ML20236K697

SER Accepting Third 10-year Interval Inservice Insp Program Plan,Rev 2 & Associated Request for Relief & Proposed Alternatives for Plant,Unit 2

ML20236K697
Person / Time
Site:	Millstone
Issue date:	07/01/1998
From:	NRC (Affiliation Not Assigned)
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ML20236K692	List: ML20236K688 ML20236K697
References
NUDOCS 9807100047
Download: ML20236K697 (4)

Text

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attg g'e k UNITED STATES g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-4001

$g i SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIOE RELATED TO THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION EBOGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT NO. 2 DOCKET NO. 50-336

1.0 INTRODUCTION

Title to of the Code of Federal Regulations (10 CFR), Section 50.55a requires that certain American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 components meet the requirements of Section XI of the ASME Boiler and Pressure Vessel Code (ASME Code) and applicable addenda, except where relief has been requested and granted or proposed attematives have been authorized by the Commission pursuant to 10 CFR 50.55a(f)(6)(i) and (g)(6)(i) when it has been demonstrated that the Code requirements are impractical. Section 50.55a(a)(3) states that attematives to the requirements of paragraphs (f) and (g) may be used, when authorized by the NRC, if (i) the proposed attematives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

By letter dated July 2,1996, as supplemented by letters dated March 20,1997, August 28, 1997, and October 31,1997. Northeast Nuclear Energy Company (NNECO) submitted its Third 10-Year Inservice Inspection (ISI) Program Plan, Revision 2, and associated requests for relief (RRs) and proposed attematives (pas) for Millstone Nuclear Power Station, Unit No. 2. This Safety Evaluation (SE) addresses two requests relating to NNECO's inservice testing (IST) program, RR-89-19 and RR-89-20, which request relief from the visual examinations and functional testing requirements for snubbers and the requirement to develop a replacement plan when removing pressure relief valves for testing, respectively. The remainder of NNECO's submittal, relating to its ISI program, is being evaluated by the staff in separate actions.

2.0 EVALUATION j l

2.1 Reauest RR-89-19: l NNECO requests relief from the snubber visual examinations and functional testing requirements of ASME Code,Section XI, Paragraph IWF-5000.

Proposed Altemative:

NNECO proposes to use the Millstone, Unit No. 2, Technical Specifications (TSs), in lieu of Paragraph IWF-5000 requirements, for hydraulic and mechanical snubber examination and testing.

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Ehclosure L

D Basis for Requesting Relief:

The requirements in the existing Millstone, Unit No. 2, TSs provide for hydraulic and mechanical snubber support inspections and functional testing that equals or exceeds those of the applicable 1989 Edition of ASME Code,Section XI, Paragraph IWA 5000.

Assessment:

The'ASME Cod (e,1989 Edition,Section XI, Paragraph IWF 5000 requirements for visual inspection and functional testing of snubbers are contained in Paragraph IWF-5300, "lNSERVICE EXAMINATION 3 AND TESTS." Paragraph IWF-5300 defers these requ;rements to the first addenda to ASME/ ANSI OM-1987, Part 4, which was published in 1988.

Generic Letter (GL) 90-09, "Altemative Requirements for Snubber Visual inspection Intervals and Corrective Actions," provides an alternative schedule for snubber visual inspections that maintains the same confidence level as the Code required insp". tion lew , and allows for inspections and corrective actions during plant outages. The GL guidanve on the inspection interval is based on the number of unacceptable snubbers identified in the last inspection in -

proportion to the size of the various snubber populations and categories. The Code required intervalis based only on the number of unacceptable snubbers identified during the last inspection without regard to the population. The staff has determined that the visualinspection schedule included in GL 90-09 is an acceptable attemative and has encouraged licensees to amend their TSs to incorporate the guidance provided in the GL. NNECO has incorporated the guidance provided ir) the GL in the Millstone, Unit No. 2, TSs.

In relation to the snubber testing requirements, the Millstone, Unit No. 2, TSs are consistent with the testing requirements of the ASME Code,1989 Edition,Section XI, Paragraph IWF-5300, and provide an acceptable level of quality and safety. ,

Summary:

Pursuant to 10 CFR 50.55a(a)(3)(ii), the staff has determined that the proposed altemative provides an accepiable level of quality and safety and that compliance with the applicable portions of the Code requirements will result in a hardship without a compensating increase in the level of quality and safety. ,

2.2 Request RR-89-20:

NNECO requests relief from the ASME Code,Section XI, Paragraph IWA 7000 requirements, which requires that a replacement plan be developed when removing ASME Code Class 1,2, and 3 pressure relief valves for testing. The staff approved the use of Code Case N-508-1 in its SE dated December 15,1995, as an altemative to the requirements of IWA 7000 for the second 10-year IST interval at Millstone, Unit No. 2.

Proposed Alternative:

NNECO proposes to continue to use the Code Case for the third 10-year IST interval as an attemative to the IW/.-7000 requirements in regards to developing a replacement plan when removing pressure relief valves for testing.

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Basis for Requesting Relief; The attemat;ve provided in the Code Case is to allow relief valves to be rotated from stock and

' installed on components, including piping systems, within the Section XI boundary, provided that requirements (a) through (i) stated in the Code Case are met. Code Case N-500-1 was approved by the ASME on May 11,1994.

i Assessment:  !

As noted, the staff has previously approved the use of this Code Case at Millstone, Unit No. 2, for its second 10-year IST interval.' NNECO indicated that it met all nine requirements specified in (a) through (i) of the Code Case. In addition, by letter datej July 21,1995, the staff requested that NNECO provide a detailed description of how the Code Case would be used and a clarification of NNECO's interpretation of, "same design and construction," aa stated in the Code Case.

