ML20150C652

Responds to Util 880301 Request for NRC Approval to Use ASME Boiler & Pressure Vessel Code Case N-234 to Extend Time Between Calibr Checks Required During Ultrasonic Exam of Reactor Vessel.Request Granted

ML20150C652
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/10/1988
From:	Calvo J Office of Nuclear Reactor Regulation
To:	Tison Campbell ARKANSAS POWER & LIGHT CO.
References
TAC-67397, NUDOCS 8803210137
Download: ML20150C652 (6)

Text

__

}

a ucf

/  %,

UNITED STATES l' ) #  ;

t NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 t i March 10,1988

%, ...../

Docket No. 50-368 Mr. T. Gene Carpbell Vice President, Nuclear Operations Arkansas Pnwer and Light Company Post Office Box 551 Little Rock, Arkansas 72203 l

Dear Mr. Campbell:

1

SUBJECT:

REQUEST FOR APPLICATION OF ASME CODE CASE N-234 '

ARKANSAS NUCLEAR ONE, UNIT 2 (ANO-2) - TAC NO. 67397 The Comission has completed their review of the Arkansas Power and Light (AP&L) request for NRC approval tG use the ASME Boiler and Pressure Vassel l Code Case N-234 as requested in the submittal dated March 1,1988(2CANO38802). i Approval for application of Case N-234 would permit AP&L to extend the time between calibration checks required during ultrasonic exarination of the reactor vessel.

The ASME code of record for the present ANO-2 Inservice Inspaction Program is the 1974 Edition through Sumer 1975 Addandum of Section XI of the ASME Boiler .

and Pressure Yessel Code. AP&L stated that the ANO-2 reactor vessel will be l examined during the present refueling outage. For the performance of the 1

i ultrasonic examiration of the vessel, automated ultrasonic examination system calibration checks are presently required once every four hours and with any change in examination personnel in accordance with Appendix I (I-4230) of

Section XI. ASME Code Case N-234 allows the time period between the calibration

checks to be extended to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and eliminates the requirements that a calibration check be perfomed with a change in operatirg personnel. I Footnote 6 to 10 CFR 50.55a permits the use of Code Cases, in addition to l those accepted in Regulatory Guide (R.G.) 1.84 or R.G.1.85, upon authorization  !

by the Director of the Office of Nuclaar Reactor Regulation upon request J pursuanttoSection50.55a(a)(3). Alternatives to the requirements of Section .

! XI of the ASME Code are pemitted by 10 CFR 50.55a(a)(3) if the applicant can I i demonstrate that (i) the proposed alternatives would provide an acceptable l 1evel of quality and safety or (ii) compliance with the specified requirements of this section would result in hardship or unusual difficulties without a 4

compensating increase in the level of quality and safety.

R.G. 1.147, Revision 5. "Inservice Inspection Code Case Acceptability ASME 3

Section XI Division I", dated August 1986, lists Code Cases that are generally j acceptable to the NRC staff for implementation in the intervice inspection of light-water cooled nuclear power plants. Code Case N-234 is er.dorsed in i i R.G. 1.147 with no exceptions taken by the NRC staff to the Code Case. This )

8803210137 000310 1 PDR ADOCK 050 3jO i P 1

l

-2 cede case states that---when performing ultrasenic examinations in accordance with either Appendix I or Appandix III of Section XI, Divisinn 1, if automated ultrasonic examination systens ara used, the time period between calibration checkt, required by I-4230 or 111-3330 may be extended tc 12 hr and need not be coincident with a change of operator persernel.

ApAL request of March 1, 1988 stated that the application of Code Case N-234 would result in a reduction of approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> ir the outage critical path time required for the examination ard, consistent with haalth physics ALARA objectives, a reduction of radiation exposure of personnel perfoming the exaninatien. Applicatier of Code Case N-234 is in accordance with the provi-sions of 10 CFR 50.55a(a)(3)(i) in that calibration checks of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during use of the autcrated ultrasonic exanination systems would provide an acceptable level of quality and safety. Further, using the four heur calibration intervals would increase personnel radiation exposure with no compensating increase in 1 the level of quality and safety.

Tha staff has detemined in accordance with the provisions of 10 CFR 50.55a(a)(3) that your rec,uest for authorization for usa n' Code Case N-234 for the ultrasonic examination of the reactor vessel as previously described provides an acceptable level of quality ard safety, and that recuiring the four hour calibration checks would result in increased radiation exposure without a compensating increase in the systems level of cuality and safety.

This letter shall serve as authorization of your request to use Code Case N-234 in lieu of currently perfoming the four hour calibration checks as part of the inservice irspection of the reactor vessel in accordance with Appendix ! of i Section XI of the ASME Code.

The Comission hereby authorizes this use of ASME Ccde Case N-234 for this pertion of reactor vessel inservice inspection program pursuant to 10 CFR 50.55a(a)(3) and finds that this use (1) provides an accaptable leval of quality ard safety, (2) that corpliance with the present requirements would increase radiation exposure not conpersated by the resultant increase in quality and safety, and (3) is authorized by law and will not endarger life or property or the comon defense and security and is otherwise in the public interest.

