ML20236U705

Safety Evaluation Granting All Requests for Relief W/Exception of Requests RR-89-17 (Authorized for Class 1 Sys Only) & RR-89-21.Requests RR-13 & RR-14 Will Be Addressed in Separate Evaluation

ML20236U705
Person / Time
Site:	Millstone
Issue date:	07/22/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236U697	List: ML20236U695 ML20236U705 ML20236U724
References
NUDOCS 9807300386
Download: ML20236U705 (4)

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%, ....+l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF NOBTJiEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT NO. 2 DOCKET NO. 50-336

1.0 INTRODUCTION

The Technical Specifications (TSs) for the Millstone Nuclear Power Station Unit No. 2, state that the inservice inspection (ISI) of the American Society of Mechanical Engineers (ASME)

Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (ASME Code) and applicable addenda as required by Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(6)(g)(i). Section 50.55a(a)(3) states that alternatives to the require.ments of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives 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.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI,'" Rules for Inservice inspection of Nuclear Power Plant Components," to the exterit 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 addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for Millstone Nuclear Power Station, Unit 2, third 10-year ISI intervalis the 1989 Edition. The third 10-year interval began December 26,1996, and will end December 25,2006 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, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement.

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9807300386 980722 Enclosure 1 PDR ADOCK 05000336 p PM l

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4 After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose attemative requirements that are determined 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 July 2,1996, Northeast Nuclear Energy Company (NNECO, licensee) submitted its Third 10-Year ISI Program Plan and associated requests for relief (RRs) and proposed attematives (pas) for Millstone Nuclear Power Station, Unit No. 2. Additional information was provided by NNECO in its letters dated March 20,1997, and August 28,1997.

In addition, by letter dated October 31,1997, NNECO submitted an additional request to use the provisions of Code Case N-522 as a PA in the third 10-year ISI interval.

t 2.0 EVALUATION l

l The NRC staff, with technical assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), has evaluated the information provided by the licensee in support of its Third 10-Year ISI Program Plan, Revision 2, and associated RRs for Millstone Nuclear Power Station, Unit No. 2. Based on the results of the review, the staff adopts INEEL's evaluations, recommendations, and conclusions presented in its Technical Evaluation Report (TER), INEEL/ EXT-97-00994, dated January 1998, with the exception of a typographical error in RR-89-17, where INEEL referenced Class 3 systems in its evaluation of the relief.

l NNECO only requested to use Code Case N-533 for Class 1 and 2 systems.

A total of 26 RRs and pas were requested of which 20 were found acceptable, one was partially approved, one was denied, two are being reviewed independent of this effort, two are l related to inservice testing and are not within the scope of this review. For supporting technical I details, justifications, and conclusions for granting reliefs or authorizing alternatives or denying the licensee's requests for relief, refer to the INEEL TER. The following paragraphs summarize 4 the results of the staff's and INEEL's review.

RR-89-01, RR-89-02, RR-89-03, RR-89-06, RR-89-07, RR-8910, RR-8911, RR-89-12, and -

, RR-89-14: Pursuant to 10 CFR 50.55a(g)(6)(i), the staff has determined that the Code i requirements for these requests are impractical. Furthermore, the proposed alternatives provide reasonable assurance of structuralintegrity or operational readiness of the subject systems and components. Based on the impracticability of complying with the Code requirements and the burden on the licensee if the Code requirements were imposed, and considering the proposed examination, relief is granted for these requests for the third 10-year inservice inspection interval. The staff concludes that the relief granted will not endanger life, property, or the common defense and security, and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

RR-89-04 (Code Case N-521), RR-89-05, RR-89-08, RR-89-16, PA N-546, PA N-524, and

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PA N-535: Pursuant to 10 CFR 50.55a(a)(3)(i), the staff determined that the proposed i attematives contained in these requests provide an acceptable level of quality and safety, i

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! l' Therefore, the staff concludes that the attematives contained in the above requests are  !

authorized for the third 10-year inservice inspection interval.

RR-89-18 (Code Case N-547), PA N-5??, PA N 416-1, and PA N 490-1: Pursuant to 10 CFR l ^ 50.55a(a)(3)(ii), the staff has determined that compliance with the Code requirements for these l requests would result in hardship or unusual difficulty without a compensating increase in the I l level of quality and safety, Furthermore, NNECO's propo";ed attematives provide reasonable assurance of operational readiness of the subject systems. The licensee's proposed l alterr atives contained in these RRs are authorized for the third 10-year inservice inspection  ;

interval.

