ML20198J059
| ML20198J059 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/22/1998 |
| From: | Hartz L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 98-696, NUDOCS 9812300079 | |
| Download: ML20198J059 (2) | |
Text
.
~
Vincisir Ei.EcTHIC AND POWER CON 11%NY Ricusioso, VINGiNI A 232fil December 22, 1998 United States Nuclear Regulatory Comm;ssion Serial No.98-696 Attention: Documsnt Control Desk NL&OS/ETS R0 Washington, D.C. 20555 Docket No.
50-338 License No.
NPF-4 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 1 ASME SECTION XI INSERVICE INSPECTION PROGRAM A public meeting was held in Rockville, Maryland between NEl and the NRC on October 8,1998. It was noted at that meeting that the NRC would be willing to allow a two year delay in submitting a revised inservice inspection (ISI) program, if a licensee develops either a full or partial risk informed inservice inspection (RI-ISI) program for piping as part of the interval updata. The delay would only apply to the portion of the piping system being evaluated under the RI-ISI process.
The other portions of the ISI program would be required to be submitted in accordance with 10 CFR 50. It was further stated that examinations (NDE), on the piping to be included in the risk-informed scope, could be deferred during these two years until the Rl-ISI program was completed.
However, Code required pressure testing, repairs or replacements, and associated augmented inspections programs would continue to be implemented as required.
The i
stipulation for the examination deferral was that the examinations required for the new interval by the RI-ISI program would still be completed by the end of the Intervalincluding any ASME Code allowed extensions. The NRC staff indicated j
that generic guidance was being prepared detailing this option.
I North Anna Power Station Unit 1 will be updating to the third inspection interval of the inservice inspection program on April 30,1999 (ASME Section XI, Program B). The new interval program is being developed to the requirements of the 1989 Edition of ASME Section XI. The program is being developed at this time.
Our experience with the Westinghouse Owner's Group RI-ISI pilot plant project at Surry has convinced us of the benefits of a RI-ISI program and we propose to apply such a program to the piping for North Anna Unit 1. A RI ISI program has the potential to reduce costs and radiation exposure, while maintaining the 9
current high levels of safety at the plant.
A partial scope (Class 1) RI-ISI I
program on piping is being initially planned at North Anna Unit 1. However, time g
nA n
~
9812300079 981222 PDR ADOCK 05000338 G
PM l
t
\\
=
j constraints will not permit us to develop a Rl ISI program for North Anna Unit 1 l
' without a schedule delay for implementing a revised ISI program. As such, the limited time to develop a Rl-ISI program places an unnecessary hardship (e.g.,
unnecessary examination costs and personnel exposure) on the plant without a i
compensating increase in safety, as it would require development and implementation of a 1989 ASME Code ISI program for compliance.
Therefore, pursuant 10 CFR 50.55a(a)(3)(ii), Virginia Electric and Power requests a delay in submitting North Anna Power Station Unit 1's Class 1 piping l
lSi program (NDE, Categories B-F and B-J) for the third inspection interval until April 30,2001, to permit development of a RI-ISI program for Class 1 piping.
If you have any questions or require additional information, please contact us.
Very truly yours, 4
L. N. Hartz Vice President - Nuclear Engineering and Services Commitments made in this letter:
Submit North Anna Power Station Unit 1 Class 1 piping ISI program for the third inspection interval by April 30,2001.
cc:
U. S. Nuclear Regulatory Commission Region 11 Atlanta Federal Centur 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. J. Morgan NRC Senior Resident inspector North Anna Power Station Mr. M. Grace Authorized Nuclear Inspector North Anna Power Station
,