PLA-6099, Notification of Changes to Snubber Inspection and Testing Requirements for Third 10-Year Interval In-Service Inspection Program Plan

Notification of Changes to Snubber Inspection and Testing Requirements for Third 10-Year Interval In-Service Inspection Program Plan

ML070890408
Person / Time
Site:	Susquehanna
Issue date:	03/19/2007
From:	Mckinney B Susquehanna
To:	Document Control Desk, NRC/NRR/ADRO
References
PLA-6099
Download: ML070890408 (6)

Text

Britt T. McKinney PPL Susquehanna, LLC

• i j f ý Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 I *,".

Tel. 570.542.3149 Fax 570.542.1504 btmckinney @pplweb.com uwu, - .: .

MAR 19 2001 TM U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION NOTIFICATION OF CHANGES TO SNUBBER INSPECTION AND TESTING REQUIREMENTS FOR THIRD 10-YEAR INTERVAL IN-SERVICE INSPECTION PROGRAM PLAN FOR SUSQUEHANNA SES UNITS 1 & 2 Docket Nos. 50-387 PLA-6099 and 50-388

Reference:

Letterfrom Mr. R. J. Laufer (NRC) to Mr. B. L. Shriver (PPL) titled "SusquehannaSteam Electric Station Units I and 2, Third JO-Year In-service Inspection (1S1) Interval ProgramPlan (TAC Nos. MCI 185, MCI186, MC 191, MCl192, MCI 193, MCl194, MCl195, MCl196, MCl197, MCl198, MCl199, MCI200),"

dated September 24, 2004.

The purpose of this letter is to document the intent of PPL to comply with the require-ments of 10 CFR 50.55a (b)(3)(v) instead of the previously approved Relief Request 3RR-03 that was submitted as part of our Third 10-Year Interval ISI Program Plan (Reference 1). This Relief Request granted relief from the Code requirements for snubber visual examination and functional testing of snubbers and is provided as Attachment I to this letter, for reference purposes only. These requirements for examination and testing of snubbers were included in the SSES Unit 1 and Unit 2 Technical Requirements Manual (TRM) Section 3.7.8 and implemented via station procedures.

Pursuant to 10 CFR 50.55a (b)(3)(v), PPL plans to implement Subsection ISTD, titled "In-service Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Power Plants," ASME OM Code, 1995 Edition, up to and including the 1998 Edition through the 2003 Addenda for examination and testing of snubbers. Improvements in the methodology of snubber examinations and testing contained in the Code ensure continued safe operation of the plant without any compromise in safety or impact to the health or safety of the public. Completed snubber examinations and functional testing for

Document Control Desk PLA-6099 the Third 10-Year Interval will be reviewed. Based on this review, a plan will be developed to ensure that the Code requirements will be complied with, from the original start of the Interval to its completion. PPL will have the Code requirements fully implemented by November 16, 2007. This will also include the incorporation of the necessary changes to the TRM, station procedures, and ISI Program Plan to insure compliance with the Code for the full 10-year interval.

In support of implementing the later Edition and Addenda of the OM Code, PPL will also utilize Code Case OMN- 13 "Requirements for Extending Snubber In-service Visual Examination Interval at LWR Power Plants." This Code Case has been approved unconditionally for use in Regulatory Guide 1.192, "Operation and Maintenance Code Case Acceptability."

This revised approach to the PPL snubber visual examination and functional testing program has been discussed with SSES NRC Project Manager Richard Guzman.

Should you have any questions, please contact Dayne R. Brophy, at (570) 542-3365.

Sincerely, B. T. McKinney - Revision 0 to Relief Request 3RR-03 (for reference only) cc: Regional Administrator - Region 1 Mr. A. J. Blarney, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. R. Janati, DEP/BRP

ATTACHMENT 1 TO PLA-6099 (Reference only)

REVISION 0 TO RELIEF REQUEST 3RR-03

ISl Progr-aimPlan Susquehanna Steam Electric Station UOnits I & 2, ThirdInterval RELIEF REQUEST NUMBER: 3RR-03 (Page lof 3)

COMPONENT IDENTMFICATION Code Class: 1,2, and 3

References:

IWF-5200(a) and IWF-5300(a)

IWF-5200(b) and [WF-5300(b)

JWF-5200(c) and IWF-5300(c)

Examination Category: N/A Item Number: N/A

==

Description:==

ISI Snubbers Included in the TRM Snubber Visual Examination and Testing Program CODE REOUJRMENTS Paragraphs [WF-5200(a) and IWF-5300(a) require Preservice and Inservice examinations to be performed in accordance with ASMEiANSI OM, Part 4, using the VT-3 visual examination method described in IWA-2213.

