ML20237D500

SER Approving Code Case N-389-1, Alternative Rules for Repairs,Replacements,Or Mods,Section Xi,Div 1

ML20237D500
Person / Time
Site:	Millstone
Issue date:	08/20/1998
From:	NRC (Affiliation Not Assigned)
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ML20237D497	List: ML20237D495 ML20237D500
References
NUDOCS 9808260239
Download: ML20237D500 (5)

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O \ UNITED STATES j j e

NUCLEAR REGULATORY COMMISSION WASHINGTc N, D.C. 20066 0001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF FROM CERTAIN ASME CODE. SECTION XI REQUIREMENTS NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NLiCLEAR POWER STATION UNIT NO. 3 DOCKET NO. 50-423 1

1.0 INTRODUCTION

Section 50.55a(g) of Title 10 of the Code of Federal Regulations (10 CFR 50.55a(g)) requires nuclear power facility piping and components to meet the applicable requirements of Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (hereafter referred as the Code).Section XI of the Code specifies Code-acceptable repair and replacement procedures to be used on components and piping that are inservice.

Altematives to Code requirements may be used by nuclear licensees when authorized by the Director of the Office of Nuclear Reactor Regulation if the proposed attematives to the requirements are such that they are shown to provide ran acceptable level of quality and safety in lieu of the Code requirements [10 CFR 50.55a(a)(3)(i)], or if compliance with the Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety [10 CFR 50.55a(a)(3)(ii)].

A licensee may also submit requests for relief from certain Code requirements when a licensee has determined that conformance with cedain Code requirements is impractical for its facility

[10 CFR 50.55a(g)(5)(iii)]. Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations ofimpracticality and may grant relief and may impose attemative requirements as it determines are authorized by law.

In a letter dated December 15,1995, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) (the licensee), submitted to the NRC certain requests for relief from the ASME Code,Section XI requirements. Specifically, pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested (1) relief from using the rules of Article lWA-4000, " Repair Procedures," for repairs on piping, valves, fittings, nominal pipe size 1 inch and smaller, a .d their associated supports; (2) relief from using the rules of Article IWA-4000 and Article IWA-7000, " Replacements," for repair or replacement activities performed on seal welds; and (3) relief from the rules of Articles IWA-4000 and IWA-7000 for repair or I i replacement activities performed on valve discs and other nonstructural valve intemals that are '

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Enclosure I

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4 constructed to a Construction Code or a Code Case for all four plants (Haddam Neck, Millstone Units 1,2, and 3). In addition, the !icensee requested, pursuant to 10 CFR 50.55a(a)(3)(i), that Code Case N-389-1, "Altemative Rules for Repairs, Replacements, or Modifications,Section XI, Division 1," be approved for use by all four plants.

By letter dated June 7,1996, the licensee revised its requests for relief and withdrew its previously requested reliefs pertaining to the rules of Articles IWA-4000 and IWA-7000 for repair or replacement activities performed on valve discs and other nonstructural valve intemals that are constructed to a Construction Code or a Code Case. In a letter dated February 18, 1997, CYAPCO withdrew the remaining requests for relief for Haddam Neck based on an earlier decision by the CYAPCO joint owners to permanently cease power operations at the facility. In a letter dated August 14,1998, NNECO withdrew all its remaining requests except for Code Case N-389-1 at Millstone Unit 3. Therefore, this safety evaluation only applies to Millstone Unit 3.

2.0 EVALUATION l

The information provided by the licensee in support of the remaining relief request has been evaluated and the basis for disposition is documented below.

I Millrtone. Unit 3 - Reauest to use Code Case N-389-1. Altemative Rules for Reoairs.

Replacements. or Modifications.Section XI. Division 1  !

Licensee's Reauest: (As stated) I The request to use Code Case revision that has not yet been approved by the NRC Staff is being submitted pursuant to 10CFR50.55.a(a)(3)(i).

We request that Code Case Revision N-389-1, "Altemative Rules for Repairs, Replacements, or Modifications,Section XI, Division 1," be approved for use by Haddam Neck plant and Millstone Unit Nos.1,2 and 3. This revision of the Code Case has not yet been incorporated into Regulatory Guide 1.147. This Code Case revision allows a licensee to use later Editions and Addenda of the  !

ASME Code Section XI for Repair or Replacement Activities as with the original l Case which has been approved by the NRC, but now requires that all related requirements must be met. This additional provision to the Case approved by the ASME, with NRC participation, provides the basis for the approval of our I request. The attematives which are provided in the Case revision have been determined by the ASME consensus process to provide an acceptable level of quality and safety, i Both CYAPCO and NNECO believe that the Staffs approval of these requests j will help to optimize our Section XI Repair and Replacement Programs. This will be accomplished by allowing the use of attematives provided in Code Case Revision N-389-1 and by reducing the burdensome documentation associated with repair or replacement activities.

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Evaluation: The Code of record for the Millstone Unit 3, first 10-year ISI intervalis the ASME Code,Section XI,1983 Edition with the Summer 1983 Addenda. The licensee has requested to use the attematives provided in Code Case N-389-1 for its Repairs and Replacement Program.

The original version of Code Case N-389 was approved by the NRC staff and is listed in Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1." Regulatory Guide 1.147, Revision 11, October 1994, states that Code Case N-389 is acceptable subject to the following condition in addition to those conditions specified in the Code Case: The applicant should submit for approval the appropriate edition and addenda of the Code that is to be used for the repair, replacement, or modification before start of the work.

