ML20236W002

Safety Evaluation Accepting Request for Relief NDE-R020 Re Third 10-yr ISI Interval of Plant,Per 10CFR50.55a(a)(3(i)

ML20236W002
Person / Time
Site:	Duane Arnold
Issue date:	07/29/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236V999	List: ML20236V997 ML20236W002
References
NUDOCS 9808050022
Download: ML20236W002 (3)

Text

-

yws p k

UNITED STATES

" NUCLEAR REGULATORY COMMISSION wASHm0 ton, D.C. 30006 0MH

• sse*

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF REQUESTS FOR RELIEF NDE-R020 FOR ,

i IES UTILITIES INC. I DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331

1.0 INTRODUCTION

The Technical Specifications (TS) for Duane Amold Energy Center (DAEC) state that the l inservice inspection 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 Bojier and Pressure Vessel Code (ASME Code) and applicable addenda as required by Title 10 of the Qda of Federal Regulations (10 CFR) Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55,1(g)(6)(i). Section 50.55a(a)(3) states that attematives to the requirements of paragraph (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 3

a compensating increase in the leve! of quality and safety.

J 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 pre-service examination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice 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 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 the Duane Amold Energy Center, third 10-year inservice 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, - ,

information shall be submitted to the Commission in support of that determination and a request j made for relief from the ASME Code requirement. After evaluation of the determination, i pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose i 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 l

' imposed.

i I

9808050022 980729 PDR ADOCK 05000331 G PDR

By letter dated April 26,1996, as supplemented on May 15,1998, IES Utilities Inc., the licensee of DAEC, requested relief from the requirements of the ASME Code Section XI,1989 Edition, Article IWF-5000, with regard to visual examination and functional testing of snubbers. Article IWF-5000 references the first addenda to ASME/ ANSI OM-1987, Part 4 (OM-4) for such snubber activities. The licensee requested the continued use of the current TS requirements for snubber .

visual examination and functional testing, pursuant to 10 CFR 50.55a(a)(3)(i).

2.0 DISCUSSION Component identification '

Code Classes: 1,2,3 and MC

References:

ASME,Section XI, IWF-5000 (1989 Edition)

ASME / ANSI OM-1987, Part 4, First Addenda (1988)

Code Case N-491 (TAP-1008) j Examination Category: F-A l Item Number: F1.10, F1.20, F1.30, F1.40

Description:

snubbers 1

Component numbers: All Chss 1,2,3, and MC component snubbers j I

Code Reauireme_n,_1 j l

IWF-5000 references the use of ASME / ANSI OM-1987, Part 4, First Addenda (1988) for rules l goveming visualinspection and functional testing of Class 1,2,3, and MC component snubbers. '

Licensee's Basis for Relief The licensee stated that the current DAEC technical specifications (TS) specify an adequate program for visual examination and functional testing for all safety-related snubbers. The snubber examinations and tests at DAEC are currently performed under TS Section 4.6.H, as amended in accordance with NRC Generic Letter (GL) 90-09, "Altemative Requirements for ,

Snubber Visual inspection Intervals and Corrective Actions," which was approved by the NRC in amendment 203 to the DAEC TS. The licensee stated that the current inspection program, as ]

defined by the TS, provides for a level of quality and safety equal to that of the OM-4. This is  ;

based on the fact that the attemative provides the same confidence level, as supported by GL 90-09. Furthermore, the TS snubber program scope includes all safety-related snubbers, which encompasses all Code Class 1,2, and 3 snubbers required to meet the ASME Section XI requirements.

Licensee's Altemative Examination The licensee proposes to continue to use the DAEC TS requirements for visual examination and functional testing for el: ASME Class 1,2,3, and MC component snubbers.

3.0 EVALUATION The staff hac reviewed the licensee's submittal pertaining to the relief request from the l requirements of the ASME Code for visual examination and functional testing of snubbers.

The staff finds that the licensee's basis for relief is acceptable, because it provides the same confidence level, is in accordance with GL 90-09, and provides assurance that snubbers will u___-___m_ _ _ _ _ _ - _ _ _ _ _ - _ _ - - _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - -

o .

e e

d 3

function and protect the structuralintegrity of safety-related systems and components.

Therefore, the attemative provides an acceptable level of quality and safety,

4.0 CONCLUSION

l i

Based on the information provided, the staff has determined that the licensee has presented an -

adequate justification for the requested relief from the requirements of the ASME Code,1989 i Edition,Section XI, Article IWF-5000 (which references OM-4), with regard to visual examination )

and functional testing of Code Class 1,2, and 3 snubbers. The staff has determined that the {

proposed altemative use of the TS requirement in Section 4.6.H for the Code Class snubbers ]

would provide an acceptable level of quality and safety. Therefore, the attemative in request for  !

relief NDE-R020 is authorized pursuant to 10 CFR 50.55a(a)(3)(i).

Principal Contributor: Amold Lee I Date: July 29, 1998  !

l l

I e

_ ._ _ _ _ . _ _ _ _