ML20237D126

Forwards Request for Addl Info Re Inservice Insp Program Relief Request

ML20237D126
Person / Time
Site:	FitzPatrick
Issue date:	08/20/1998
From:	Williams J NRC (Affiliation Not Assigned)
To:	James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
TAC-MA0711, TAC-MA711, NUDOCS 9808250083
Download: ML20237D126 (8)

Text

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' ' Mr. Jim:s Knubel August 20, 1998 ChiIf Nucl;rr Officer  !

Pow;r Authority of tha Stria of I New York 123 Main Street White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT- REQUEST FOR ADDITIONAL INFORMATION REGARDING INSERVICE INSPECTION PROGRAM RELIEF REQUESTS (TAC NO. MA0711)

Dear Mr. Knubel:

On January 26,1998, the New York Power Authority (also known as the Power Authority of the State of New York) submitted the third interval inservice inspection program and relief requests for the James A. FitzPatrick Nuclear Power Plant. The NRC staff has determined that additional information will be required to cornplete its review of the relief requests in this submittal. The information required is described in the enclosure to this letter.

To expedite the review process, please provide a copy of your response directly to the NRC's contractor, INEEL, at the following address:

MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Your prompt response will assist us in our efforts to complete this review in a timely manner. If you have any questions regarding this matter, please contact me at (301) 415-1470.

Sincerely, ORIGINAL SIGNED BY:

Joseph F. Williams, Project Manager Project Directorate 1-1 Division of Reactor Projects - l/11 Office of Nuclear Reactor Regulation Docket No. 50-333 )

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\p,,4,,,,/ August 20, 1998 Mr. James Knubel Chief Nuclear Officer Power Authority of the State of New York 123 Main Street White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATR!CK NUCLEAR POWER PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING INSERVICE INSPECTION PROGRAM RELIEF REQUESTS (TAC NO. MA0711)

Dear Mr. Knubel:

On January 26,1998, the New York Power Authority (also known as the Power Authority of the State of New York) submitted the third interval inservice inspection program and relief requests for the James A. FitzPatrick Nuclear Power Plant. The NRC staff has determined that additional information will be required to complete its review of the relief requests in this submittal. The information required is described in the enclosure to this letter.

To expedite the review process, please provide a copy of your response directly to the NRC's contractor, INEEL, at the following address:

MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Your prompt response will assist us in our efforts to complete this review in a timely manner. If you have any questions regarding this matter, please contact me at (301) 415-1470.

Sincerely,

/ l Joseph F. Williams, Project Manager Project Directorate I-1 Division of Reactor Projects - 1/ll Office of Nuclear Reactor Regulation Docket No. 50-332

Enclosure:

As stated cc w/ encl: See nent page i

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1 James K?> bel .

James A. FitzPatrick Nuclear Power Autnority of the State Power Plant I of New York '

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Mr. Gerald C. Goldstein Regional Administrator, Region i Assistant General Counsel U.S. Nuclear Regulatory Commission Power Authority of the State 475 Allendale Road of New York King of Prussia, PA 19406 1633 Broadway New York, NY 10019 Mr. F. William Valentino, President New York State Energy, Research, Resident inspector's Office and Development Authority

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U. S. Nuclear Regulatory Commission Corporate Plaza West P.O. Box 136 286 Washington Avenue Extension Lycoming, NY 13093 Albany, NY 12203-6399 Mr. Hany P. Salmon, Jr. Mr. Richard L. Patch, Director Vice President - Engineering Quality Assurance Power Authority of the State Power Authority of the State of NewYork of New York 123 Main Street 123 Main Street White Plains, NY 10601 White Plains, NY 10601 Ms. Charlene D. Faison Mr. Gerard Goering Director Nuclear Licensing 28112 Bayview Drive Power Authority of the State Red Wing, MN 55066 of New York 123 Main Street -

Mr. James Gagliardo White Plains, NY 10601 Safety Review Committee 708 Castlewood Avenue Supervisor Arlington, TX 76012 Town of Scriba

. Route 8, Box 382 Mr. Arthur Zaremba, Licensing Manager Oswego, NY 13126 James A. FitzPatrick Nuclear Power Plant Mr. Eugene W. Zeltmann P.O. Box 41 President and Chief Operating Lycoming, NY 13093 Officer Power Authority of the State Mr. Paul Eddy l cf New York New York State Dept. of 99 Washington Ave., Suite No. 2005 Public Service Albany, NY 12210-2820 3 Empire State Plaza,10th Floor Albany, NY 12223 Charles Donaldson, Esquire Assistant Attorney General Michael J. Colomb New York Department of Law Site Executive Officer j 120 Broadway James A. FitzPatrick Nuclear Power Plant New York, NY 10271 P.O. Box 41 Lycoming, NY 13093 i

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l JAMES A. FITZPATRICK NUCLEAR POWER PLANT  !

