ML20238F328
| ML20238F328 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/31/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20238F323 | List: |
| References | |
| NUDOCS 9809030274 | |
| Download: ML20238F328 (3) | |
Text
. - - - - - - _. - - - - - - - -. - - - - - - - _ _ _ _ _ _,
%g g-4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION 2
W \\SHINGToN, o.C. 20555-4001
\\...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF NO.12R-14 COMMONWEALTH EDISON COMPANY BRAIDWOOD STATION. UNITS 1 AND 2 l
DOCKET NOS. STN 50-456 AND STN 50-457
1.0 INTRODUCTION
The Code of Federal Regulations,10 CFR 50.55a, requires that inservice inspection (ISI) of certain ASME Code Class 1,2, and 3 components be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (Code) applicable edition and addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to paragraph 10 CFR 50.55a(g)(6)(i), or altematives authorized pursuant 10 CFR 50.55a(a)(3). In proposed attematives, the licensee must demonstrate that: (i) the proposed altamatives psovide an acceptable level of quality and safety; or (ii) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
In requesting relief, the licensee must demonstrate that the requirement is impractical for its facility.
This safety evaluation covers Relief Request 12R-14, submitted by Commonwealth Edison Company (Comed) by letter dated April 17,1998, as supplemented by letter dated August 3, 1998. Comed requested authorization to perform visual examination of Code class snubbers in accordance with the Technical Specifications (TSs) in lieu of the requirements of ASME/ ANSI l
OMa-1988, Part 4, until the improved Technical Specifications (ITS) Technical Requirements Manual (TRM) is implemented. At that time the TS requirements will be relocated to the TRM.
j The licensee's ISI program is based on the requirements of the ASME Code,Section XI,1989 Edition for the second 10-year interval ISI program at Braidwood Station, Units 1 and 2.
Section XI, Subsection lWF, Article IWF-5000, Subarticle IWF-5300(a) contains inservice examination requirements that are to be performed in accordance with the first addenda to ASME/ ANSI OM-1987, Part 4 (published in 1988), using the VT-3 visual examination method described in IWA-2213.
2.0 EVALUATION l
Relief is requested from the requirements for inservice examination of snubbers in accordance with Subarticle 5300(a) contained in ASME/ ANSI OM-1987 Edition, Part 4, pubi.shed in 1988 (OMa-1988 Part 4). The licensee requests authorization to use attemative snuboer visual 9009030274 990831 Enclosure PDR ADOCK 05000456 G
PDR g
. examination requirements at the Braidwood Station, Units 1 and 2, during the second 10-year interval of the ISI program. The altemative requirements are those in the Braidwood Station Technical Specifications. These requirements will be relocated to the TRM when the ITS is implemented.
2.1. Licensee's Proposed Altemative The altomative proposed for Brasdwood Station, Units 1 and 2, is to use the TS requirements for the inservice examination of snubbers in lieu of the ASME Code,Section XI, Article IWF 5000, Subarticle 5300 (a) requirements contained in the first Addenda to ASME/ ANSI OM-1987, Part 4 (published in 1988), using the VT-3_ visual examination method described in Paragraph IWA-2213. Personnel performing the snubber visual examination will be qualified and certified to perform Visual, VT-3 examinations per IWA-2300.
The visual examination boundary will include the snubber structural attachment to the foundation or supporting structure up to and including the fasteners that connect the snubber to the pipe or component attachment. Component support steel, including ASME Section !!!, Subsection NF component supports, connected to snubber structural attachments, will be visually examined
.(VT-3). If any component included in the visual examination boundary cannot be verified to be properly aligned, tight, and functional during the VT-3 examination, due to insulation interference, the insulation will be removed from the component prior to performing the examination.
Further, the examination of snubber integral and nonintegral attachments, as required by IWF-5200(c) and IWF-5300(c), will be performed in accordance with Subsection IWF.
2.2 Licensee's Basis For Reauested Altemative Braidwood Station TS 3/4.7.8 includes a comprehensive program for visual examination of all safety related hydraulic and mechanical snubbers. The program scope encompasses all ASME Code Class 1,2, and 3 snubbers, safety related non-code class snubbers, and non-safety related snubbers whose failure could adversely affect a safety related system. Braidwood Station TS 4.0.5 also includes requirements for visual examination of Code Class 1,2, and 3 snubbers in accordance with ASME Section XI and ASME/ ANSI OMa-1988, Part 4. The snubber program requirements datailed in the TS (TRM) are as rigorous and conservative, and similar in content, L
as the program presented in ASME/ ANSI OMa-1988, Part 4, Subarticles IWF-5200(a) and PNF5300(a). All of the programs have a.,nsistent requirements for visual examination, examination frequency, examination sample size, examination failure evaluation, examination corrective actions, and examination documentation.
L L
l The licensee considers the overlap of the requirements for snubber visual examination existing in the TS (TRM) and ASME Section XI an unnecessary redundancy that provides no additional plant safety benefits. The licensee considers that the proposed altemative provides an acceptable level of quality and safety.
3.0 EVALUATION Based on its review of the information provided in the request for relief from the snubber visual inservice examination requirements of IWF-5300(a), the staff has determined that the licensee's
(-
l-1
)
L proposed altamative to use TS requirements (which will be relocated to the TRM when the ITS is implemented) provides an acceptable level of quality and safety. The staff's determination is
. based on the proposed altemate provisions and the following considerations; 1) Comed indicates that the TS (TRM) and the ASME Code,Section XI, Subsection IWF, Article IWF-5000, Subarticle IWF-5300(a), contair,ed in ASME/ ANSI OMa-1988, Part 4, are similar in scope and have consistent visual examination and frequency, sample size, failure evaluation, corrective action, and documentation requirements, 2) visual, VT-3, TS snubber examinations will be consistent with the methods described in IWA-2213, 3) personnel performing visual, VT-3, snubber examinations will be qualified and certified in accordance with IWA-2300. Therefore, the proposed altemative may be authorized.
4.0 CONCLUSION
The staff concludes that the licensee's proposed altemative to the requested relief from the snubber visualinservice examination requirements contained in the ASME Code,Section XI.
Subsection IWF, Article IWF-5000, Subarticle IWF-5300(a), may be authorized pursuant to
' 10 CFR 50.55a(a)(3)(i) based on the determination that the licensee's proposed altematives and provisions, together with the conditions described herein, provide an acceptable level of quality and safety.
Principal Contributor: F. Grubelich Dated: August 31, 1998 l
L_______.1____________._2___.___._
_. _ _ _. _