ML040850540
| ML040850540 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 04/16/2004 |
| From: | John Nakoski NRC/NRR/DLPM/LPD2 |
| To: | Mccollum W Duke Energy Corp |
| Olshan L N, NRR/DLPM, 415-1419 | |
| References | |
| 03-GO-008, TAC MB8998, TAC MB8999, TAC MB9000, TAC MB9001 | |
| Download: ML040850540 (9) | |
Text
April 16, 2004 Mr. William R. McCollum, Jr.
Senior Vice President Duke Energy Company Post Office Box 1006 Charlotte, North Carolina 28201-1006
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 ALTERNATIVE PRESSURE TESTING FOR CLASS 2 PIPING, INSERVICE INSPECTION PROGRAM RELIEF REQUEST NO. 03-GO-008 (TAC NO. MB8998, MB8999, MB9000, AND MB9001)
Dear Mr. McCollum:
By letter to the Nuclear Regulatory Commission (NRC, Commission) dated April 13, 2003, Duke Power Company (the licensee) requested the use of an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, 1995 Edition through the 1996 Addenda for McGuire Nuclear Station (McGuire), Unit 1, (third inspection interval), and the 1989 Edition with no Addenda for Catawba Nuclear Station (Catawba), Units 1 and 2, and McGuire, Unit 2, (second inspection interval). The Relief Request No. 03-GO-008, requests the approval of use, as an alternative, the NRC staff-endorsed 1998 Edition through the 2000 Addenda for piping that penetrates the containment vessel when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of Section XI.
The inservice inspection (ISI) of the ASME Code Class 1, 2, and 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g), except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). As stated, in part, in 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) may be used, when authorized by the Commission, if the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The NRC staff concludes that the alternative to pressure test ASME Class 2 safety related components and piping per the boundary established by the 1998 Edition of ASME Section XI through the 2000 Addenda, in accordance with the requirements of 10 CFR Part 50, Appendix J, provides an acceptable level of quality and safety.
Mr. McCollum, Jr. The enclosed Safety Evaluation contains the NRC staffs evaluation and conclusions. The NRC staff authorizes the proposed alternative under Relief Request No. 03-GO-008, for use at Catawba, Units 1 and 2, and McGuire, Unit 2, second 10-year ISI interval, and McGuire, Unit 1, third 10-year ISI interval, pursuant to 10 CFR 50.55a(a)(3)(i).
Sincerely,
/RA/
John A. Nakoski, Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413, 50-414, 50-369, and 50-370
Enclosure:
As stated cc w/encl: See next page
ML040850540 NRR-028 OFFICE PDII-1/GE PDII-1/ PM PDII-1/LA EMCB OGC-NLO PDII-1/SC NAME ZCruz SPeters CHawes TChan MLemoncelli JNakoski DATE 4/1/04 4/1/04 4/1/04 06/09/03 4/7/04 4/16/04
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE INSPECTION PROGRAM RELIEF REQUEST NO. 03-GO-008 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DUKE POWER COMPANY DOCKET NOS. 50-413, 50-414, 50-369, AND 50-370
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC, Commission) dated April 13, 2003, Duke Power Company (the licensee) requested the use of an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, 1995 Edition through the 1996 Addenda for McGuire Nuclear Station (McGuire), Unit 1, (third inspection interval), and the 1989 Edition with no Addenda for Catawba Nuclear Station (Catawba), Units 1 and 2, and McGuire, Unit 2, (second inspection interval). The Relief Request No. 03-GO-008, requests the approval of use, as an alternative, the NRC staff-endorsed 1998 Edition through the 2000 Addenda for piping that penetrates the containment vessel when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of Section XI.
