ML18153B102
| ML18153B102 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/11/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-552, NUDOCS 9410180199 | |
| Download: ML18153B102 (6) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 11, 1994 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 INSERVICE INSPECTION PROGRAM RELIEF REQUEST FROM ASME SECTION XI Serial No.
SPS/ETS Docket Nos.
License Nos.94-552 50-280 50-281 DPR-32 DPR-37 Pursuant to 10 CFR 50.55a(g)(5)(iii) relief is requested from certain impractical requirements associated with snubber visual inspections as delineated in ASME Section XI, 1989 edition. The basis for this relief is provided in Relief Request SH-2 for Surry Unit 1 and Relief Request SH-1 for Surry Unit 2.
The relief requests are included in Attachment 1.
Should you have any questions or require additional information, please contact us.
Very truly yours,
~?~
James P. O'Hanlon Senior Vice President - Nuclear Attachment cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Mr. Morris Branch NRC Senior Resident Inspector Surry Power Station
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9410180199 941011 PDR ADOCK 05000280 Q
e Surry Units 1 and 2 lnservice Inspection Program Relief Requests
Relief Request SH-2 (Unit 1)
I.
IDENTIFICATION OF COMPONENTS Class 1, 2, and 3 Snubbers II.
IMPRACTICAL CODE REQUIREMENTS e
Section XI of the ASME Boiler and Pressure Vessel Code, 1989 Edition, IWF-5000 with respect to visual examination and repairs/replacements of snubbers as required in the first addenda to ASME/ANSI OM-1987, Part 4 (published in 1988).
Ill.
BASIS FOR RELIEF Differences exist between the referenced standard requirements and the Surry Technical Specification 4.17. The first addenda to ASME/ANSI OM-1987, Part 4 (published in 1988) contains requirements, which were recommended for removal from technical specifications 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 inspection schedule contained in technical specifications. In May of 1991, Amendments 156 and 155 were approved by the NRC which removed the restrictive visual inspection requirements from the Surry Technical Specifications. As a result of the 1 O CFR 50.55a program update requirements, the 1989 ASME Section XI Code was required to be used for the third interval ISi programs. Since the 1989 Section XI Code references ASME/ANSI OM-1987, Part 4, this restrictive inspection schedule for snubbers is again required to be followed. Later Code, ASME 0Mb Code-1992, Addenda to ASME OM Code-1990, subsection ISTD, Table ISTD 6.5.2-1, contains the newer inspection schedule requirements (subsection ISTD replaced OM Part 4). Therefore, this is not a technical issue, but simply a case of the administrative aspects of the Code lagging behind the other industry standards. As such, requiring the use of the referenced standard's inspection schedule is considered impractical.
The referenced standard (OM Part 4) additionally contains requirements again eliminated by the later ISTD Code (1992 addenda) with regard to visual failure evaluation groupings. As this is not perceived by the industry as a significant technical issue, performance of this requirement would be an unnecessary administrative burden, and therefore impractical to perform.
The remainder of the referenced standard (OM Part 4) pertaining to snubber visual inspection, repairs and replacement requirements are essentially the same as those already delineated in the Surry Technical Specification 4.17, and the ASME Section XI Repair/Replacement program. Requiring the use of the referenced standard in these remaining areas is an unnecessary duplication and therefore impractical.
e IV.
ALTERNATE REQUIREMENTS In lieu of the Code requirements specified in IWF-5000 (OM Part 4) for snubber visual examination, the requirements of Surry Technical Specification 4.17 with regard to snubber visual examination shall be followed.
The required examination shall be performed by personnel certified visual (VT-3) as required by the Code. Repairs and replacements shall be performed as required by the general requirements (IWA-4000 and IWA-7000) of ASME Section XI.
Relief Request SH-1 (Unit 2)
I.
IDENTIFICATION OF COMPONENTS Class 1, 2, and 3 Snubbers II.
IMPRACTICAL CODE REQUIREMENTS Section XI of the ASME Boiler and Pressure Vessel Code, 1989 Edition, IWF-5000 with respect to visual examination and repairs/replacements of snubbers as required in the first addenda to ASME/ANSI OM-1987, Part 4 (published in 1988).
Ill.
BASIS FOR RELIEF Differences exist between the referenced standard requirements and the Surry Technical Specification 4.17. The first addenda to ASME/ANSI OM-1987, Part
- 4 (published in 1988) contains requirements, which were recommended for removal from technical specifications 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 inspection schedule contained in technical specifications. In May of 1991, Amendments 156 and 155 were approved by the NRC which removed the restrictive visual inspection requirements from the Surry Technical Specifications. As a result of the 1 O CFR 50.55a program update requirements, the 1989 ASME Section XI Code was required to be used for the third interval ISi programs. Since the 1989 Section XI Code references ASME/ANSI OM-1987, Part 4, this restrictive inspection schedule for snubbers is again required to be followed. Later Code, ASME 0Mb Code-1992, Addenda to ASME OM Code-1990, subsection ISTD, Table ISTD 6.5.2-1, contains the newer inspection schedule requirements (subsection ISTD replaced OM Part 4). Therefore, this is not a technical issue, but simply a case of the administrative aspects of the Code lagging behind the other industry standards. As such, requiring the use of the referenced standard's inspection schedule is considered impractical.
The referenced standard (OM Part 4) additionally contains requirements again eliminated by the later ISTD Code (1992 addenda) with regard to visual failure evaluation groupings. As this is not perceived by the industry as a significant technical issue, performance of this requirement would be an unnecessary administrative burden, and therefore impractical to perform.
The remainder of the referenced standard (OM Part 4) pertaining to snubber visual inspection, repairs and replacement requirements are essentially the same as those already delineated in the Surry Technical Specification 4.17, and the ASME Section XI Repair/Replacement program. Requiring the use of the referenced standard in these remaining areas is an unnecessary duplication and therefore impractical.
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V a
IV.
e ALTERNATE REQUIREMENTS In lieu of the Code requirements specified in IWF-5000 (OM Part 4) for snubber visual examination, the requirements of Surry Technical Specification 4.17 with regard to snubber visual examination shall be followed.
The required examination shall be performed by personnel certified visual (VT-3) as required by the Code. Repairs and replacements shall be performed as required by the general requirements (IWA-4000 and IWA-7000) of ASME Section XI.