ML20249B401
| ML20249B401 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/17/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-98081, NUDOCS 9806230033 | |
| Download: ML20249B401 (6) | |
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h North North Atlantic Energy Service Corporation P.O. Box 300
'h.3. Atlaritic seehreet NiiO3874 0
(603) 474-9521 The Northeast Utilities System I
l June 17,1998 Docket No. 50-443 NYN-98081 United States Nuclear Regulatory Commission Attention: ' Document Control Desk Washington, D.C. 20555 Seabrook Station Inservice Insnection Pronram Pursuant to 10CFR50.55a(aX3Xi),10CFR50.55a(aX3Xii) and 10CFR50.55a(g)S(iii), North Atlantic Energy Service Corporation (North Atlantic) hereby submits proposed changes to the North Atlantic Inservice Inspection Program. The Inservice Inspection Program Plan, First Ten-Year Interval complies with the 1983 Edition with the Summer 1983 Addenda of ASME Section XI.
L North' Atlantic submits the following request for relief from specific requirements of the ASME Boiler and Pressure Vessel Code,Section XI for Seabrook Station.
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Relief Request IR-8," Class 1 Valve Internal Visual Examination" North Atlantic believes the requirement to disassemble an operable valve for the sole purpose of performing a visual examination (VT-3) of the internal pressure retaining boundary imposes undue hardship without a compensating increase in the level of quality and safety. A total of 33 Class i valves fall into this category. Although not all are required to be examined, a significant number do require disassembly and examination. Disassembly of large valves to the degree necessary to examine the I
internal pressure retaining surfaces is a major effort and may involve large personnel exposures. To do this disassembly solely to perform a visual examination of the interr.al body is impractical. The specified
- visual examination is to determine whether anticipated severe degradation of the body is occurring due to phenomena such as erosion or corrosion. North Atlantic is committed to visual examination (VT-3) when the required valves are disassembled for maintenance. North Atlantic believes this proposed alternative, along with visual examination for leakage during system pressure tests under ASME Section l
XI, Category B-P, and periodic testing per the requirements of ASME Section XI, Subsection IWV, provides an acceptable level of quality and safety to assure structural reliability.
Similar relief from ASME Section XI requirements for Class 1 valve bodies has been granted to
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- Millstone Unit 3'.
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- Letter from NRC to Mr. E. J. Mroczka,"First Ten-Year Program Plan and Inservice inspection Relief Requests, l
l Millstone Nuclear Power Station, Unit No. 3 (TAC No. 60385), dated February 8,1991." Relief Request IR
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maa e 7 PDR ADOCK 05000443 G
United St:t:s Nuclear Regul: tory Commission NYN-98081/Page 2
. provides the bases for Relief Request IR-8.
Nonh Atlantic requests NRC review and approval of Relief Request IR-8 by December 11,1998 to support planning and scheduling work scope activities for the upcoming sixth refueling outage (OR06).
. Should you have any questions regarding this letter, please contact Mr. Terry L. Harpster - Director of Licensing Services, at (603) 773-7765.
Very truly yours,
' W M
Ted C. Feigenbaum [
Executive Vice President and Chief Nuclear Officer cc:
H. J. Miller, NRC Regional Administrator J. T. Harrison, NRC Project Manager, Project Directorate 1-3 R. K. Lorson, NRC Senior Resident inspector l
)
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l ENCLOSURE I TO NYN-98081 i
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North Atlantic Energy Service Corporation Seabrook Unit 1 -
First Ten-Year Interval Relief Request Number IR-8
- 1. Comnonents For Which Reliefis Reauested:
Thirty Three (33) ASME Class 1 Valves
- 2.. Comnonent ID No's:
See attach (. I list.
- 3. ASME Code Class:
1
- 4. Framination Categorv: B-M-2
- 5. Code Requirement; ASME B&PV Code Section XI,1983 Edition through Summer 1983 Addenda, Table IWB-2500-1, Item No. B12.50 requires a visual examination (VT-3) of the internal surfaces on valve bodies exceeding 4" nominal pipe size (NPS).
Note:
Examinations are limited to one valve within each group of valves that are of the same constructional design (such as globe, gate, or check valve) and manufacturing method, and that perform similar functions in the system (such as containment isolation and system overpressure protection).
- 6. Code Requirement From Which Reliefis Reauested:
Pursuant to 10CFR50.55a(aX3Xi),10CRF50.55a(aX3Xii) and 10CFR50.55a(g)5(iii), relief is requested from performing the Code required visual examination (VT-3).
- 7. Basis for Relief:
The requirement to disassemble an operable valve for the sole purpose of performing a visual examination (VT-3) of the internal pressure retaining boundary imposes undue hardship without a comp nsating increase in the level of quality and safety. Disassembly of large valves to the degree necessary to examine the internal pressure retaining surfaces is a major effort and may involve large personnel exposures.
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- 8. Alternative Examination:
Perform a VT-3 visual examination on Class 1 valves as specified in Table IWB-2500-1, Item Bli.50 of the 1983 Edition, Summer 1983 Addenda of ASME Section XI when they are disassembled for maintenance or purposes other than ISI.
- 9. Justification For The Granting of Relief:
North Atlantic believes that performing a VT-3 visual examination when the subject Class 1 valves are disassembled for maintenance or other purposes provides reasonable assurance that unallowable inservice degradation can be detected. The visual examination is to determine whether severe degradation has occurred from conditions such wear, erosion, corrosion, loose parts, or cracking.
Class 1 valves were subjected to numerous nondestructive examinations during fabrication in accordance with ASME Section til and were installed in accordance with ASME rules and the North Atlantic Quality Assurance Program. These valves were accepted by _the manufacturer, the Authorized Nuclear Inspector, and North Atlantic Quality Assurance.
They are also subjected to risual examination for leakage during system pressure tests under ASME Section XI, Category B-P and periodic testing per the requirements of ASME Section XI, Subsection IWV.
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Conclusion:
I Based on the foregoing, North Atlantic believes that an acceptable level of quality and safety will continue to be achieved, and public health and safety veill not be endangered by allowing j
the proposed alternative examination in lieu of the Code requirement.
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l Class 1 Valve Grounin_e Group No.
System Valve No-Description 1
Reactor Coolant RC-V-22 12" Gate Valve RC-V-23 RC-V-87 RC-V-88 2
Reactor Coolant RC-V-115 6" Relief Valve RC-V-116 RC-V-l l7 3
Residual Heat Removal RH-V-15 6" Check Valve RH-V-29 RH-V-30 RH.V-31 RH-V-52 RH-V-53 RH-V-50 8" Check Valve RH-V-51 4
Residual IIeat Removal RH-V-59 6" Gate Valve RH-V-61 RH-V-63 RH-V-65 5
Safety injection SI-V-3 10" Gate Valve SI-V-17 SI-V-32 SI-V-47 6
Safety Injection SI-V-5 10" Check Valve SI-V-6
{
SI-V-20 SI-V-21 SI-V-35 SI-V-36 SI-V-50 SI-V-51 SI-V-82 6" Check Valve SI-V-87 1
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