ML062200457

Deviation from BWR Vessel and Internals Project (BWRVIP) Guideline

ML062200457
Person / Time
Site:	Oyster Creek, PROJ0704
Issue date:	08/07/2006
From:	Rausch T AmerGen Energy Co, Exelon Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2130-06-20373, TAC MA5012
Download: ML062200457 (3)

Text

August 7,2006 2130-06-20373 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

Deviation from BWR Vessel and lnternals Project (BWRVIP) Guideline

References:

1) Letter from Robin Dyleffom Mulford (BWR Vessel and lnternals Project (BWRVIP)) to All BWRVIP Committee Members, dated April 27, 2006

2) BWRVIP-75-A: BW R Vessel and lnternals Project Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules, Final Report, October 2005

3) BWR Vessel and lnternals Project Technical Basis for Inspection Relief for BWR internal Components with Hydrogen Injection (BWRVIP-62), EPRl Report TR-108705, Final Report, December 1998.

BWRVIP-94, Revision 1: BWR Vessel and lnternals Project Program Implementation Guide, Final Report, December 2005 Safety Evaluation of the BWRVIP Vessel and lnternals Project, Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules (BWRVIP-75), EPRI Report TR-113932, October 1999 (TAC NO. MA5012),

dated September 15, 2000 The BWR Vessel and lnternals Project (BWRVIP) notified all BWRVIP utilities (Reference 1) that relief from weld inspections discussed in BWRVIP-75-A (Reference 2) should not be taken until such time as the NRC issues a Safety Evaluation Report for BWRVIP-62 (Reference 3),

and the BWRVIP provides additional guidance on implementing inspection relief for Hydrogen Water Chemistry (HWC) or Noble Metal Chemicals Addition (NMCA). The reference to an NRC-approved Safety Evaluation Report for BWRVIP-62, and the criteria necessary to demonstrate an effective HWC and NMCA program for Oyster Creek Generating Station (OCGS), is provided in Section 3.6 of BWRVIP-75-A.

Specifically, as discussed in Section 3.6 (Effective HWC) of BWRVIP-75-A:

U.S. Nuclear Regulatory Commission August 7, 2006 Page 2 Therefore, for the purposes of this report, effective HWC (in~ludingN ~ G can A ~be demonstrated by verifying and validating that an effective HWC program inaccordance with the NRC-amroved BWRVIP-62 quideline has been achieved for welds in every

~ i ~ i system ng for which WWC credit is taken or demonstrated by means of a plant-specific evaluation approved by NRC.

Therefore, OCGS has developed this Deviation Disposition in accordance with BWRVIP-94, Revision 1 (Reference 41, Appendix B (Guidelines for Deviation Disposition). This Deviation Disposition justifies a deviation from the requirement to have an NRC-approved Safety Evaluation Report for BWRVIP-62 as discussed above, This Deviation Disposition is justified through a review of the HWC and NMCA requirements at OCGS since 2000 for demonstrating an effective program as provided in Open ltem 3.7and 3.8 of the BWRVIP-75-A NRC Safety Evaluation Report (Reference 5).

OCGS has reviewed the Open ltem 3,7 and 3.8 requirements provided in the BMRVIP-75-A Safety Evaluation Report, and has demonstrated that OCGS meets the intent of these requirements. Therefore, this deviation from the requirement of B ~ ~ Rto ~ ~ P ~

have an NRC-approved BWRVIP-62 SER is justified.

As discussed in BWRVIP-94, Revision 1 Section 3.5 (Reporting):

If at any time a utility does not impi~mentany portion of an a ~ p i i c a ~ ~ ~~~ ~or ~ ~ a needed BWRVlP guideline that has been approved by the Executive ~ ~and ~ ~

t r a n s ~ te ~ the

~ eNRC,

~ the utility shall notiVy the NRC and the ~ ~ ~VEW?  ? 45VdaysI ~

of the ~ t j ~ iexecutive ty concurrence with the devtation ~ ~ s p o ~ i t The

~ ~~n ..

ficensee shall clearly state ~~~f they are viati ti^^ from, i.e., irrspection r ~ ~ ~ ~ i;r~sp~.e!ior:

~ ! n ~ ~ ~ t ~ ,

s c h ~ d ~ l eetc.,

s , of the B ~uide~ines and whar is being aone in lieu of the ents, as neces,wry In a the letter should be very clear fo indicate that is being t ~ a n s ~ i for

~ed tion only and that the kensee is not r e ~ ~ e s t i n g any actior: fro,? the NRC staff.

Ths Deviation Disposition has been approved by the Senior Vice President of Engineering ard Technical Services, and the Vice President - Oyster Creek Generating Station. The ahom discussion provides the statement from BWRVIP-75-A from which Oyster Creak ~ e ~ ~ r ~

Station is deviating. No additional requirernents are being imposed. This letter is beirrg transmitted to the NRC for information only and is not requesting any action from the NRC: skff.

if any additional j n ~ o ~ m a ~is~needed, on please contact Torn Loomis at (tit 0) 765-5513.

Oyster Creek Generating Station

US. Nuclear Regulatory Commission August 7,2006 Page 3 cc: S. J. Collins, Administrator, USNRC Region I G. E. Miller, USNRC Project Manager, Oyster Creek M. S. Ferdas, USNRC Senior Resident Inspector, Oyster Creek Director, Bureau of Nuclear Engineering, NJDEP NRC BWRVIP Project Manager R. Stark - BWRVIP File No. 06039