ML071440342

Relief Request to Use Portion of 2001 Edition of American Society of Mechanical Engineers Code

ML071440342
Person / Time
Site:	Surry, North Anna
Issue date:	08/03/2007
From:	Marinos E NRC/NRR/ADRO/DORL/LPLII-1
To:	Christian D Virginia Electric & Power Co (VEPCO)
Marinos, EC, NRR/DORL 415-2911
References
TAC MD3200, TAC MD3201, TAC MD3202, TAC MD3203
Download: ML071440342 (7)

Text

August 3, 2007 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 AND SURRY POWER STATION, UNIT NOS. 1 AND 2 - RELIEF REQUEST TO USE PORTION OF 2001 EDITION THROUGH 2003 ADDENDA OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE (TAC NOS. MD3200, MD3201, MD3202 AND MD3203)

Dear Mr. Christian:

By letter dated October 9, 2006, Virginia Electric and Power Company (Dominion), the licensee for North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2) and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2) submitted a Relief Request to use only portions of the 2001 edition through 2003 addenda of the American Society of Mechanical Engineers (ASME),

Boiler and Pressure Vessel Code (Code),Section XI for containment inservice inspection (ISI).

The NRC staff concludes that the licensees request to use only portions of the 2001 edition through 2003 addenda of ASME Code,Section XI, Table IWE-2500-1, Item No. E1.12 addresses all related requirements and associated modifications and limitations in paragraph 50.55a(b) of Title 10 of the Code of Federal Regulations (10 CFR). Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the NRC staff approves the use of the 2001 edition through 2003 addenda of ASME Code,Section XI, Table IWE-2500-1, Item No. E1.12 at North Anna 1 and 2, and Surry 1 and 2 for the first 10-year containment inservice inspection interval. The NRC staffs safety evaluation is enclosed.

Sincerely,

/RA/

Evangelos C. Marinos, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338, 50-339, 50-280, and 50-281

Enclosure:

Safety Evaluation cc w/encl: See next page

August 3, 2007 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 AND SURRY POWER STATION, UNIT NOS. 1 AND 2 - RELIEF REQUEST TO USE PORTION OF 2001 EDITION THROUGH 2003 ADDENDA OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE (TAC NOS. MD3200, MD3201, MD3202 AND MD3203)

Dear Mr. Christian:

By letter dated October 9, 2006, Virginia Electric and Power Company (Dominion), the licensee for North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2) and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2) submitted a Relief Request to use only portions of the 2001 edition through 2003 addenda of the American Society of Mechanical Engineers (ASME),

Boiler and Pressure Vessel Code (Code),Section XI for containment inservice inspection (ISI).

The NRC staff concludes that the licensees request to use only portions of the 2001 edition through 2003 addenda of ASME Code,Section XI, Table IWE-2500-1, Item No. E1.12 addresses all related requirements and associated modifications and limitations in paragraph 50.55a(b) of Title 10 of the Code of Federal Regulations (10 CFR). Therefore, pursuant to 10 CFR 50.55a(g)(4)(iv), the NRC staff approves the use of the 2001 edition through 2003 addenda of ASME Code,Section XI, Table IWE-2500-1, Item No. E1.12 at North Anna 1 and 2, and Surry 1 and 2 for the first 10-year containment inservice inspection interval. The NRC staffs safety evaluation is enclosed.

Sincerely,

/RA/

Evangelos C. Marinos, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338, 50-339, 50-280, and 50-281

Enclosure:

Safety Evaluation cc w/encl: See next page Distribution:

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ADAMS ACCESSION NO. ML071440342

• memo transmitting SE dated. NRR-028 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/PM NRR/LPL2-1/LA NRO/DE/SEB1/BC DLR/RLRC/BC OGC NRR/LPL2-1/BC NAME SLingam:nc RJervey MOBrien BThomas KChang ASilvia NCO EMarinos DATE 7/25/07 7/25/07 8/2/07 7/25/07*

7/26/07 8/2/07 8/3/07

OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF PORTION OF LATER EDITION AND ADDENDA OF ASME CODE, SECTION XI VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338, 50-339, 50-280, AND 50-281

1.0 INTRODUCTION

By a letter dated October 9, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML062860603), Virginia Electric and Power Company (Dominion), the licensee for North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2), and Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2), submitted its request for use of Item Number E1.12 of the 2001 edition through 2003 addenda of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI, subsection IWE, Table-2500-1, Category E-A. Subsection IWE of ASME Code,Section XI, provides the requirements for inservice inspection (ISI) of Class CC (concrete containment) and Class MC (metallic containment) of light-water cooled power plants. Pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(g)(4)(iv), the licensee requests approval to use the indicated section of the 2001 edition through 2003 addenda, only for the first 10-year containment ISI interval, in lieu of the 1992 edition currently in use.

2.0 REGULATORY EVALUATION

Section 50.55a(g)(4)(iv) allows that inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda of the ASME Code that are incorporated by reference in paragraph (b) of 10 CFR 50.55a, subject to listed limitations and modifications. This section also states that portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

Section 50.55a(b)(2) endorses the 2001 edition through the 2003 addenda of ASME Code.

Pursuant to 10 CFR 50.55a(b)(2)(ix), limitations identified in paragraphs 10 CFR 50.55a (b)(2)(ix)(A), (b)(2)(ix)(B), and, (b)(2)(ix)(F) through (b)(2)(ix)(I) apply to the use of this edition and addenda.