Revision 1 to Code Case N-389 (N-389-1) has been approved by the ASME Code and the staff is currently in the process of incorporating Revision 1 to the Code Case into the forthcoming revision of Regulatory Guide 1.147. Code Case N-389-1 will enable licensees to use the attematives provided in later editions of the Code (that have been approved by the NRC staff) for repair or replacement activities, provided all related requirements of the Code are met.

Since the Code Case requires that an NRC-approved edition of the Code will be used and allits requirements must be met, the attemative proposed by the licensee will provide an acceptable level of quality and safety.

Conclusion:

Request to use Code Case N-389-1 as an alternative to the Code requirements has been proposed by the licensee. The NRC staff reviewed the proposed alternatives for compliance with the provisions of 10 CFR 50.55a(a)(3)(i), which allows licensees to propose alternatives to Code requirements if the proposed altemative would provide an acceptable level of quality and safety. The licensee has proposed to use the attematives provided in Code Case N-389-1 for its Repair and Replacement Program. Code Case N-389-1 has been reviewed by the NRC staff and is currently in process of being incorporated into the forthcoming revision of Regulatory Guide 1.147. The staff finds the attematives provided in Code Case N-389-1 acceptable. The staff, therefore, concludes that the licensee's proposed altemative to use Code Case N-389-1 would provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the altemative is authorized.

3.0 CONCLUSION

The licensee has requested, pursuant to 10 CFR 50.55a(a)(3)(i), that Code Case N-389-1 be approved for Millstone Unit 3. The staff has concluded that the licensee's proposed alternative is acceptable because it provides an acceptable level of quality and safety. Therefore, the staff concludes that the licensee's proposed alternative is authorized pursuant to 10 CFR  !

50.55a(a)(3)(i).

i Principal Contributors: G. Georgiev and S. Dembek l

Date: August 20, 1998 l

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4 Millston] Nucle:r P w r St:ti:n Unit 3 cc:

Lillian M. Cuoco, Esquire Joseph R. Egan, Esquire Senior Nuclear Counsel Egan & Associates, P.C.

Northeast Utilities Service Company 2300 N Street, NW P. O. Box 270 Washington, DC 20037 Hartford, CT 06141-0270 Mr. F. C. Rothen Mr. Kevin T. A. McCarthy, Director Vice President -Work Services 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 Ernest C. Hadley, Esquire l

Regional Administrator, Region i 1040 B Main Street j U.S. Nuclear Regulatory Commission P.O. Box 549 '

475 Allendale Road West Wareham, MA 02576 ,

King of Prussia, PA 19406 Mr. John Buckingham First Selectmen Department of Public Utility Control Town of Waterford Electric Unit Hall of Records 10 Liberty Square 200 Boston Post Road New Britain, CT 06051 Waterford, CT 06385 Mr. James S. Robinson, Manager Mr. Wayne D. Lanning Nuclear investments and Administration Deputy Director of Inspections New England Power Company Special Projects Office 25 Research Drive 475 Allendale Road Westborough, MA 01582 King of Prussia, PA 19406-1415 Mr. John Streeter Mr. M. H. Brothers Recovery Officer - Nuclear Oversight Vice President - Millstone Unit 3 Northeast Utilities Service Company l Northeast Nuclear Energy Company P. O. Box 128 P.O. Box 128 Waterford, CT 06385

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Waterford, CT 06385 l Deborah Katz, President Mr. M. R. Scully, Executive Director l Citizens Awareness Network Connecticut Municipal Electric P.O. Box 83 ,

Energy Cooperative Shelburne Falls, MA 03170 30 Stott Avenue

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Norwich, CT 06360 Mr. Allan Johanson, Assistant Director Office of Policy a'nd Management Mr. David Amerine Policy Development and Planning Vice President - Human Services Division i Northeast Utilities Service Company 450 Capito! Avenue - MS# 52ERN P. O. Box 128 P. O. Box 341441 Waterford, CT 06385 Hartford, CT 06134-1441 l

,;, Millston) Nuclear Powsr Stition i Unit 3 l

cc:

The Honorable Terry Concannon Mr. William D. Meinert Nuclear Energy Advisory Council Nuclear Engineer Room 4035 Massachusetts Municipal Wholesale Legislative Office Building Electric Company Capitol Avenue P.O. Box 426 Hartford, CT 06106 Ludlow, MA 01056 l- Mr. Evan W. Woollacott Attorney Nicholas J. Scobbo, Jr.

Co-Chair Ferriter, Scobbo, Caruso, Rodophele, PC Nuclect Energy Advisory Council 1 Beacon Street,11th Fbor 128 Terry's Plain Road Boston, MA 02108 Simsbury, CT 06070 Citizens Regulatory Commission i MrcJohn W. Beck, President ATTN: Ms. Susan Perry Luxton Little Harbor Consultants, Inc. 180 Great Neck Road l

Millstone -ITPOP Project Office Waterford, CT 06385 P.O. Box 0630 Niantic, CT 06357-0630

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Mr. B. D. Kenyon (Acting)

Chief Nuclear Officer - Millstone l Northeast Nuclear Energy Company l P.O. Box 128 Waterford, CT 06385 Mr. Daniel L. Curry I 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 Mr. P. D. Hinnenkamp Director- Unit 3 Northeast Nuclear Energy Company P.O. Box 128 1 Waterford, CT 06385 l

. Senior Resident inspector

! Millstone Nuclear Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 C____________.___________________.________