J RR-89-17 (Code Case N-533): The alternative preposed in this request is to apply Code Case N-533 to Class 2 systems as well as Class 1 systems. The staff has determined that the.

application of Code Case N-533 to Class 2 systems is unacceptable. The proposed frequency l (Code Period) of 40 months or greater could result in a period of greater than 6 years between inspections. Therefore, the proposed alternative to use Code Case N 533 for Class 2 systems is denied. However, pursuant to 10 CFR 50.55a(a)(3)(ii), the staff has determined that Code >

Case N 533 is acceptable for Class 1 systems, because the inspections are performed every outage verses every Codo Period and compliance with the Code requirements for Class 1  !

systems would result in a burden without a compensating increase in safety, in addition, .

NNECO's proposed alternative to use Code Case N-633 for Class 1 systems provides  ;

reasonable assurance of continued operational readiness of the Class i boltea connections,  !

l therefore, the use of Code Case N-533 for Clast 1 systems is authorized and for the third 10-year inservice inspection interval.

l RR-89-21: The staff denies this request. NNECO has not demonstrated that the Code i requirements are impractical as required by 10 CFR 50.55a(g)(6)(i) or represents a hardship or unusual difficulty without a compensatory increase in the level of quality and safety as required by 10 CFR 50.55a(a)(3)(ii).

RR-89-19 and RR 89 20: These requests are related to inservice testing (IST) requirements and are not in the scope of this review. The IST requests were approved by the staff and the

. a' pproval and supporting safety evaluation were provided by an NRC letter dated July 1,1998.  ;

t RR 13 and RR-14: These requests will be addressed in a separate evaluation. ,

in addition to the above, the staff noted that NNECO is not performing inservice volumetric, i surface, and visual examinations on ASME Code Class 1,2, and 3 components, and their supports using sampling schedules as described in Section XI of the ASME Code and 10 CFR 50.55a(b), and the licensee has not requested relief from the schedules. NNECO must submit a relief request if it is going to use an alternative schedu!e in lieu of the Code requirements.

3.0 CONCLUSION

t Based on the review of the Millstene Nuclear Power Station, Unit No. 2, Third 10-Year Interval ISI Program Plan, Revision 2, NNECO's responses to the staffs requests for additional <

information, and the recommendations for granting relief from the ISI examinations that cannot

4-be performed to the extent required by Section XI of the ASME Code, no deviations from regulatory requirements or commitments were identified and the following requests are granted or authorized:

Pursuant to 10 CFR 50.55a(g)(6)(i), RR-89-01, RR-89-02, RR-89-03, RR-89-06, RR-89-07, RR-89-10, RR-89-11, RR-89-12, and RR-89-14 are granted for the third 10-year inservice  !

inspection interval. The relief granted is authorized by law and will not endanger life, property, ;

j or the common defense and security, and is otherwise in the public interest, giving due  !

l consideration to the burden upon the licensee that could result if the requirements were  ;

imposed on the facility.

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Pursuant to 10 CFR 50.55a(a)(3)(i), the alternatives proposed in RR-89-04 (Code Case N-521),

RR-89-05, RR-89-08, RR-89-16, PA N-546, PA N-524, and PA N-535 provide an acceptable level of quality and safety and are authorized fer the third 10-year inservice inspection interval.

l Pursuant to 10 CFR 50.55a(a)(3)(ii), the staff has determined that compliance with the Code requirements for RR-89-18 (Code Case N-547), PA N 522, PA N-416-1, and PA N 498-1 l

would result in hardship or unusual difficulty without a compensating increase in the level of  ;

quality and safety. Furthermore, NNECO's proposed attematives provide reasonable  !

assurance of operational readiness of the subject systems. The licensee's proposed l attematives contained in these RRs are authorized for the third 10-year inservice inspection l interval.

Pursuant to 10 CFR 50.55a(a)(3)(ii), RR-99-17 (Co;'e Case N-533) is authorized for Class 1 l

systems and denied for Class 2 systems. l RR-89-21 is denied and RR-13 and RR-14 will be addressed in a separate evaluation. 1 RR-89-19 and RR-89-20 were previously approved for inservice testing.  !

The alternatives contained in RR-89-04 (Code Case N-521), PA N-522, PA N-416-1, PA N-498-1, PA N 546, PA N-524, and PA N-535 are authorized for the third 10-year interval or until such time as the Code Cases are published in Regulatory Guide 1.147. At that time, if NNECO intends to continue to implement any of the Code Cases when they are published, it must follow all provisions in the published Code Cases with the limitations issued in Regulatory i Guide 1.147, if any are published in the regulatory guide.

Principal Contributor: T. McLellan Date: July 22, 1998 l

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