By letter dated August 25,1995, NNECO responded indicating that it has a comprehensive plan in conjunction with its relief valve testing activities and that the term, "same design and construction," was interpreted to mean identicalin manufacturer, model, and part number. The staff determined in its SE dated December 15,1995, that the safety characteristics of NNECO's proposed replacement plan remained unchanged and the use of this Code Case provided an acceptable level of quality and safety and approved the use of the Code Case for the second 10-year IST interval. By letter dated August 28,1997, NNECO confirmed that its responses I provided in the August 25,1995, letter remain valid for the third 10-year IST interval.

Summary:

' Pursuant to 10 CFR 50.55a(a)(3)(i), the staff r.as determined that the proposed use of Code Case N-508-1 as an altemative provides an acceotable 'evel of quality and safety.

3.0 CONCLUSION

The staff has determined that the pror.osed altemative provided in RR-89-19, which is to use the Mi!Istona, Unit No. 2, TSs in lieu of the ASME Code, Section X1, Paragraph IWF.5000 requirements for snubber examination and testing, provides an acceptable level of quality and safety arid that compliance with the applicable portions of the Code requirements will result in a hardship without a compensating increase in the level of quality and safety. Therefore, the proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

The staff has also determined that the proposed use of Code Case N-508-1, requested in RR-89-20, as an altemative to the ASME Code,Section XI, IWA-7000 requirements for developing a replacement plan when removing pressure relief valves for testing, provides an acceptable level of quality and safety and is, therefore, authorized pursuant to 10 CFR SC,.55a(a)(3)(i). The use of this Code Case is authorized for the third 10-year IST interval or until it is included in a future revision of RG 1.147. At that time, NNECO is to follow all provisions in the Code Case, with limitations issued in the RG, if any, should NNECO continue to use the Code Case.

Principal Contributors: K.' Dempsey F. Grubelich Date: July 1, 1998

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Millstone Nuclear Power Station Unit 2 cc:

Lillian M. Cuoco, Esquire Mr. F. C. Rothen Cenior Nuclear Counsel l

Vice President - Work Services '

Northeast Utilities Service Company Northeast Utilities Service Company P. O. Box 270

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P. O. Box 128 1 Hartford, CT 06141-0270 Waterford, CT 06385 Mr. John Buckingham Emest C. Hadley, Esquire Department of Public Utility Control 1040 B Main Street Electric Unit P.O. Box 549 10 Liberty Square West Wareham, MA 02576 I New Britain, CT 06051 Mr. John F. Streeter Mr. Kevin T. A. McCarthy, Director Recovery Officer - Nuclear Oversight Monitoring and Radiation Division Northeast Utilities Service Company Department of Environmental Protection P. O. Box 128 79 Elm Street Waterford, CT 06385 ,

Hartford, CT 06106-5127 l Mr. David B. Amerine Regional Administrator, Region l Vice President - Human Services U.S. Nuclear Regulatory Commission Northeast Utilities Service Company 475 Allendale Road P. O. Box 128 King of Prussia, PA 19406 Waterford, CT 06385 First Selectmen Mr. Allan Johanson, Assistant Director Town of Waterford Office of Policy and Management Hall of Records Policy Development and Planning 200 Boston Post Road Division Waterford, CT 06385 450 Capitol Avenue - MS# 52ERN P. O. Box 341441 Mr. Wayne D. Lanning Hartford, CT 06134-1441 Deputy D.: rector ofInspections Special Projects Office Mr. M. H. Brothers 475 Allendale Road Vice President - Operations King of Prussia, PA 19406-1415 Northeast Nuclear Energy Company P.O. Box 128 Charles Brinkman, Manager Waterford, CT 06385 Washington Nuclear Operations ABB Combustion Engineering Mr. J. A. Price 12300 Twinbrook Pkwy, Suite 330 Director - Unit 2 Rockville, MD 20852 Northeast Nuclear Energy Company P.O. Box 128 Senior Resident inspector Waterford, CT 06385 Millstone Nucleat Power Station clo U.S. Nuclear Regulatory Commission P.O. Box 513 Niantic, CT 06357 l.

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Millstone Nuclear Power Station Unit 2 cc:

Mr. B.~ D. Kenyon (Acting) Attomey Nicholas J. Scobbo, Jr.

Chief Nucler Officer- Millstone Ferriter, Scobbo, Caruso, Rodophele, PC

, Northeast Nuclear Energy Company 1 Beacon Street,11th Floor

- P.O. Box 128 Boston, MA 02108

! Waterford, CT 06385 Mr. J. P. McElwain Citizens Regulatory Commission Recovery Officer - Millstone Unit 2

' ATTN: Ms. Susan Perry Luxton Northeast Nuclear Energy Company 180 Great Neck Road P. O. Box 128 Waterford, CT 06385 Waterford, Connecticut 06385 Deborah Katz, President.

Citizens Awareness Network P. O. Box 83 Shelbume Falls, MA 03170 i

. The Honorable Terry Concannon Co-Chair Nuclear Energy Advisort Council Room 4035 Legislailve Office Building Capitol Avenue Hartford, CT 06106 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P. O. Box 0630 Niantic, CT 06357-0630 Mr. Daniel L. Curry Project Director Parsons Power Group inc.

2675 Morgantown Road Reading, PA 19607 Mr. Don Schopfer Verification Team Manager Sargent & Lundy 55 E. Monroe Street Chicago,IL 60603 i

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