ML12130A216

ASME Section XI Inservice Inspection Program Request for Alternative - Fifth 10-Year Inservice Inspection Interval ASME Section XI Code of Record Relief Requests S1-15-ISI-01 and S2-15-ISI-01

ML12130A216
Person / Time
Site:	Surry
Issue date:	04/25/2012
From:	Lane N Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-191
Download: ML12130A216 (10)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 25, 2012 United States Nuclear Regulatory Commission Serial No.12-191 Attention: Document Control Desk NLOS/GDM RO Washington, D.C. 20555 Docket Nos. 50-280/281 License No. DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNITS 1 AND 2 ASME SECTION XI INSERVICE INSPECTION (ISI) PROGRAM REQUEST FOR ALTERNATIVE - FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL ASME SECTION Xl CODE OF RECORD RELIEF REQUESTS S1-15-ISI-01 AND S2-15-ISI-01 Pursuant to 10 CFR 50.55a(a)(3)(i), Dominion requests an alternative to the requirements of 10 CFR 50.55a(g)(4)(ii) pertaining to the Fifth 10-year ISI Interval update for Surry Power Station (Surry) Units 1 and 2 to the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code, Section Xl (ASME Section Xl). The requested alternative will permit the use of the 2004 ASME Section Xl Code Edition for the Surry Units 1 and 2 Fifth 10-year Interval ISI programs that is currently used at North Anna and Millstone Power Stations. The ASME Section Xl programs are corporately administered for these three sites; consequently, the proposed alternative will facilitate the implementation of ASME Section Xl activities (e.g. ISI, repair/replacement, pressure testing, and Non-destructive Examination (NDE))

in a consistent and standardized manner at the Surry, North Anna, and Millstone sites.

Relief Requests Sl-15-ISI-01 and S2-15-ISI-01 for Surry Units 1 and 2, respectively, are attached and provide the requisite information and justification for the proposed alternative. Surry Units 1 and 2 will begin their Fifth 10-year ISI Intervals on October 14, 2013 and May 10, 2014, respectively. To support use of the 2004 ASME Section XI Code Edition for the Surry Units 1 and 2 Fifth 10-year Interval ISI programs, Dominion requests approval of Relief Requests Sl-15-ISI-01 and S2-15-ISI-01 by May 30, 2013.

If you have any questions or require additional information, please contact Mrs. Candee G. Lovett at (757) 365-2178.

Sincerely, N. L. Lane Site Vice President - Surry Power Station

?pt~l

Serial No.12-191 Docket Nos. 50-280/281 Page 2 of 2 Attachments

1. Relief Request S1-15-1SI-01 Surry Unit 1

2. Relief Request $2-15-1SI-01 Surry Unit 2 Commitments made by this letter: None cc: U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street, Suite 730 Richmond, Virginia 23219 NRC Senior Resident Inspector Surry Power Station Ms. K. R. Cotton, NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Dr. V. Sreenivas, NRC Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852 Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station

Serial No.12-191 Docket Nos. 50-280/281 Attachment 1 Fifth 10-year Inservice Inspection Interval 2004 ASME Section XI Code of Record -

Relief Request S1 ISI-01 Virginia Electric and Power Company (Dominion)

Surry Power Station Unit I

Serial No.12-191 Docket Nos. 50-280/281 Attachment 1 Page 1 of 3 Virginia Electric and Power Company Surry Power Station Unit 1 Fifth 10-year Inservice Inspection Interval ASME Section XI Code of Record Relief Request S1-15-ISI-01 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

1. ASME (American Society of Mechanical Engineers) Code Components Affected ASME Section Xl Class 1, 2 and 3 components and component supports

2. Applicable Code Edition and Addenda

2004 ASME Section Xl Code Edition, No Addenda, for the Fifth 10-year Inservice Inspection (ISI) Interval

3. Applicable Code Requirement

Dominion is required to update the Surry Unit 1 120-month ISI Program to the latest Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section Xl, approved by the NRC in 10 CFR 50.55a(b)(2) one year before the start of the new interval.

10 CFR 50.55a(g)(4)(ii) presently 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 before the start of the 120-month inspection interval (or the optional ASME Code cases listed in NRC Regulatory Guide 1.147, Revision 16, that are incorporated by reference in paragraph (b) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose inservice inspection interval commences during the 12 through 18-month period after July 21, 2011 may delay the update of their Appendix VIII program by up to 18 months after July 21, 2011."

Paragraph (b)(2) presently states: "As used in this section, references to Section Xl refer to Section Xl, Division 1, of the ASME Boiler and Pressure Vessel Code, and include the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition through the 2007 Edition with the 2008 Addenda, subject to the following conditions: ... "

Serial No.12-191 Docket Nos. 50-280/281 Attachment 1 Page 2 of 3

4. Reason for Request

Four Dominion nuclear operating units have started new 10-year inservice inspection intervals within the last three years:

Millstone Unit 3 Third Interval April 23, 2009 - April 22, 2019 Millstone Unit 2 Fourth Interval April 1, 2010 - March 31, 2020 North Anna Unit 1 Fourth Interval May 1, 2009 - April 30, 2019 North Anna Unit 2 Fourth Interval December 14, 2010 - December 13, 2020 Each of these four units updated their ASME Section Xl ISI Programs to the 2004 Edition of ASME Section Xl as this was the latest edition incorporated by reference in the Code of Federal Regulations one year prior to the start of the new intervals. The 2004 Edition was incorporated into the Final Rule on September 10, 2008, Volume 73, No. 176 of the Federal Register.

