ML020720034

Request for Authorization to Utilize Wire-Type Image Penetrameters in Accordance with 10 CFR 50.55a(a) (3) (I)

ML020720034
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	02/14/2002
From:	Tuckman M Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
02-GO-001
Download: ML020720034 (7)

Text

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Duke wPower A Duke Energy Company Duke Power 526 South Church St. EC07H Charlotte, NC 28202 P. O. Box 1006 EC07H Charlotte, NC 28201-1006 (704) 382-2200 OFFICE (704) 382-4360 FAX M. S. Tuckman Executive Vice President Nuclear Generation February 14, 2002 U.S. Nuclear Regulatory Commission Washington, D.C.

20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Duke Energy Corporation Oconee Nuclear Station, Units 1, 2,

& 3 Docket Nos. 50-269, 50-270, 50-287 McGuire Nuclear Station, Units 1 & 2 Docket Nos. 50-369, 50-370 Catawba Nuclear Station, Units 1 & 2 Docket Nos.

50-413, 50-414 Request for Authorization to Utilize Wire-Type Image Penetrameters in Accordance with 10 CFR 50.55a(a) (3) (i).

Duke Energy Corporation Serial Number 02-GO-001 Pursuant to 10 CFR 50.55a(a) (3) (i),

Duke Energy Corporation (DEC) is requesting relief from specified inspection requirements to authorize the use of wire-type Image Quality Indicators (IQI's). This relief is requested for

Oconee, McGuire and Catawba Nuclear Stations.

The applicable ASME Boiler and Pressure Vessel Code,Section XI Editions/Intervals are:

1. Oconee Nuclear Station, Units 1, 2, and 3: 1989 Edition, Third Interval

2.

McGuire Nuclear Station, Unit 1: 1995 Edition with 1996 Addenda, Third Interval p479(41

U.S. Nuclear Regulatory Commission February 14, 2002 Page 2

3.

McGuire Nuclear Station, Unit 2: 1989 Edition, Second Interval

4.

Catawba Nuclear Station, Units 1 and 2: 1989 Edition, Second Interval The first application of the requested relief, DEC serial Number 02-GO-001, would be during the Oconee Unit 1 Steam Generator replacement outage in September 2003.

DEC is requesting NRC approval to use wire-type IQI's in addition to plaque-type IQI's for performing radiographic inspections. The current codes of record do not list wire type IQI's for use. DEC has determined that the proposed alternative would provide an acceptable level of quality and safety.

ASME Section III NB and NC (1989 and 1992 Editions) stipulates the use of the IQI's listed in Table NB 1111 1 and NC-5111-1, respectively. ASME Section III NB and NC do not indicate that the use of wire-type IQI's is unacceptable.

The code sections do not include a listing of the wire diameters that will provide equivalent sensitivity for the specified plaque-type IQI and essential hole.

ASME Code Case N-416-1* will be invoked during the Steam Generator replacement outages for all three Oconee units.

The Code Case is approved by Regulatory Guide 1.147, Rev.

12.

ASME Code Case N-416-1 invokes the 1992 Edition, no Addenda, of the ASME Section III Code in the performance of nondestructive examination of piping weldments.

The 1993 Addenda to the 1992 Edition incorporated equivalent wire type IQI's into Tables NB-5111-1 and NC 5-111-1.

The use of wire-type IQI's was previously approved by the NRC for Browns Ferry, Units 2 and 3 (TAC Nos. MA5308 and MA5309) and for Indian Point, Unit 2 (TAC No.

MB0032).

A detailed description of the proposed alternative and justification is included as an attachment to this letter.

"*"Alternate Pressure Test Requirements for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2, and 3,Section XI, Division 1"

U.S. Nuclear Regulatory Commission February 14, 2002 Page 3 DEC is requesting NRC approval of this request by September 2002.

This date will support timely planning and preparation of the Oconee Unit 1 Steam Generator replacement outage in September 2003.

Questions regarding this request may be directed to L.

A.

Hentz at 704-382-8081.

Very truly yours, M.S.

Tuckman Attachment xc w/att: L.

A.

Reyes, Regional Administrator U.

S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85 Atlanta, GA 30303 L.

N. Olshan (Addressee only)

NRC Senior Project Manager (ONS)

U.

S.

Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 R.

E.

Martin (Addressee only)

NRC Senior Project Manager (MNS)

U.

S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 C.

P. Patel (Addressee only)

NRC Senior Project Manager (CNS)

U.

