCS normal operating 1-Sl-82 AND 1-Sl-236, 1-Sl-242 pressure 1-Sl-85 AND 1-Sl-237, 1-Sl-243 1-Sl-88 AND 1-Sl-238 1-Sl-91 AND 1-Sl-239 1-Sl-94 AND 1-Sl-240 RHR piping between MOV-1700 and System hydrostatic System pressure test at Granted MOV-1701 test in accordance the pressure required by with IWB-5222 the adjoining Class 2 system Piping upstream of the first System hydrostatic System flow test as Authorized isolation valve in the Class 3 test in accordance allowed for open ended Circulating and Service Water with IWD-5223 portions of discharge systems lines (IWD-5223(d))

SURRY POWER STATION, UNIT 1 Th;rd 10-Year ISi Interval RR 4 Class 3 IW-5223 Coqx>nent Cooling Water RR 5 Class 3 IW-5223 Service Water RR 6 Class 3 IWD-5223 Auxiliary Feedwater RR 7 Class 3 0-A 01.10 Circulating and Service Water Systems Page 3 of 4 TABLE 1

SUMMARY

OF RELIEF REQUESTS System Hydrostatic Withdrawn in e

Test Response to the 9/12/94 NRC's RAI Class 3 Service Water System System hydrostatic System hydrostatic test Authorized piping used in the cooling of test in accordance using 60 psig as this coqx>nent cooling water for the with IW-5223 systems PD value charging f)l.ll1JS and lube oil for the charging f)l.ll1JS Auxiliary Feedwater system System hydrostatic System functional test Granted between the following valves:

test in accordance IWA IWD-5222 1-FW-145 1-FW-149 with IW-5223 1-FW-146 1-FW-609 1-FW-160 1-FW-163 1-FW-161 1-FW-608 1-FW-175 1-FW-179 e

1-FW-176 1-FW-607 Circulating and Service Water System hydrostatic System inservice test, Granted piping between valves:

test in accordance IWD-5221 be performed in 1-SW-499 1-SW-311/

with IWD-5223 conjunction with a and 1-SW-321/

visual (VT-2) 2-SW-476 2-SW-331 examination 1-SW-317/

1-SW-346 1-SW-327/

and 2-SW-337 2-SW-344

SURRY POWER STATION, UNIT 1 Third 10-Year ISi Interval RR 8 Class 3 D-A D1.10 Circulating and Service Water System RR 9 Repair or Replacement RR 10 Bolted IWA-5250 Connections RR 11 Insulated IWA-5252 Bolted Connections SH-1 Coqionent F-A F1.10 Supports F-B Thru F-C F3.50 Page 4 of 4 TABLE I

SUMMARY

OF RELIEF REQUESTS Class 3 Circulating and Service System hydrostatic System inservice test, Granted e

Water System valves:

test in accordance IWD-5221 performed in 1-SW-MOV-102A 1-SW-37 with IWD-5223 conjunction with a and 1-SW-33 visual (VT-2) 1-SW-MOV-102B 1-SW-29 examination 1-SW-25 System Hydrostatic Withdrawn in Test submittal dated 6/22/94 Corrective measurements for IWA-5250(a)(2) 1992 Edition of ASME Authorized w/

leakage at bolted connectionsSection XI, conditions found during pressure test IWA-5250(a)(2)

Insulated bolted connections IWA-5242(a)

Inspect during outage Granted with insulations removed and non pressurized Coqionent Supports VT-3 Visual Code Case N-491 Not required