By Federal Register Volume 76, No. 119, dated June 21, 2011, the Code of Federal Regulations was amended to incorporate by reference the 2007 Edition with 2008 Addenda for ASME Boiler and Pressure Vessel Code, Section Xl, Division 1, superseding the 2004 Edition of ASME Section Xl as the latest edition. Therefore, Dominion would be required to update the Surry Unit 1 Fifth 10-year Interval, which begins on October 14, 2013, to a code edition published at a date later than 2004.

ASME Section XI activities at the Millstone, North Anna, and Surry Power Station units are standardized and corporately administered as a fleet operation at Dominion. Dominion IS[ and Non-destructive Examination (NDE) personnel assist one another in the planning, performing, reporting, and assessing of ISI activities throughout the fleet. Maintaining a common ASME Section Xl Code for the Dominion units and conforming to identical ASME Section Xl rules would assist incorporation of industry best standards and would reduce administrative burden and error-likely situations.

A similar relief request is being submitted for Surry Unit 2 (Relief Request S2-15-ISI-01) to facilitate operation of the six units using a common ASME Section Xl Code (i.e., the 2004 ASME Section Xl Code).

5. Proposed Alternative and Basis for Use Dominion proposes to use an ASME Section Xl Code Edition that was incorporated and referenced in an earlier revision of the Code of Federal Regulations; specifically, the 2004 Edition of ASME Section Xl for the Surry Unit 1 Fifth 10-year ISI Interval and will continue to incorporate all current and future 10 CFR 50.55a conditions,

Serial No.12-191 Docket Nos. 50-280/281 Attachment 1 Page 3 of 3 limitations, modifications, and augmented requirements. Dominion will use only those ASME Code Cases applicable to the 2004 Edition of Section XI as listed in the most recent revision of NRC Regulatory Guide 1.147, unless otherwise approved for use by relief from the NRC.

A detailed comparison between the 2004 Edition and the 2007 Edition/2008 Addenda was performed. There were no changes identified that ensured or increased an acceptable level of quality and safety, nor were any changes made to address any type of deficiency in the 2004 Edition.

Dominion believes that commonality will improve the level of quality and safety at the fleet units by sharing common knowledge and lessons learned for ISI Programs governed by the same ASME Section XI rules and will reduce error-likely situations.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), Dominion proposes to use an alternative to the ASME Boiler and Pressure Vessel,Section XI Code edition as specified by 10 CFR 50.55(b)(2) and use an earlier edition, the 2004 Edition with no Addenda, to establish the Surry Unit 1 Fifth 10-year ISI Interval. As this code edition was previously incorporated and referenced for use by the Code of Federal Regulations and is presently in use at four other Dominion units, the alternative will provide an acceptable level of quality and safety.

6. Duration of Proposed Alternative Dominion intends to use the 2004 Edition of ASME Section XI in its entirety, subject to limitations and modifications of 10 CFR 50.55a, as the Code of Reference for the Surry Unit 1 ISI Program for the entire Fifth 10-Year ISI Interval. The Surry Unit 1 Fifth 10-Year ISI Interval is scheduled to begin October 14, 2013 and end October 13, 2023.

7. Precedents Similar relief was granted to Entergy Operations, Inc. for Arkansas Nuclear One, Unit 2, by letter dated April 26, 2010, "Arkansas Nuclear One, Unit 2 - Request for Relief ANO2-ISI-003, Alternative to Use 2001 Edition through 2003 Addenda in lieu of the 2004 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section Xl (TAC No. ME1452)." [ML100970659]

Serial No.12-191 Docket Nos. 50-280/281 Attachment 2 Fifth 10-year Inservice Inspection Interval 2004 ASME Section XI Code of Record -

Relief Request S2-15-ISI-01 Virginia Electric and Power Company (Dominion)

Surry Power Station Unit 2

Serial No.12-191 Docket Nos. 50-280/281 Attachment 2 Page 1 of 3 Virginia Electric and Power Company Surry Power Station Unit 2 Fifth 10-year Inservice Inspection Interval ASME Section XI Code of Record Relief Request S2-15-ISI-01 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)

1. ASME (American Society of Mechanical Engineers) Code Components Affected ASME Section Xl Class 1, 2 and 3 components and component supports

2. Applicable Code Edition and Addenda

2004 ASME Section XI Code Edition, No Addenda, for the Fifth 10-year Inservice Inspection (ISI) Interval

3. Applicable Code Requirement

Dominion is required to update the Surry Unit 2 120-month ISI Program to the latest Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section Xl, approved by the NRC in 10 CFR 50.55a(b)(2) one year before the start of the new interval.