1 THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM l

REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUESTS 1

1. Scope / Status of Review l

l Throughout the service life of a water-cooled nuclear power facility,10 CFR 50.55a(g)(4) requires that components (including supports) that are classified as American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice 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 l materials of construction of the components. This section of the regulations also requires that )

inservice examinations of components and system pressure tests conducted during successive i 120-month inspection intervals comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of the interval, subject to the limitations and modifications listed therein. The components ]

(including supports) may meet examination requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regalatory Commission (NRC) approval. The licensee, New York Power Authority (also known as the Power Authority of the j State of New York), prepared the James A. FitzPatrick Nuclear Power Plant, Third 10-Year j

Intervalinservice Inspection Program, to meet the requirements of the 1989 Edition of the ASME Code Section XI. The third 10-year interval began September 28,1997. The licensee requested that evaluation of Requests for Relief 1 through 10,12, and 13 be expedited to support an '

upcoming outage.

The NRC staff has reviewed the available information in Relief Requests 1 through 10,12, and 13, and has determined that the additional information described below will be required to complete its review.

2. AdditionalInfomTation Reauired A. Request for Relief No.1 - The licensee has requested authorization to implement Code Case N-416-1, Altemative Pressum Test Requirement for WeIJed Repairs orInstallation of Replacement Items by Welding, Class 1,2 and 3. The licensee has stated in the request that "the Authority does not intend to perform a surface examination on the root pass layer i of butt and socket welds of the pressure retaining boundary of Class 3." The NRC ststf has found the use of Code Case N-416-1 acceptable only if the licensee commits to performing a surface examination of the root pass weld layer for welded repairs and replacements in Class 3 systems, :.f surface examination is required by ASME Section 111 for final acceptance. Confirm that the condition above will be met.

B. Request for Relief No. 4 - The licensee has requested authorization to implement Code l Case N-509, Altemative Rules for the Selection and Examination of Class 1, 2 and 3  ;

Integrally Welded At'echments. The NRC has allcwed the use of Code Case N-509 I provided that licensee's commit to supplement the examination requirements of N 509 to j include a minimum of 10% of the total number of non-exempt piping, pump, and valve i

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't 2-integral attachments distributed among all Class 1,2 and 3 systems. Confirm that these conditions will be met.

C. Requests for Relief Nos 5-10 and 13 - The licensee must state the specific paragraph of the Regulations underwhich each proposed request for relief or attemative is submitted. A licensee may propose an attemative to CFR or Code requirements in accordance with 10 CFR 50.55a(s)(3)(1) or 10 CFR 50.55a(a)(3)(ii). When submitting a proposed attemative, the licensee must specify the appropriate regulatory basis. Under 10 CFR 50.55a(a)(3)(l),

the proposed altemative must be shown to provide an acceptable level of quality and safety, i.e., essentially be equivalent to the original requirement in terms of quality and safety.

Under 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship or unusual difficulty without a compensating increase in the level of quality and safety, Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimalincreases in examination coverage. Financial factors should not be included as a hardship.

In accordance with 10 CFR 50.55a(g)(5)(iii), a licensee may submit a request for relief from ASME Code requirements, if a licensee determines that conformance with certain ASME Code requirements are impractical for its facility, the licensee shall notify the Cornmission and submit, as specified in $50.4, information to support that determination. When a licensee determines that an inservice inspection requirement is impractical, e.g., the system would have to be redesigned or a component would have to be replaced to enable inspection, the licensee should cite this part of CFR to support the criteria for evaluation.

Th( NRC may, giving due consideration to the burden placed on the licensee, impose an i altemative examination requirement.

Revise the subject requests for relief to include the required reference (s) and regulatory basis to ensure that the requests for relief are evaluated in accordance with the appropriate criteria.

D. Request for Relief No. 7 - The licensee is seeking relief from the ultrasenic examination testing frequency requirements specified in NUREG-0619, Table 2, and requests to eliminate the routine liquid penetrant examination testing, and the FW Nonle Leakage Monitoring System (LMS), as required by NUREG-0619.

The Boiling Water Reactor Owners Group (BWROG), by letter dated October 30,1995, .

submitted report GE-NE-523-A71-0594, "Altemate BWR Feedwater Nonle inspection Requirements." This report proposed attematives to the recommendations set forth in NUREG-0619. "BWR Feedwater Nonle and Control Rod Retum Drain Line Nonle Cracking." The staff performed an evaluation on the BWROG submittal and the results of the evaluation are contained in the Safety Evaluation (SE) dated June 5,1998. The staff found the proposed inspection program submitted by the BWROG acceptable subject to the l conditions listed in Section 5.0 of the SE. However, as stated in Section 2.0 LICENSING l REQUIREMENTS, of the SE, "the NRC has received commitments from licensees to follow the examination schedule for UT, visual testing (VT), and PT coritained in Paragraph 4.3.2 of NUREG-0619." " Licensees incorporated these commitments into their ISI programs through technical specification changes, FSAR changes, or letters of commitment.

Therefore, any changes to licensse's commitments are predicated on how the commitments i

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3-were incorporated in the licensees' documents." It is unclear how the licensee committed to the NUREG-0619 examination requirements. Submittal of a request for relief may or may not be the correct means of changing the licensee's commitment. Provide additional information explaining how the original commitment was made to NUREG-0619 examination requirements.

