ML20202F076
| ML20202F076 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/02/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20202F074 | List: |
| References | |
| NUDOCS 9712090003 | |
| Download: ML20202F076 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION wAsHmotoN o.C. seseHept RAFETY EVAlt.1ATION BY 'fHE OFFICE OF NUCLEAR REACTOR REGULATION f
OF THE THIRD 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUEST FOR RELIEF CR 13. RIEVISION 1 EDE i
COMMONWEALTH EDICON COMPANY 1
ElON NUCLEAR POWER STATION. UNITS 1 AND 2 4
DOCKET.NOS,50-295 AND 50 304 l
1.0 INTRODUCTION
The Technical Specifications (TS) for Zion Nuclear Power Station, Units 1 and 2, state that the inservice inspection of the American Society of Mechanical Engineerr (ASME) Boiler and Pressure Vessel Code (Code) Class 1,2, and 3 components shall be perforr9ed in accordance i
with Section XI of the ASME Code and applicable addenda as required by 10 CFR 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Pursuant to 10 CFR 50.55a(s)(3) attematives to the requirements of paragraph i
(g) may be used, when authorized by the NRC, if (i) the proposed altematives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardsnip or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.b5a(p)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre.
service examination requirements, set forth in the ASME Code, SMion XI, " Rules for Inservka inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and 4
addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55s(b)
'12 months prior to the start of the 120-month interval, subject to the limitations and l
modifications listed therein.
The appFcable edition of Section XI of the ASME Code for the current Zion Nuclear Power
' Station, Units 1 and 2, third 10 year !nservice inspection (ISI) interval is the 1989 Edition.
Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, ENCLOSURE 9712090003 971202 PDR ADOCK 05000295 O
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2-information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose altomative requirements that are determinad to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.
By letter dated March 1,1996, Commonwealth Edison Company (Comed), submitted Request for Relief CR 13, flevision 1, from the ASME Section XI requirements for Zion Nuclear Power Sistion, Units 1 and 2. Comed providert additionalinformation in a "A97010, Requests Authorization for Alternative to One Time Augmented Insp of RPV Shell Welds Set Forth in 10CFR50.55a(g)(6)(ii) (A)(2) Per [[CFR" contains a listed "[" character as part of the property label and has therefore been classified as invalid.(5).Authorization to Use Partial Insp Coverage Requested|letter dated August 13, 1997]].
2.0 EVALUATION The staff, with technical assistance from its contracter, the Idaho National Engineering and Environmental Laboratory (INEEL), has evaluated the information provided by Comed in support of its third 10-year inservice inspection interval program plan Roquests for Relief CR 13 Revision 1, for Zion Nuclear Power Station, Unit 1 and 2. Based on the results of the review, the staM concludes the following:
Relief Request CR 13, Revision 1: The Code,Section XI, lWA 5242(a) requires that for systems borated for the purpose of controlling reactivity, insulation shall be removed from pressure retaining bolted connections for VT 2 visual examination. Pursuant to 10 CFR 50.55a(a)(3)(li), comed proposed an altemative to the ASME Section XI requirements for removing insulation from Class 1 and Class 2 pressure retalning bolted connections during VT 2 visual examination. Comed stated:
'A system pressure test and VT 2 visual examir,ation shall be performed each refueling outage without removal of insulation, after a minimum 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time, on systems borated for the purpose of controlling reactivity.
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- Each refueling outage, removable insblation shall be remo ted from bolted connections l
In systems borred for the purpose of controlling reactivity, and a VT 2 visual I
examination shall be performed on the connections prior to conducting any activities that could remova evidence of leakage that may have occurred during the previous operating cycle. During this VT 2 examination, the connections are not required to be pressurized.
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Any evidence of leakage shall be evaluated in accordance with IWA 5250 (as modified j
by approved Relief Request CR 14).
'These altematives will provide reasonable assurance that safety and integrity will be maintained for bolted connections in ;ystems borated for the purpose of controning l
reactivity."
Paragraph IWA 5242(a) requires the removal of all inselation from pressure-retaining bolted connections in systems borated for the purpose of controlling reactivity when performing VT 2 visual examina'jon during system pressure terts. Comed has proposed that each refueling
3 outs.ge, remove 6As insulation shall be removed from boHed connections in systems borated for the purpose of controlling reactivity, and a VT 2 visual examination shall be performed.
4 in the submittel dated August 13,1997 Comed defined removable insulation as stainless steel reflective insulation with quick release bucides. Non removable insulation was def;ned as Calcium Silicate or fiberglass insulation banded in place and covered with an aluminum jacket that is secured by metal banding or sheet metal screws, it was also rWed in Comed's v bmittal, that the removabAo insulation is located only on the Reactor Coolant System aind portions of the Class 1 Safety injection and Residual Heat Removal systems. Comed did net identify any portions of Class 2 systems with removable insulation.
The purpose of a VT 2 visual examination is to look for evidence of leakage so that, if leakage has occurred, corrective action may be taken. Because certain Class 1 and Class 2 systems are required for the safe shutdown of the plant (i.e., provide emergency shutdown features), it is technically prudent to monitor the integrity of all bolted connections on these systems by removing the insulation sare refueling outage on hglb Class 1 and Class 2 systems borated for the purpose of controlling reactivity. Therefore, the staff concludes that Comed's proposed aHemative for removing only insulation classified as removable /nsulation each refueling outage is unacceptable and the proposed attemative is denied.
3.0 CONCLUSION
S The staff has reviewed Comed's submittels and concludes tr.at Comed's proposed allemative contained in Request for Relief CR 13, Revision 1, of removing only the insulati:,n classified as removable, does not provide an acceptable level of quality and safety. Therefore, Comed's proposed altemative is denied.
Principal Contributor. T. McLellan Cated:
December 2, 1997 I
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