ML20150D063
| ML20150D063 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/15/1988 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NMP1L-0235, NMP1L-235, TAC-60451, NUDOCS 8803230068 | |
| Download: ML20150D063 (4) | |
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N3 MINA NIAGARA MOH AWK POWER CORPOR ATloN'301 PLAINFIELD ROAD. SYRACUSE, N Y.13212t TELEPtioNE (315) 474 1511 March 15, 1988 NMP1L 0235 U.S. Nuclear Regulatory Commission Attn: Doce.aent Control Desk Hashington, D.C. 20555 Re:
Nine Mile Joint Unit 1 Docket No. 50-220 DPR-63 Gentlemen:
This letter provides Niagara Mohawk's response to your request dated December 15, 1987, for additional information on the Inservice Inspection Program (TAC 60451). A specific response to each of your questions is provided in Attachment A.
Nine Mile Point Unit 1 is currently shutdown for refueling.
He are performing Inservice Inspections in accordance with our second ten year interval program.
In addition, we aie performing additional examinations and evaluations as necessary to support our requests for relief.
Revised celief requests will be submitted within three menths after completicn of the refueling outage.
Very truly yours, NIAGARA MOHAWK P0HER CORPORATION
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C. V. Mangan Senior Vice President KBT/pns 4594G cc: Regional Administrator, Region I Mr. R. A. Capra, Director Mr. R. A. Benedict, Project Manager Mr. H. A. Cook, Resident Inspector 0g A
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9803230068 880315 PDR ADOCK 05000220 0
ATTACHMENT A Nine Mile Point Unit 1 Inservice Inspection Additional Information on Relief Requests 1.
Request for Relief IIIRR2 for the first interval and ISI-9 for the second interval:
Relief is requested from examining 100% of the Code-required volume of all welds in 10% (equal to four) of the peripheral CR0 housings.
The licensee states that the subject welds cannot be fully inspected ultrasonically due to limitations of design.
The coverage of each of the four ultrasonically examined CRD housing welds is estimated to be 50% of the Code-required volume.
A sector of approximately 180 degrees of each housing circumference is obstructed by adjacent housings and their hydraulic lines.
Can 50% of four additional welds be examined.in order to meet the intent of the 10% Code requirement?
Response
Niagara Mohawk will examine 50% of four (4) additional CRD housings in order to meet the intent of the Code requirement.
Relief Request ISI-9 will be revised after the refueling outage.
2.
Request for Relief ISI-l for the second interval:
Relief is requested from performing the Code-required volumetric examination of the beltline region welds.
The licensee states that the Code-required volumetric examination of the welds in the beltline region is impractical based on the existing design which precludes access to the welds.
All Item No.
Bl.10 welds that are accessible for volumetric examination should be examined as an alternative to the examination of the beltline region welds.
Identify those welds which will be examined as an alternative to examining the beltline region welds.
Response
Niagara Mohawk will solumetrically examine all Item No. Bl.10 wolds that are accessible.
Relief Request IEl-1 will be revised to indicate the welds that will be examined.
In addition, we are investigating alternative techniques for examining welds in the beltline region.
3.
Request for Relief IIIRR4A for the first interval:
Relief is requested from performing the Code-required visual examination of internal pressure boundary surfaces of one of the required ten Group 9 - Reactor Vessel Head Safety Valves in the ma'n Steam system.
The licensee also requests relief from the requirements to examine valve bodies by qualified examiners per i
Section XI Subarticle IWA-2300 and to document results and evaluations in accordance with Section XI Article IWA-6000.
The licensee states:
"Group 9 valves reco1ved maintenance inspections by the Owner's quality control person'nel.
Other maintenance inspections were performed when all Group 9 valves were refurbished.
Fifty percent of the valves are rotated out of service and are replaced by spares each refueling outage.
All were sent off-site each outage for refurbishing and testing prior to being returned to service or placed in storage as spares.
Relief is requested from the examiner qualification and certification requirements of Section XI Subarticle IWA-2300 and documentation requirements of Article IWA-6000, Documentation, inspector certification of training and qualification, specific visual findings of valve body and other internal pressure retaining surfaces, and evaluation of results are not in place.
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inspection similar to that required is directly evidences by selective replacement, repair or adjustment of parts and indirectly by accomplishment of pressure and operability tests conducted off-site."
No technical basis for requesting relief is supplied in this relief request.
During the time the valves were off-site, were examinations performed that were equivalent or superior to the Code-required visual examination? As stated in IHA-2240 of Section XI, alternative examination methods, a combination of methods, or newly developed techniques may be substituted for the methods, specified in Section XI, provided the Inspector is satisfied that the results are demonstrated to be equivalent or superior to those of the specified method.
If an IHA-2240 evaluation cannot be performed by an Authorized Nuclear Inservice Inspector (ANII) and, thus, relief is still requested, provide explicit information to justify why relief should be granted.
Response
The Reactor Head Safety Valves were examined, overhauled and tested by Hyle Laboratories.
In our opinion, the examinations performed were equivalent to an ASME XI examinations except for:
The inspection procedure did not reference ASME XI.
The inspector was not certified to an ASME XI program.
He was certified in accordance with Wyle Labs QA program.
The inspection was not witnassed by the Authorized Nuclear Inservice Inspector (ANII)
The documentation provided by Hyle Labs was used as the basis for accepting the valves.
This documentation is available on site for further review.
Similarly, the Main Steam line valves were examined by Niagara Mohawk personnel quallfled in accordance with our Quality Assurance procedures.
These examinations are equivalent to an ASME XI examination except that:
The inspection procedure did not reference ASME XI.
The inspector was not certified to an ASME program.
The inspection was not witnessed by the Authorized Nuclear Inservice Inspector (ANII).
The documentation for these examinations is available on site for further review.
No relief is requested for the second ten year interval because both the Reactor Head Safety Valves and the Main Steam line valves will be examined in accordance with ASME XI requirements.
4.
Requests for Relief IIIRR8A and IIIRR8B for the first interval and ISI-10 for the second interval:
The licensee states that a significant portion of the welds for which relief is requested is inaccessible for examination and requests total relief from the Code-required volumetric examination.
For each of the subject welds, provide an estimate of the percentage of the Code-required volume that is accessible for examination.
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Response
During the current outage we will take' detailed data'for each weld. This information will.'be provided in a revised' relief request.-
5.
Request for Relief IIIRR3 for the first interval:. The licensee Ilits two reactor recirculation pump casing welds (32-SW-ilS-0 and 32-SH-15S-9) that r
received a liquid penetrant examination.
Verify that weld number 32-SW-15S-9 is the correct weld number,
Response
The correct-weld number is 32-SH-15S-0.
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