10 CFR 50.55a(g)(4)(ii) presently 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 before the start of the 120-month inspection interval (or the optional ASME Code cases listed in NRC Regulatory Guide 1.147, Revision 16, that are incorporated by reference in paragraph (b) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose inservice inspection interval commences during the 12 through 18-month period after July 21, 2011 may delay the update of their Appendix VIII program by up to 18 months after July 21, 2011."

Paragraph (b)(2) presently states: "As used in this section, references to Section XI refer to Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, and include the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition through the 2007 Edition with the 2008 Addenda, subject to the following conditions: ..

Serial No.12-191 Docket Nos. 50-280/281 Attachment 2 Page 2 of 3

4. Reason for Request

Four Dominion nuclear operating units have started new 10-year inservice inspection intervals within the last three years:

Millstone Unit 3 Third Interval April 23, 2009 - April 22, 2019 Millstone Unit 2 Fourth Interval April 1, 2010 - March 31, 2020 North Anna Unit 1 Fourth Interval May 1, 2009 - April 30, 2019 North Anna Unit 2 Fourth Interval December 14, 2010 - December 13, 2020 Each of these four units updated their ASME Section Xl ISI Programs to the 2004 Edition of ASME Section XI as this was the latest edition incorporated by reference in the Code of Federal Regulations one year prior to the start of the new intervals. The 2004 Edition was incorporated into the Final Rule on September 10, 2008, Volume 73, No. 176 of the Federal Register.

By Federal Register Volume 76, No. 119, dated June 21, 2011, the Code of Federal Regulations was amended to incorporate by reference the 2007 Edition with 2008 Addenda for ASME Boiler and Pressure Vessel Code, Section Xl, Division 1, superseding the 2004 Edition of ASME Section Xl as the latest edition. Therefore, Dominion would be required to update the Surry Unit 2 Fifth 10-year Interval, which begins on May 10, 2014, to a code edition published at a date later than 2004.

ASME Section Xl activities at the Millstone, North Anna, and Surry Power Station units are standardized and corporately administered as a fleet operation at Dominion. Dominion ISI and Non-destructive Examination (NDE) personnel assist one another in the planning, performing, reporting, and assessing of ISI activities throughout the fleet. Maintaining a common ASME Section XI Code for the Dominion units and conforming to identical ASME Section Xl rules would assist incorporation of industry best standards and would reduce administrative burden and error-likely situations.

A similar relief request is being submitted for Surry Unit 1 (Relief Request S1-15-ISI-01) to facilitate operation of the six units using a common ASME Section Xl Code (i.e., the 2004 ASME Section Xl Code).

5. Proposed Alternative and Basis for Use Dominion proposes to use an ASME Section XI Code Edition that was incorporated and referenced in an earlier revision of the Code of Federal Regulations; specifically, the 2004 Edition of ASME Section Xl for the Surry Unit 2 Fifth 10-year ISI Interval and will continue to incorporate all current and future 10 CFR 50.55a conditions,

Serial No.12-191 Docket Nos. 50-280/281 Attachment 2 Page 3 of 3 limitations, modifications, and augmented requirements. Dominion will use only those ASME Code Cases applicable to the 2004 Edition of Section Xl as listed in the most recent revision of NRC Regulatory Guide 1.147, unless otherwise approved for use by relief from the NRC.

A detailed comparison between the 2004 Edition and the 2007 Edition/2008 Addenda was performed. There were no changes identified that ensured or increased an acceptable level of quality and safety, nor were any changes made to address any type of deficiency in the 2004 Edition.

Dominion believes that commonality will improve the level of quality and safety at the fleet units by sharing common knowledge and lessons learned for ISI Programs governed by the same ASME Section Xl rules and will reduce error-likely situations.

Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), Dominion proposes to use an alternative to the ASME Boiler and Pressure Vessel, Section Xl Code edition as specified by 10 CFR 50.55(b)(2) and use an earlier edition, the 2004 Edition with no Addenda, to establish the Surry Unit 2 Fifth 10-year ISI Interval. As this code edition was previously incorporated and referenced for use by the Code of Federal Regulations and is presently in use at four other Dominion units, the alternative will provide an acceptable level of quality and safety.

6. Duration of Proposed Alternative Dominion intends to use the 2004 Edition of ASME Section Xl in its entirety, subject to limitations and modifications of 10CFR50.55a, as the Code of Reference for the Surry Unit 2 ISI Program for the entire Fifth 10-Year ISI Interval. The Surry Unit 2 Fifth 10-Year ISI Interval is scheduled to begin May 10, 2014 and end May 9, 2024.

7. Precedents Similar relief was granted to Entergy Operations, Inc. for Arkansas Nuclear One, Unit 2, by letter dated April 26, 2010, "Arkansas Nuclear One, Unit 2 - Request for Relief ANO2-1SI-003, Alternative to Use 2001 Edition through 2003 Addenda in lieu of the 2004 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI (TAC No. ME1452)." [ML100970659]