ML18153A851
| ML18153A851 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/08/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18153A850 | List: |
| References | |
| NUDOCS 9506230226 | |
| Download: ML18153A851 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION OF THE OFFICE OF NUCLEAR REACTOR REGULATION
,THIRD INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FROM ASME CODE SECTION XI SURRY POWER STATION UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY INTRODUCTION By letter dated October 11, 1994, Virginia Electric and Power Company, the licensee for Surry Power Station Units 1 and 2, requested relief from the requirements of ASME Code Section XI, 1989 Edition, Subsection IWF-5000, with regard to visual examination and repair/replacement of snubbers. Subsection IWF-5000 references the first addenda to ASME/ANSI OM-1987, Part 4 (published in 1988) for visual examination and repair/replacement for snubbers.
BACKGROUND The first addenda to ASME/ANSI OM Code-1987 contains a visual examination schedule which was recommended for removal from Technical Specifications (TSs) by Generic Letter 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions," dated December 11, 1990. This Generic Letter was issued to reduce the burden placed upon utilities by the then overly restrictive visual examination schedule.
In May 1991, Amendments 155 and 156 were approved by the NRC which removed the restrictive visual examination requirements from the Surry TSs which now contain the alternate schedule recommended by the Generic Letter.
As the licensee stated in its October 11, 1994, letter, due to the 10 CFR 50.SSa program update requirements, the 1989 ASME Code Section XI would be required to be used for the third interval Inservice Inspection (ISi) programs. Since the 1989 ASME Code Section XI references ASME/ANSI OM-1987, Part 4, the restrictive examination schedule for snubber is again required to be followed.
In addition, the referenced standard (OM Part 4) also contains a requirement with regard to visual failure evaluation grouping for snubbers which is not perceived by the industry as a significant technical issue. The remainder of OM Part 4 pertaining to requirements for snubber visual examination and repair/replacement is essentially the same as that delineated in the Surry TSs section 4.17 and the ASME Section XI Repair/Replacement program (IWA-4000 and IWA-7000).
The licensee, therefore, stated that complying with 1989 ASME Code Section XI, Subsection IWF, and OM Part 4, would be impractical and/or would constitute an unnecessary administrative burden.
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e EVALUATION The staff has reviewed the licensee's submittal and determined that pursuant to 10 CFR 50.55a{a){3)(i), the proposed alternatives would provide an acceptable level of quality and safety.
In fact, 1994 Addenda to ASME OM Code 1990 Edition, Subsection ISTD {replacing OM Part 4), Table ISTD 6.5.2-1, now contains the new visual examination schedule similar to that in the Surry Tech Specs 4.17.
In its October 11, 1994, letter, the licensee stated that the required examination shall be performed by personnel certified for visual examination {VT-3) as required by the Code.
This is acceptable to the staff.
The staff concluded that visual failure evaluation grouping as required by OM Part 4 is not a significant technical issue and performance for this requirement would be an unnecessary administrative burden.
In fact, this requirement has been eliminated from the above mentioned, later OM Code.
In addition, the staff considered the repair and replacement requirements as stipulated in the ASME Section XI Subsection IWA to be sufficient without an unnecessary duplicated requirement of OM Part 4.
The repair/replacement program shall be performed as required by the general requirements (IWA-4000 and IWA-7000) of ASME Section XI. This is also acceptable to the staff.
CONCLUSION Based on the information provided, the staff determined that the licensee has presented adequate justification for its relief requests from the requirements of ASME Code 1989 Edition,Section XI, Subsection IWF (which references OM part 4), with regard to visual examination, visual failure group evaluation, and repair/replacement for snubbers.
Based on this and the fact that acceptable alternatives already exist in the Surry Technical Specifications and ASME Code Section XI, Subsection IWA, the staff concluded that, pursuant to 10 CFR 50.55a(a)(3)(i), the relief requests should be granted, and the licensee's proposed alternative should be imposed.
Further, the staff has determined that the granting of this relief request 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 facilities.
Principal Reviewer:
Arnold Lee Date:
June 8, 1995