HNP-95-107, Requests Approval to Use Amse Code Case N-416-1
| ML18011B066 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/22/1995 |
| From: | Robinson W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HNP-95-107, NUDOCS 9512010110 | |
| Download: ML18011B066 (5) | |
Text
ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION 8BR:9512010110 DOC.DATE: 95/11/22 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION ROBINSON,W.R.
Carolina Power Sr Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET g
05000400 P
SUBJECT:
Requests approval to use AMSE Code Case N-416-1.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-89-04 NOTES:Application for permit renewal filed.
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N NOTE TO ALL"RIDS" RECIPIENTS:
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c Carolina Power & Light Company PO Box 165 New Hill NC 27562 William R. Robinson Vice President Harris Nuclear Plant NOV 22 1995 SERIAL: HNP-95-107 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARIUSNUCLEARPOWER PLANT DOCKETNO. 50-400/LICENSE NO. NPF-63 REQUEST FOR APPROVALTO USE ASME CODE CASE N-416-1 Gentlemen:
In accordance with 10 CFR 50.55a(a)(3), Carolina Power &Light (CP&L) Company requests approval for the Harris Nuclear Plant to usc an alternative to the American Society ofMechanical Engineers (ASME) Boiler and Prcssure Vessel Code hydrostatic testing requirements for welded repairs and installation ofreplacement items by welding. The requested alternative is delineated in ASME Code Case N-416-1, "Alternative Pressure Test Requircmcnt forWcldcd Repairs or Installation ofReplacement Items by Welding, Class 1, 2, and 3 Section XI, Division 1,"
which was approved by the ASME committee on February 15, 1994, but has not yet been incorporated into Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI Division 1."
The basis for this rcqucst is provided in the enclosure.
On November 8, 1995, a through-wall leak was identified on a stub offof the service water return linc from Containmcnt Fan Cooler AH-1, located outside containment.
Therefore, in order to allow immediate usc of altematc prcssure test requirements forrepairs being made to thc Code Class 3 service water system line, CP&L requests expedited NRC approval for use ofthis Code Case.
Questions regarding this matter may be rcfcrrcd to Mr. T. D. Walt at (919) 362-2711.
LSR/lsr Enclosure Sincerely, c:
Mr. S. D. Ebneter Mr. N. B. Lc Mr. D. J. Roberts
- r. c r.f' 9512010110 951122 "
'DR ADOCK 05000400
, PDR State Road 1134 New Hill NC Tel 919 362-2502 Fax 919 362-2095
Enclosure to Serial: HNP-95-107 SHEARON HARRIS NUCLEARPOWER PLANT DOCKETNO. 50-400/ LICENSE NO. NPF-63 REQUEST FOR APPROVALTO USE ASME CODE CASE N-416-1 In accordance with 10 CFR 50.55a(a)(3), Carolina Power &Light,(CP&L)Company rcqucsts approval for thc Harris Nuclear Plant to use an alternative to the American Society ofMechanical Engineers (ASME)
Boiler and Prcssure Vessel Code hydrostatic testing requirements for welded repairs and installation of replacement items by welding. Thc requested alternative is delineated in ASME Code Case N-416-1, "Alternative Pressure Test Requirement for for Welded Repairs or Installation ofReplacement Items by Welding, Class I, 2, and 3 Section XI,Division 1," which was approved by thc ASME committcc on February 15, 1994, but has not yet bccn incorporated into Regulatory Guide 1.147, "Inscrvicc Inspection Code Case Acceptability ASME Section XIDivision 1."
The Code Case allows a system leakage test to be performed in lieu ofthe hydrostatic pressure test, as required by IWA-4000 ofthe ASME Code,Section XI,for welded repairs or installation ofreplacement items by welding provided that:
1.
Non-destructive examination (NDE) is performed in accordance with the methods and acccptancc criteria ofthe applicablc Subsection ofthe 1992 Edition ofSection III.