S.

Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 M. C.

Shannon, NRC Senior Resident Inspector(ONS)

D.

J.

Roberts, NRC Senior Resident Inspector(CNS)

S.

M. Shaeffer,NRC Senior Resident Inspector(MNS)

U.S. Nuclear Regulatory Commission February 14, 2002 Page 4 bxc w/att:

M. T. Cash L.

E. Nicholson J.

E. Smith C.

J. Thomas K. L. Crane G. D. Gilbert K. E. Nicholson T. K. Pasour (2)

R. K.

Rhyne T. Wills (WC28H)

R. 0. Sharpe (WC28H)

J. 0. Barbour NRIA File/ELL ONS MasterFile ON03DM MNS Master File MG01DM CNS Master File CN04DM

DUKE ENERGY CORPORATION Oconee Nuclear Stations, Unit 1, 2 & 3 McGuire Nuclear Station, Units 1 & 2 Catawba Nuclear Station, Units 1 & 2 Request For Relief No.

02-GO-001 Request for Alternative use of wire-type Image Quality Indicators (IQI's) in performing radiographic examinations

Applicable Code Edition and Addenda

"* ASME Boiler and Pressure Vessel Code,Section III, 1989 and 1992 Editions, No Addenda

"* ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition, No Addenda and 1995 Edition with 1996 Addenda.

Description of Code Requirement (s) for Which an Alternative is Requested ASME Section III NB and NC (1989 and 1992 Editions) stipulates the use of the IQI's listed in Table NB 1111 1 and NC-5111-1, respectively. ASME Section III NB and NC do not state that the use of wire-type IQI's is unacceptable, it just does not include a listing of the wire diameters that will provide equivalent sensitivity for the specified plaque-type IQI and essential hole.

The Oconee steam generator replacement outages for Units 1, 2,

and 3 will invoke Code Case N-416-1, "Alternate Pressure Test Requirements for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2, and 3,Section XI, Division 1." ASME Code Case N-416-1 invokes the 1992 Edition, no Addenda, of the ASME Section III Code in the performance of nondestructive examination of piping weldments. The 1993 Addenda to the 1992 Edition incorporated equivalent wire type IQI's into Tables NB 5111-1 and NC 5-111-1.

Duke Energy Corporation Page 1 of 3 Request For Relief Serial No. 02-GO-001

Description of Proposed Alternative DEC is requesting NRC approval to use wire-type penetrameters in addition to plaque-type IQI's for performing radiographic examinations. The current code of record does not list wire-type IQI's for use. DEC has determined that the proposed alternative would provide an acceptable level of quality and safety.

Justification for Using the Proposed Alternative DEC considers that plaque-type IQI's are in some cases impractical for use due to physical placement and radiographic characteristics. Placement of flat plaque-type IQI's on curved surfaces of pipe components normally require shimming. When using Plaque-type IQI's, the recorded radiographic characteristics of the essential T hole is often obscured or distorted due to specimen anomalies or part geometry. These difficulties create re shoot conditions. Re-shoots have a negative ALARA impact due to the additional personnel radiation exposure.

Wire-type IQIs have been shown to provide quality and sensitivity equivalent to plaque-type IQI's as documented in Table 4 of ASTM E747-87. Equivalent sensitivity has also been demonstrated in ASME Section V, Article 22,SE-747 and in ASME Section III, 1995 Edition, tables NB and NC 5111-1.

Because of the equivalent sensitivity, the proposed alternative provides equivalent or superior results to current exam method utilizing only plaque-type IQI's.

Therefore, the quality of the examination and resulting safety of the plant, based on the exam results are not impacted by this proposed alternative.

The intent of this request for relief is to apply the sensitivity level specified in Tables NB-5111-1 and NC 5111-1 to the selection of the appropriate wire diameter or plaque-type IQI size as provided for in ASME Section III, 1995 Edition, No Addenda.

The Quality and Safety Provided by the Proposed Alternative Information provided above supports the proposed use of wire-type IQIs and provides an acceptable level of quality Duke Energy Corporation Page 2 of 3 Request For Relief Serial No. 02-GO-001

and safety. The use of only plaque-type IQI's may result in unusual difficulty and additional personnel radiation exposure with no benefit of quality and safety.

Originated By:

Reviewed By:

RT Level III

Manager, QATS Date Date Duke Energy Corporation Page 3 of 3 Request For Relief Serial No. 02-GO-00I