ML20237D498
| ML20237D498 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/19/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20237D489 | List: |
| References | |
| NUDOCS 9808260237 | |
| Download: ML20237D498 (4) | |
Text
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a ps rg k
g UNITED STATES g
j NUCLEAR REGULATORY COMMISSION p
WASHINGTON, D.C. 20566 4 001
.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 1
ON EXTENSION OF THE SECOND TEN-YEAR INSPECTION INTERVAL l
FOR i
CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NO.1 BALTIMORE GAS AND ELECTRIC COMPANY DOCKET NO. 50-317 l
1.0 INTRODUCTION
The Technical Specifications for Calvert Cliffs Nuclear Power Plant, Unit No.1 state that the inservice inspection and testing 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 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).10 CFR 50.55a(a)(3) states that altematives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed
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altematives 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 that become effective subsequent to editions specified in 10 CFR 50.55a(g)(2) and (g)(3), 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 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 ten-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) on the l
date twelve months prior to the start of the 120-month interval, subject to the limitations and J
modifications listed therein. The applicable edition of Section XI of the ASME Code for the second ten-year inservice inspection interval for Calvert Cliffs Unit 1 is the 1983 Edition, including the Summer 1983 Addenda. The components (including supports) may meet the requirement set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
Pursuant to 10 CFR 50.55a(g)(5)(iii), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is impractical for its facility information, it should be submitted to the Commission in support of that determination. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may 9808260237 900919 f
ADocK os y y 7 i
Enclosure
. impose attemative requirements that are determined to be authorized by law; will not endanger life, property, or the common defense and securit); 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 letters dated April 28,1998, and June 25,1998, Baltimore Gas and Electric Company (licensee) requests approval of the proposed altemative to extend the end date of the second 10-year inspection interval of Calvert Cliffs Unit 1 from June 30,1998, to June 30,1999, and to continue using the current Code during the period of the extension of the interval. The licensee states that pursuant to 10 CFR 50.55a(a)(3)(l), the proposed altemative provides an acceptable level of quality and safety.
The NRC staff, has reviewed and evaluated the licensee's request and supporting information on the proposed extension of the second ten-year interval and to continue use of the current ASME Code,Section XI, (1983 Edition through the Summer '83 Addendum) during the extension of the interval for Calvert Cliffs Unit 1.
2.0 DISCUSSION Systems / Components Acolicable:
ASME Code Class 1,2, and 3 Components.
Requirement:
The ASME Code,Section XI,1983 Edition through the Summer 1983 Addendum, paragraph IWA-2400(c) states that each inspection interval may be decreased or extended (but not cumulatively) by as much as 1 year. For power units that are out-of-service continuously for 6 months or more, the inspection interval may be extended for a period equivalent to the outage.
10 CFR 50.55a(g)(4)(ii) states " Inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed in paragraph (b) of this section."
Licensee's Proposed Attemative to the Requirements:
l The licensee has proposed to extend the second inspection interval to an end date of June 30,1999, which exceeds the Code allowed extension of 1 year and to continue use of the
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existing ASME Code,Section XI that was applicable for the interval, during the extended duration of the interval.
Licensee's Basis for Reouestino Attemative to the Requirements:
j in the original request dated April 28,1998, the licensee stated that the extension of the l
second ten-year inspection interval would enable them to utilize the 1995 Edition, ASME Code,Section XI, through the 1996 Addenda for the third inspection interval of Calvert Cliffs Un!t 1. In
t 3-the proposed rulemaking, the NRC is considering incorporation of this Code into 10 CFR 50.55a(b)(2). The licensee anticipates that the third ten-year inspection interval for Unit 2 would adopt the new Code prior to Unit 1, which would then necessitate Unit 1 program plan to be updated to the same Code for consistency between inservice inspection programs of both units.
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The licensee amended its request in a submittal to the NRC dated June 25,1998 stating that the timing of the issuance of the rulemaking may not be beneficialin regard to the original request stated above. Since the date of the change in the Code of Federal Regulations regarding incorporation of ASME Section XI,1995 Edition with the 1996 Addenda is no longer certain, the licensee stated that they were in the process of evaluating editions of ASME Section XI published later than the 1989 Edition for incorporating into the third interval program plan for both units of Calvert Cliffs and planned to submit a line-by-line analysis of a proposed altemate Code edition for NRC review by January 1999. Subsequently, the intemal programs, procedures, and personnel qualifications for the third interval need to be updated in accordance with the new Code by June 1999. Therefore, the proposed attemative to continue the use of the existing Code during the period of extension of the second interval, would facilitate timely completion of these activities. Nevertheless, there is no inservice inspection scheduled for Unit 1 between June 1998 and June 1999 that would have required examination in accordance with an updated ASME Section XI Code, pursuant to 10 CFR 50.55a(g)(4)(ii). The licensee further states that in accordance with the requirement of the ASME Code,Section XI, paragraph IWA-2400(c), the third inspection interval will be correspondingly decreased by 1 year with duration from June 1999 to June 2008 due to the proposed extension of the second inspection interval.
3.0 EVALUATION The NRC staff has reviewed the licensee's proposed extension of the second ten-yearinspection interval for Calvert Cliffs Unit 1 from June 30,1998 to June 30,1999, and use of the existing Code for all repair and replacement during the period of extension of the interval. The licensee has proposed to use the 1995 Edition of ASME Section XI Code including the 1996 Addendum which is currently in the rulemaking by the NRC for incorporating into 10 CFR 50.55a(b)(2),
during the third inspection interval. Since the adoption of the new Code in the Title 10 CFR is uncertain, the licensee has embarked on a comparison of the increased and decreased requirements between the goveming Code (1989 Edition) and the proposed Code to evaluate as to how the attemate provides an acceptable level of quality and safety which will be submitted by the licensee for staff's review. This approach has been acceptable to staffin the past. In the interim, however, the licensee proposes to continue the use of the existing Code which is the 1983 Edition through the Summer 1983 Addenda for repair, replacement and preservice inspection. Should the relief not be authorized by the NRC, the licensee has to update its second ten-year program plan to the 1989 Edition of the ASME Code Section XI for the interim period of extension and again update to the 1995 Edition through the 1996 Addenda after a year when the third inspection interval begins. The staff has further determined that there is no inservice inspection activities scheduled to take place during the interim period. Therefore, compliance with the 1989 Edition of ASME Code Section XI for the interim period would be a hardship without a compensating increase in the level of quality and safety,
4.0 CONCLUSION
The staff concludes that the proposed extension of the second ten-yearinspection interval by a year from the scheduled end date of June 30,1998 with no inservice inspection scheduled to take place during the period, has negligible impact on the health and safety of public. Based on E
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the low impact on the overall effect of the requested extension, it would be a hardship withou compensating increase in the level of quality and safety to require the licensee to update the Code during the extended period of the interval. Therefore, pursuant to 10 CFR 50.55a(
the licensee's proposed alternative is authorized for Calvert Cliffs Unit 1.
3 Principal Contributor: P. Patnaik Date: August 19, 1998 m...._.___.