Enclosure

3.0 TECHNICAL EVALUATION

The current version of the code in use at North Anna 1 and 2 and Surry 1 and 2 is the 1992 edition and addenda of the ASME Code,Section XI, Subsection IWE, Table IWE-2500-1, Examination Category E-A, Item E1.12. This version requires a 100-percent VT-3 examination of accessible submerged surface areas of the containment vessel.

ASME Code,Section XI, 2001 edition through 2003 addenda, Subsection IWE, Table IWE-2500-1, Examination Category E-A requires general visual examination for item E1.12, for submerged surface areas, instead of a VT-3 examination. However, Section 50.55a(b)(ix)(G) requires that a VT-3 examination be used to conduct the examinations in Item E1.12 of Table IWE-2500-1 for wetted surfaces of submerged areas.

The effect of this change would be to reduce the VT-3 examination from all accessible surface areas of the metallic liner (and the portions of insulated surface areas), to VT-3 examination of wetted surfaces of submerged areas only, and provide for general visual examination of other accessible surface areas requiring examination. Additionally, Table IWE-2500-1 for the 2001 edition through 2003 addenda provides for examination to be performed on all accessible inside or outside surfaces, where the 1992 edition allows either the inside or outside surface to be examined. The Nuclear Regulatory Commission (NRC) staff finds that the licensees proposal is acceptable given that the use of the 2001 edition assures all accessible and submerged areas will be inspected either with a general visual or a VT-3 examination.

The additional consideration needed to accept the licensees proposal is to assure all related requirements from the later edition are met and listed limitations are implemented. Section 50.55a(b)(2)(ix) places limitations on the use of the 2001 edition through 2003 addenda. The licensees evaluation identifies the listed limitations required for use of the 2001 edition in their evaluation. Paragraphs 10 CFR 50.55a (b)(2)(ix)(A), (b)(2)(ix)(B), and, (b)(2)(ix)(F) through (b)(2)(ix)(I) apply. The licensees evaluation indicates that there is no difference between the requirements imposed by the 1992 edition and the 2001 edition with 2003 addenda, or the item does not apply to Item E1.12 in Table IWE-2500-1, with several exceptions.

The owner-defined personnel qualification provisions in IWE-2330(a) from the 2001 edition through 2003 addenda, are not approved for use as stated in paragraph 10 CFR 50.55a(b)(2)(ix)(F). The licensee stated that its personnel are qualified in accordance with IWA-2300, thus are not affected by this limitation. This level of certification will verify that the capability and visual acuity of the examiners are sufficient to detect evidence of potential degradation of the containment surface areas. The NRC staff finds that this approach meets the code because it retains code specified qualification provisions and avoids the use of owner-defined qualifications.

The owner-defined visual examination provisions of IWE-2310(a) from the 2001 edition through 2003 addenda are not approved for use as stated in 10 CFR 50.55a(b)(2)(ix)(G). The licensee stated they will implement VT-3 methods using the provisions of IWA-2200. Thus, this limitation will not affect licensee use of the later edition. The NRC staff finds that this approach meets the regulation and the code because it retains code specified visual examination provisions and does not use owner-defined examination criteria.

The licensee discussed related requirements in its application. Code requirements for VT-3 examinations from IWA-2200 and IWE-3510 were compared and found to be equivalent in practical application, as the Dominion inspection procedures currently implement 2001 edition requirements. An additional related requirement of the VT-3 examination pertains to the qualification of examiners. The licensee stated that it would use the 1992 edition requirements for qualification of VT-3 examiners for the upcoming inspection. The 2001 edition states that earlier qualifications are valid until recertification is required. In the future, the licensee shall utilize the later edition of the ASME Code to qualify its VT-3 examination personnel when recertification is required. This is acceptable to the NRC staff as the qualification requirements are implemented as required by the ASME Code, and are not limited by the regulations of 10 CFR 50.55a.

4.0 CONCLUSION

The review of the licensees request to use the 2001 edition through 2003 addenda of ASME Code,Section XI, for Table IWE-2500-1, Item E 1.12, and review of the related requirements and limitations mandated by 10 CFR 50.55(b)(2)(ix)(A), (b)(2)(ix)(B), and, (b)(2)(ix)(F) through (b)(2)(ix)(I) as applied to North Anna 1 and 2 and Surry 1 and 2 was performed and found to meet the requirements necessary to use the later code edition and addenda.

As a result of this review, the NRC staff concludes that the proposal is acceptable and approves the use of the 2001 edition through 2003 addenda of ASME Code,Section XI, for Table IWE-2500-1, Item E 1.12 pursuant to 10 CFR 50.55a(g)(4)(iv), for the first 10-year containment ISI interval.

Principal Contributors: M. Valentin-Olmeda J. Ma Date: August 3, 2007

North Anna Power Station, Units 1 & 2 and Surry Power Station, Units 1 & 2 cc:

Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources Services, Inc.

Building 475, 5th Floor Rope Ferry Road Waterford, Connecticut 06385 Mr. Donald E. Jernigan Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711 Mr. C. Lee Lintecum County Administrator Louisa County Post Office Box 160 Louisa, Virginia 23093 Old Dominion Electric Cooperative 4201 Dominion Blvd.

Glen Allen, Virginia 23060 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory Commission P. O. Box 490 Mineral, Virginia 23117 Mr. Daniel G. Stoddard Site Vice President North Anna Power Station Virginia Electric and Power Company Post Office Box 402 Mineral, Virginia 23117-0402