Sincerely, i

CJ A lu 4

' Jose A. Calvo, Director  !

Project Directorate - IV l Division of Reactor Projecte - III, l

IV, Y and Special Projects  !

i cc: See next page

1  ;

i Mr. T. Gene Campbell Arkansas Power & Light Company Arkansas Nuclear One, Unit 2 CC' Mr. J. Ted Enos, Managar Mr. Charles B. Brinknar, Manager Nuclear Engineering and Licensing Washington Nuclear Operations j Arkansas Power & Light Company C-E Power Systens

.! P. O. Box 551 7910 Woodmont Avenue ,

l Little Rock, Arkansas 72203 Suita 1310 i Bethesda, Maryland 7081a

, Mr. James M. Levina, Director l Sito Nuclaar Operations Mr. Frank Wilson, Directne Arkanses Nuclear Ona Division of Environmental Health P. O. Box 608 Protection Russellville, Arkansas 72801 Department of Health Arkansas Departnent of Health Mr. Nicholas S. Reynnits 4815 Wast Markham Streat Bishop Liberran, Cook, Purcell Little Rock, Arkansas 7?201 1200 Seventeenth Street, N.W.

Suite 700 Hnnorable Willitm Abe-vsthy ,

, Washington, D.C. 20036 County Judoa of Pope Count'y ,

Pope County Courthouse l Regional Adninistrator, Renien IV Russelville, Arkansas 72801 U.S. Nuclear Pagulatory Commission Office of Executive Director fn*

Operations 611 Pyan Plaza Drive, Suite 1000 Arlirgton, Texas 76011 Senior Resident IrSpector U.S. Nuclear Regulatory Commission i 1 Nuclear Plant Road Pussellville, Arkansas 72801

Ms. Greta Dieus, Director i Division of Er"ironmental Health i Protectice  !

Arkansas Department of Health  !

4815 West Markam Street  !

Little Rock, Arkansas 72201  !

Mr. Robert B. Borsum

, Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue ,

Rethesda, Maryland 20814 l

l 4

1 i

i

f

code case states that---wher perfomina ultrasonic examinatiers in accordance with either Appendix ! or Appendix III of Section XI, Division 1 if automated ultrasenic examination systems are used, the time peried between calibration checks required by I-4230 or III-3330 may be extended to 17 hr. ard naed not be coincident with a change of operator personnel.

AP&L request of March 1, 1988 stated that the application ef Code Case N-234 would result in a reduction of approximataly 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in the outage critical path time required for the examination and, consistent with health physics ALARA objectives, a reduction of radiation exposure of perternel perfoming the examinatier. Application of Code Case N-234 is in accordarce with the provi-siens of 10 CFR 50.55a(a)(3)(1) in that calibration checks of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during use of the automated ultrasonic examination 'ystens would provide er acceptable level of quality and safety. Further, usino the 'our hour calibration irtervals would increase personnel radiation exposure with no compensating increase in the level of oue14ty and safety. ,

The staff has detemined in acccedance with the provisiers of 10 CFR 50.55a(a)(3) that your request for authorization for use of Code Case N-?34 for the ultrasonic examination of the reactor vessel at previously described provides an acceptable level of cuality and safety, and that requiring the four hcur calibration checks would result ir increased radiation exposure without a comparsating increase in the systens level of quality and safety.

This letter shall serve as authori7ation of your request to use Code Case N-234 in lieu of currently perferring the four hour calibration checks as part of the inservice inspection of the reactor vcssel in accordance with Apperdix I of Section XI o' the ASME Code. ,

The Comiscion hereby authorizes this use of ASME Code Case N-734 for this portion of reactor vessel inservice inspection program pursuert to 10 CFR 50.55a(a)(3) and finds that this use (1) provides an acceptabla level of ouality and safety, (2) that compliance with th* present requirements would i increase radiation axposure not compensated by the resultant increase in I quality ard safety, and (3) is authorized by law asd will not endanger life or property or the comon defense and security and is otherwise ir the public interest.

Sincerely, Jose A. Calvo, Director Project Directorate - IV Division of Peactor Projects - III, IV, V and Special Projects cc: See next page DISTRIRUTION Docket File NRC PDR Local PDR PD4 Reading DR4A/J. Collins J. Calvo P. Noonar G. Dick OGC-Bethesda E. Jordan J. Partlow ACRS (10)

PD4 Plart File C. Harbuck I

• See previous cercurrence i

• PD4/LA *PDA/PM *EMTB OGC PD4/D/M PNoonan GDick:sr /) ,y 5 JCalvo 03/03/88 03/03/88 03/03/88 03/ /88 03//o/88 i l

l

)

t

) ,

code case states that---when perfoming ultrasonic examinations in accordance with either Appendix I or Appendix III of Section XI, Division 1, if automated ultrasonic examination systems are used, the time period between calibration checks required by I-4230 or III-3330 may be extended to 12 hr. and need not ,

be coincident with a change of operator personnel.