Paragraphs IWF-5200(b) and IWF-5300(b) require Preservice and Inservice tests to berperformed in accordance with ASME/ANSI OM, Part 4. Table IWA-1600-1 specifies use of the 1987 Edition, with OMa-1988 Revision of ASME/ANSI OM, Part 4.

Paragraphs IWF-5200(c) and IWF-5300(c) require integral and nonintegral attachments for snubbers, including lugs, bolting, pins, and clamps, shall be examined in accordance with the requirements of Subsection [WF.

The regulation in IOCFR50o.55a(b)(3)(v) permits the use of Subsection ISTD, titled "Inservice Testing of Dynamic Restraints (Snubbers) in Light-water Reactor Power Plants," ASME OM Code, 1995 Bdition up to and including the 1998 Edition through the 2000 Addenda, in lieu of the requirements for snubbers in Section XI, IWF-5200(a) and (b) and IWF-5300(a) and (b), by making appropriate changes to their technical specifications or licensee controlled documents.

Preservice and inservice examinations shall be performed using the VT-3 visual examination method described in TWA-2213.

BASIS FOR RELIEF Pursuant to 10CFR50.55a(a)(3)(i), relief is requested on the basis that the proposed alternative would provide an acceptable level of quality and safety.

The current SSES TRM snubber program, Section 3.7.8, includes a comprehensive program for visual examination and functional testing requirements of safety related and non-safety related snubbers.

ISN ProgramPlarl SunsiehaninaStean ElaecricStation Units I & 2, Third Iaterval RELIEF REQUEST NUMBER: 3RR-03 (Page 2 of 3)

BASIS FOR RELIEF (Continued)

There are approximately 956 safety related and non-safety related snubbers at SSES Units I and 2.

The overlap of the visual examination program required by ASME Section XG and the TRM snubber program for the 1SI Class snubbers presents an unnecessary redundancy without a compensating increase in the level of quality and safety.

The TRM snubber visual examination program requires a sample size of 100% of all safety related and non-safety related smubbers and incorporates the alternate snubber visual examination delineated in NRC Generic Letter (GL) 90-09, "Alternate Requirements for Snubber Visual Inspection Intervals and Corrective Actions." As determined by the NRC, the alternate schedule of GL 90-09 maintains the same confidence level of quality and safety as the previous TRM schedule, which was very similar in content to that of OMa-1988, Part 4.

The GL 90-09 alternate schedule is based on the number of unacceptable snubbers found during the previous examination in proportion to the sizes of the various snubber populations or categories. The alternative examination interval is based on arefueling cycle of up to 24 months and maybe as long as two fuel cycles, depending on the number of unacceptable snubbers found during the previous visual examination.

Based on the reason that the TRM snubber visual examination and testing program maintains the same confidence level of quality and safety as that of 0Ma-1988, Part 4, SSES requests that the TRM visual examination and testing program for snubAers be used in lieu otf the OMa-1988, Part 4 visual examinations and testing program required by ASME Section XI, Subarticles IWF-5200(a) and IWVF-5300(a), IWF-5200(b) and IWF-5300(b), and IWF-5200(c) and WF-5300(c).

PROPOSED ALTERNATE EXAMTNATION SSES will perform visual examinations and testing of safety related and non-safety related snubbers in accordance with the snubber examination and testing program contained in the latest approved revision of the TRM in lieu of the OMa-1988, Part 4 visual examination and testing program required by ASME Section XI, Subarticles IWF-5200(a) and IWF-5300(a), IWF-5200(b) and rwF-5300(b).

As required by IWF-5200(c) and TWF-5300(c) the examination of snubber integral and nonintegral attachments, including lugs, bolting, pins, and clamps will also be perfomned in accordance with the TRM snubber program.

It should be noted that snubber welded attachments will be performed in accordance with the ASME Section XT Subsections [VWB, IWC, and IWD welded attachment examination requirements.

IS! ProgramPlan Susquehanta Steam Electric Station Units I & 2, Third titlerval RELIEF REQUEST NUMBER: 3RR-03 (Page 3 of 3)

PROPOSED ALTERNATE EXAMINATION (Continued)

Visual examiners, who are qualified to the applicable rules ofASME Section XI, Article IWA-2000, "Examination and Inspection," will perform the examinations and tests of safety related and non-safety related snubbers. Visual examination and testing results of safety related and non-safety related snubbers will be recorded and reported in accordance with the applicable rules of ASME Section XI, Article 1WA-6000.

APPLICABLE TIME PERIOD Relief is requested for the third ten-year inspection interval of the Inservice Inspection Program for SSES Units I and 2.