ML18153A815
| ML18153A815 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/15/1995 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 95-145, NUDOCS 9505190381 | |
| Download: ML18153A815 (3) | |
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- PRIORITY *1 *1
_ ACCELERATED RIDS PROCESSl'.\\G)
- REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
AGCESSION NBR:9505190381 DOC.DATE: 95/05/15 NOTARIZED: NO DOCKET#
FACIL:50-281 Surry Power Station, Unit 2, Virgin~a Electric & Powe 05000281 AUTH.NAME AUTHOR AFFILIATION O'HANLON,J.P.
RECIP.NAME RECIPIENT AFFILIATION p
Document Control Branch (Document Control Desk)
SUBJECT:
Submits response to ISI program clarification of ASME relief request.
DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR f ENCL Q SIZE:
2,_.
TITLE: OR Submittal: Inservice/Testing/Relief from ASM~Code -
GL-89-04 NOTES:
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OGC/HDS2 EXTERNAL: LITCO ANDERSON NOAC NOTES:
NOTE TO ALL "RIDS" RECIPIENTS:
COPIES LTTR ENCL
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1 RECIPIENT ID CODE/NAME PD2-1 *po AEOD/SPD/RAB NRR/DE/EMCB NUDOCS-ABSTRACT RES/DSIR/EIB LITCO RANSOME,C NRC PDR PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCL'ME;"\\;T COJ\\:TROL DESK, ROOl\\1 Pl-37 (EXT 504-2083) TO ELHvtl\\/ATE YOL'R \\/A\\fE FRO\\!
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- t VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 15, 1995 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington.- D. C. 20555 Gentlemen: **
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 INSERVICE INSPECTION PROGRAM Serial No.95-145 NL&P/ETSR2' Docket No.
50-281 License No. DPR-37 CLARIFICATION OF ASME RELIEF REQUEST RESPONSE On March 8, 1995, interim relief from selected ASME Section XI requirements was granted for Surry Power Station Unit 2. Qualifications pertaining to Relief Request RR-6 were stated in this letter. Relief Request RR-6 detailed Virginia Electric and Power Company's request for relief from Subparagraph IWA-5242(a) of the 1989 Edition of the ASME Section XI Code.
For systems borated for the purpose of controlling reactivity, this subparagraph requires the removal of insulation from pressure-retaining bolted connections for the performance of visual examination (VT-2).
These examinations are intended to be conducted in conjunction with system leakage tests which are performed at normal operating temperature and pressure prior to plant startup.
Based upon a statement pertaining to RR-6 included in the NRC letter referenced above, clarification is appropriate. The discussion in the letter regarding RR-6 states:
"This interim relief is being granted for the Unit 2 refueling outage, which commenced February 1995, with the understanding that modification of the insulation on selected areas will be performed to make this relief request unnecessary for any future Unit 2 refueling outages." This statement does not represent our intentions with regard to RR-*6 and indicates that an apparent misunderstanding of our intentions exists.
On February 22, 1995, Virginia Electric and Power Company personnel di$cussed the basis for. RR-6 with the NRC Staff. RR-6 was submitted to address plant-specific conditions which make compliance with selected ASME Section XI requirements impractical. Because Surry operates with subatmospheric containments, compliance with these Section XI Class 1 and Class 2 inspection requirements would require station personnel to reinsulate the lines as well as disassemble and remove scaffolding from within containment while wearing self-contained breathing apparatus.
Furthermore, the piping will be at normal operating temperature which will create an additional personnel hazard. Personnel will also be exposed to increased radiation levels.
Virginia Electric and Power Company's RR-6 seeks permanent relief from the selected ASIVIE Section XI requirements. The containment and plant operating conditions
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- under which the required inspection would be performed at Surry Unit 2 will not
- change over the inspection interval for which relief is requested.
During RR-6 discussions, the NRC Staff requested that we consider removing insulation and inspecting Class 2 as well as Class 1 sections of the piping on a.
refueling rather than ten year interval basis.
This request would increase the inspection frequency for Class 2 sections of piping specified in RR-6.
We responded that this request would not be a problem for future refueling outages.
However, due to the timing of the request,* the additional inspection scope would present problems *for* the *then**ongoing**Surry*
- l:ln it-*2.. refueling -outagei "--Specifically; --the****
additional inspection scope associated with including Class 2 pipe sections had not.
been identified for performance during the Unit 2 outage. The increased inspections could not have been added to the outage without impacting the overall outage schedule.
The discussions concluded with our commitment to remove insulation and subsequently perform the alternate examinations proposed in RR-6 for applicable Class 2 pipe segments on a refueling basis starting with the next refueling outage as proposed in RR-6. This commitment is only applicable to piping systems addressed in RH-6.
In summary, permanent approval of RR-6 is requested to reduce potential risks to personnel. Implementation of the alternatives proposed in RR-6 does not require the permanent modification of any insulation. RR-6 is necessary not only during the approved interim period but also throughout the remaining third ten year inservice inspection interval.
If you have any questions or require any additional information, please contact us.
Very truly yours,
~YlW~
James P. O'Hanlon
. Senior Vice President - Nuclear cc:
United States Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, GA 30323 Mr. Morris Branch NRC Senior Resident Inspector Surry Power Station