AP&L request of March 1,1988 stated that the application cf Code Case N-234 would result in a reduction of approxinately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in the outage critical '

path time required for'the examination and, consistent with health physics ALARA objectives, a reduction of radiation exposure of personnel p;rfoming the  !

examinatien. Application of Code Case N-234 is in accordance with the provi-  ;

siens of 10 CFR 50.55afa)(3)(1) in that calibration checks of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during use of the automated ultrasonic examination rystens would provide an acceptable level of quality and safety. Further, using the four hour calibration intervals would increase personnel radiation exposure with no compensating increase in the level of quality and safety.

The staff has detemined in accordance with the provisiens of 10 CFR 50.55a(a)(3) that your request for authorization for use of Code Case N-234 for the ultrasonic examination of the reactor vessel as previously described provides an acceptable level of cuality and safety, and that requiring the four hour calibration checks would result in increased radiation exposure without a comparsating increase in the systens level of quality and safety.

This letter shall serve as authoriration of your request to use Code Case N-234 in lieu of currently perfoming the four hour calibration checks as part of the inservice inspection of the reactor vessel in accordance with Apperdix ! of  ;

Section XI of the ASME Code.  ;

The Comission hereby authorizes this use of ASME Code Case N-234 for this portion of reactor vessel inservice inspection program pursuant to 10 CFR ,

50.55a(a)(3) and finds that this use (1) provides an acceptable level of  :

quality and safety, (2) that compliance with the present requirements would increase radiation exposure not compensated by the resultant increate in ,

quality ard safety, and (3) is authorized by law snd will not endanger life or l property or the comon defense and security and is otherwise in the public  :

interest.

Sincerely, ,

i Jose A. Calvo, Director i Project Directorate - IV Division of Peactor Projects - III, ,

IV, V and Special Projects cc: See next page  !

DISTRIBUTION l

'lfDoctetJ11e. NRC POR Local PDR PD4 Reading l DR4A/J. Collins J. Calvo P. Noonar G. Dick

• OGC-Bethesda E. Jordan J. Partlow ACRS(10)

PD4 Plant File C. Harbuck ,

• See previous cercurrence

• PD4/LA *PD4/PM *EMTB OGC[ PD4/D/M PNoonan GDick:sr /) ;/ < JCalvo 03/03/88 03/03/88 03/03/P8 03/ /88 03/ /c/R8

r j

.p.

code case states that---when performirg ultrasonic examinations in accordance -

! with either Appendix ! or Appendix III of Section XI, Division 1, if automated 4 ultrasonic examination systens are used, the time period between calibration  :

checks required by I-4230 or 111-3330 may be extended to 12 hr. and need not i i be coincident with a change of operator personnel.  ;

AP&L' request of March 1, 1988 stated that the application of Code Case N-234 )

would result in a reduction of approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in the outage critical  !

. path time required for the examination and, consistent with health physics  ;

ALARA objectives, a reduction of radiation exposure of personnel performing the l

examination. Application of Code Case N-234 is in accordance with the provi-sions of 10 CFR 50.55(a)(3)(1) in that calibration checks of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during use of the automated ultrasonic examination systens would provide an acceptable j level of quality and safety. Further, using the four hour calibratien intervals l would increase personnel radiation exposure with ro compensating increase in l

the level of cuality and safety. j 1

i The staff has detemined in accordance with the provisions of 10 CFR 50.55a(a)(3) that your request for authorization for use of Code Case N-234 for the ultrasonic i examination of the reactor vessel as previously described provides an acceptable  !

level of quality and safety, and that requiring the four hour calibration checks  !

i would result in increased radiation exposure without a compensating increase in  :

the systers level of quality and safety. .

This letter shall serve as authorization of your request to use Code Case N-234 in lieu of currently perfoming the four hour ca.libration checks as part of the '

! inservice inspection of the reactor vessel in accordance with Appendix ! of Section XI of the ASME Code, f The Comissier hereby authorizes this use of ASME Code Case N-?34 for this

portion of reactor vessel inservice inspection program pursuant to 10 CFR i 50.55a(a)(3) and finds that this use (1) provides an acceptable level of i

quality and safety. (?) that compliance with the present requirements would  !

l increase radiation expcsure not compensated by the resultant increase in '

i quality and safety, and (3) is euthorized by law and will not endanger life or i property or the comon defense and security and is otherwise in the public l i interest. >

] 'Sircerely, .

Jose A. Calvo, Director i Project Directorate - IV 2

Division of Reactor Projects - III, i IV, V and Special Projects cc: See next page

! DISTRIBUTION l Docket File .NPC PDR Local PDP PD4 Reading

DR4A/J. Collins J. Calvo P. Nooran G. Dick J. Partlow j OGC-Bethesda E. Jordan ACRS (10)

! PD4 Plent file C. Harbuck 4 PD4/LAPNoonan h k/PM A ( ek:sr h

O(WWT OGC PD4/D JCalvo i 03j/88 03/63/88 03/3/88 03/ /88 03/ /88 i

-. -_ . . _ _ _ _ _ . _ - _ _ _ _ ~_ . _ _ . , _ . _ . _ _ _

_ , _ _ _ . . . . _ _ . _ _ . _ . _ l