Also, provide verification, that the proposed altemative is in compliance with the requirements identified in the " Safety Evaluation By The Office Of Nuclear Reactor Regulation BWR Owners' Group Report GE-NE-523-A71-0594 Altemate BWR Feedwater Nozzle Inspection Requirements."

E. Request for Relief No. 8 - The licensee has submitted this request for relief relating to the Control Rod Drive System. However, it is unclear as to the specific Code requirement (s) the licensee is seeking relief from. The licensee references Category C-H. However, Category C-H has multiple examination requirements. The licensee states in the Examination Requirements portion of the request that:

... relief should be from the 10 year inservice / hydro test and Code Case N-498-1 that the inservice test will be done during a normally scheduled shutdown from plant operation.

In the Relief Requested portion of the Request for Relief the licensee states that:

Relief is requested from the requirements specified in IWC-2000, Table IWC-2500-1, Code Category C-H, All Pressure Retaining Components of the ASME Boiler and Pressure Vessel Code,Section XI,1989 Edition for inservice pressure testing of the C.D. System each inspection period. Also Code Case N-498-1 for the third period test.

It is unclear whether the licensee is seeking relief from the interval requirement, period requirement, or both. Identify the specific Code requirement (s) that will not be met (include category and item number (s)). Provide a specific description of the portion of the CRD system requiring relief. Include boundary / isometric drawings identifying the portion of the CRD system requiring relief.

, Also, provide a basis for relief, explaining / justifying why the Code requirements cannot be met (see question C).' The licensee has provided an attemative examination, explain as applicable:

1. how the attemative examination is equivalent to the Code-required examination and l how it provides an acceptable level of quality and safety (10 CFR 50.55a(a)(3)(l)) or,

2. how the altemative examination provides reasonable assurance of operational readiness, and why compliance with the Code requirements would result in a hardship without a compensating increase in safety (10 CFR 50.55a(a)(3)(ii)) or,

3. how the attemative examination provides reasonable assurance of operational readiness, and why compliance with the Code requirements is considered to be impractical (10 CFR 50.55a(g)(6)(l)).

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t F. Request for Relief No. 9 - The licensee has requested relief from the requirements of ASME Section XI,1992 Edition, Article IWA-2000, as invoked by 10 CFR 50.55a(b)(2)(vi).

The licensee has proposed as an attemative, to meet the requirements specified in ASME I Section XI,1989 Edition without Addenda, Article IWA-2000.

Article IWA-2000 contains multiple requirements concoming examination and inspection. In order to perform an evaluation of this request for relief, it is necessary to know the specific requirements that will not be met. Provide the specific Code requirements in ASME Section XI,1992 Edition, Article IWA-2000 that will not be met. Also, explain as applicable:

1. how the attemative examination is equivalent to the Code-required examination and how it provides an acceptable level of quality and safety (10 CFR 50.55a(a)(3)(l)) or,

2. how the attemative examination provides reasonable assurance of operational readiness, and why compliance with the Code requirements would result in a hardship without a compensating increase in safety (10 CFR 50.55a(a)(3)(ii)) or,

3. how the a3emative examination provides reasonable assurance of operational readiness, aad why compliance with the Code requirements is considered to be impractical (10 CFR 50.55a(g)(6)(l)).

G. Request for Relief No.10 - The licensee has requested relief from the requirements of '

IWA-5250(a)(2), conceming leakage at bolted connections. The licensee has proposed to include in the ISI program the requirement to perform VT-3 examination in-place on bolted connections when leakage occurs. Evidence of degradation to the bolted connection or bolting shall require the bolt closest to the source of the leakage to be removed, visually examined VT-3 and evaluated to IWA-3100. When the removed bolt has evidence of degradation, all remaining bolting in the connection shall be removed, VT-3 examined, and ,

evaluated in accordance with IWA-3100.

Other licensees have proposed acceptable altematives to the requirements of l IWA-5250(a)(2) that have included a detailed and well-defined engineering evaluation of the botting and the bolted connection when leakage is detected. The evaluation should, at a minimum, consider the following factors: bolting materials, corrosiveness of process fluid ,

leaking, leakage location, leakage history at connection or other system components, visual )

evidence of corrosion at connection (while connection is assembled), and service age of the i bolting materials.

In order for the licensee's proposed altemative to be found acceptable, a specific leakage evaluation procedure with the appropriate corrective actions to be taken if the evaluation is inconclusive or identifies bolting degradation is necessary. Discuss the intended action regarding this Request for Relief.

l H. Request for Relief No.12 - The licensee has proposed the use Code Case N-522, i Pressure Testing of Containment Penetration Piping,Section XI, Division 1. The licensee stated that the leakage testing requirement results in unusual difficulties without a compensating increase in the level of quality and safety.10 CFR 50.55a(a)(3)(ii) requires t that the licensee demonstrate that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

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5-Provide a discussion describing / demonstrating the hardship and/or unusual difficulty associated with the requirements, and why compliance with the examination requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

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