ML022380030
| ML022380030 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/14/2002 |
| From: | Montgomery B Constellation Generation Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMP1L 1685, TAC MB4085 | |
| Download: ML022380030 (2) | |
Text
P.O. Box 63 Lycoming, New York 13093 Constellation Generation Group Nine Mile Point Nuclear Station August 14, 2002 NMP1L 1685 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Nine Mile Point Unit 1 Docket No. 50-220 DPR-63 TAC No. MB4085
Subject:
Request for Authorization to Use Risk-Informed Inservice Inspection Alternative Gentlemen:
By letter dated February 22, 2002 (NMP1L 1644), Nine Mile Point Nuclear Station, LLC (NMPNS) submitted inservice inspection (ISI) relief request ISI-22 for Nine Mile Point Unit I (NMP1). This relief request proposed use of an alternative risk-informed ISI methodology in lieu of certain ASME Code Section XI requirements. The alternative methodology was developed by the Electric Power Research Institute (EPRI) and is included in EPRI topical report 112657, "Revised Risk-Informed Inservice Inspection Evaluation Procedure," Rev. B-A.
Section 5.2 of Attachment 1 to the relief request took exception to the EPRI methodology concerning the statement: "For flaws not exceeding acceptance criteria, items shall be examined for the next three inspection periods." Section 5.2 characterized this statement as "an inadvertent typographical error."
Based on a telephone discussion with the NRC staff on August 7, 2002, NMPNS now believes that the EPRI statement is ambiguous, but not erroneous. The technical basis for this change is that the term "acceptance criteria" in the statement should be understood as referring to the criteria in subsection IWB-3600 of Section XI and not the criteria in subsection IVVX-3500 of Section XI of the ASME Code.
In light of the above clarification, the two paragraphs in Section 5.2 of Attachment I to the relief request are to be replaced with the following:
"There are no exceptions taken to the EPRI methodology."
Page 2 NIP1L 1685 As stated in the February 22, 2002, letter, NMPNS requests NRC authorization for use of the proposed alternative by November 30, 2002, to support planning efforts for Refueling Outage Number 17.
Very truly yours, I r S.Mo gome~ry ur;c arEEngineering B SM/JJD/jm cc:
Mr. H. J. Miller, NRC Regional Administrator, Region I Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR (2 copies)