Prior to or immediately upon return to service, a visual examination (VT-2) shall be performed in conjunction with a system leakage test, using thc 1992 Edition ofthc ASME Code Section XI,in accordance with IWA-5000, at nominal operating prcssure and tempcraturc.
3.
Use ofthc Code Case is documcntcd on an NIS-2 Form.
Usc ofthe Code Case willbe subject to thc provision that surface examinations are performed on the root (pass) layer ofbutt and socketed wclds on thc pressure retaining boundary of Class 3 components.
For those Class 3 wclds receiving radiography in lieu ofa surface examination in accordance with Section III,no additional surface examination ofthc root layer needs to be performed.
Thc applicable edition ofSection XIofthe ASME Code for thc Harris Plant, first 10-year inservice inspection (ISI) interval is the 1983 Edition, through and including the Summer 1983 Addenda.
Ifrcquircd hydrostatic testing followingwelded repairs and installation ofrcplaccmcnt items by welding is impractical, it is currently necessary to defer the testing as allowed by Code Case N-416 or to request relief from ASME Code required tests.
Impracticality oftesting may be the result ofvarious situations, ranging from boundary valve isolation problems to incorporation ofsensitive components within thc hydrostatic test boundary.
Since hydrostatic test pressures arc higher than nominal operating prcssurcs, hydrostatic prcssure testing frequently requires significant effort to set-up and perform. The need to use special equipment (e.g.,
temporary attachment oftest pumps and gauges) and thc nccd for individual valve lineups can cause thc testing to become the critical path activity during outages or not be practical during plant operation.
Piping components arc designed for a number ofdiffcrcnt loading conditions that arc postulated to occur under the various modes ofplant operation.
Hydrostatic testing subjects the piping components to a
Enclosure to Serial: HNP-95-107 relatively small increase in prcssure over the design pressure and, therefore, does not present a significant challenge to pressure boundary integrity. Accordingly, it is our understanding that (1) hydrostatic pressure testing is primarily regarded as a means to enhance leakage detection during the examination ofcomponents under pressure, rather than solely as a measure to determine thc structural integrity ofthe components, (2) leaks are not being discovcrcd as a result ofhydrostatic test prcssurcs propagating a precxisting through-wall flaw, and (3) typically, when leaks are identified, they occur at flanges, packing, seals, ctc., whether at hydrostatic test pressure or normal operating prcssure.
In some cases, welded repairs and installation ofreplacement items by welding are unexpcctcd and arc oflen identified only by the performance ofin-service inspections.
In such cases, it is necessary to request ASME Code reliefon an expedited basis to avoid,startup delays or exceeding limitingconditions ofoperation action times, since hydrostatic testing is oflen impractical to perform followingrepair or rcplaccmcnt activities.
ASME Code Case N-416-1 provides incrcascd testing flcxibilityand can considerably reduce or eliminate reliefrequests associated withwcldcd repairs and installation ofreplaccmcnt items by welding. This is accomplished while maintaining an acccptablc level ofquality and safety. The Code Case has already been approved by the NRC for usc by other licensees, inluding thc H. B. Robinson Steam Electric Plant, Unit 2 by NRC letter dated May 11, 1995, and thc Brunswick Stcam Electric Plant, Units 1 and 2 by NRC letter dated November 1, 1995.
NRC approval is requested is in accordance with IOCFR50.55a(a)(3) because, as discussed above (i) the proposed alternative would provide an acccptablc level ofquality and safety since leaks arc not generally discovcrcd as a result ofhydrostatic testing, and (ii)compliance with thc ASME Code Section XI,IWA-4000 requirements would result in hardship and unusual difficulty,primarily resulting from boundary valve isolation problems, without a compensating incrcasc in thc level ofquality and safety. Thcrcforc, in addition to the immediate need for NRC approval, CPkL also considers this request to use ASME Code Case N-416-1 to be a regulatory burden reduction item for thc Harris Nuclear Plant, and requests that the NRC grant approval to usc the alternative provisions ofthe Code Case until it is incorporated into Regulatory Guide 1.147.