2.0 REGULATORY EVALUATION
The inservice inspection (ISI) of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Class 1, Class 2, and Class 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.55a(g), except where specific relief has been granted by the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i). The regulation at 10 CFR 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI code of record for Catawba Nuclear Station (Catawba), Units 1 and 2, and McGuire Nuclear Station (McGuire), Unit 2, second 10-year ISI interval is the 1989 Edition of the ASME Code. The ISI code of record for McGuire, Unit 1, third 10-year ISI interval is the 1995 Edition of the ASME Code through the 1996 Addenda.
2.1 Code Requirements for which Relief is Requested The licensee stated that the 1989 Edition through the 1996 Addenda of ASME Section XI, Table IWC-2500-1, requires a system pressure test each inspection period for Class 2 piping that penetrates the containment vessel when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of ASME Section XI.
2.2 Licensees Proposed Alternative Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee stated the alternative is to use the 1998 Edition of ASME Section XI through the 2000 Addenda to define the boundaries for pressure testing Class 2 piping that penetrates the containment vessel when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of ASME Section XI. The affected piping will be examined in accordance with 10 CFR Part 50, Appendix J.
2.3 Licensees Basis for Relief The licensee stated that the current edition of the Code endorsed by the NRC staff is the 1998 Edition through the 2000 Addenda. This edition allows piping that penetrates the containment vessel to be exempt from the period pressure test requirements previously stated when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of ASME Section XI.
The licensee indicated that Regulatory Guide 1.147, Revision 13, will endorse the use of Code Case N-522 without the limitations that were issued in Revision 12. With the limitations removed, the licensee stated the alternative in Code Case N-522 is the same as the boundary exemption in the 1998 Code Edition.
3.0 TECHNICAL EVALUATION
The ISI code of record for Catawba, Units 1 and 2, and McGuire, Unit 2, second 10-year ISI interval is the 1989 Edition of the ASME Code. The inservice inspection code of record for McGuire, Unit 1, third 10-year ISI interval is the 1995 Edition of the ASME Code through the 1996 Addenda.
The 1989 Edition of ASME Section XI, Table IWC-2500-1, Examination Category C-H, note 7, IWC-5222(a) of the 1995 Edition of ASME Section XI, and the 1998 Edition of ASME Section XI state: The pressure retaining boundary includes only those portions of the system required to operate or support the safety function up to and including the first normally closed valve (including a safety or relief valve) or valve capable of automatic closure when the safety function is required. IWC-5222(b) of the 1998 Edition of ASME Section XI states: Items outside the boundaries of IWC-5222(a), and open ended discharge piping, are excluded from the examination requirements.
The regulation at 10 CFR 50.55a(b)(2) endorses the use of the 1977 Edition of ASME Section XI through the 2000 Addenda. No exemptions were listed that pertained to the licensees request for relief. The regulation at 10 CFR 50.55a(g)(4)(iv) authorizes the use of later editions of ASME Section XI and portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
Regulatory Guide 1.147, Revision 12, dated May 1999, endorsed the use of ASME Code Case N-522, Pressure Testing of Containment Penetration Piping,Section XI, Division 1, subject to the following condition in addition to those conditions specified in the Code Case:
The test should be conducted at the peak calculated containment pressure and the test procedure should permit the detection and location of through-wall leakage in containment isolation valves (CIVs) and pipe segment between the CIVs. This Code Case will be endorsed in Revision 13 of the Regulatory Guide without the stated condition imposed.
The referenced Code Case states that 10 CFR Part 50, Appendix J, may be used as an alternative to the rules in Table IWC-2500-1, Code Category C-H, for pressure testing piping that penetrates a containment vessel, when the piping and isolation valves that are part of the containment system are Class 2 but the balance of the piping system is outside the scope of ASME Section XI.
The regulations at 10 CFR Part 50, Appendix J, require that type C tests shall be conducted at the calculated peak containment internal pressure related to the design basis accident and specified either in the technical specification or associated bases. This pressure test shall be performed during each reactor shutdown for refueling but in no case at intervals greater than two years. The licensee stated that testing of the subject piping would be in accordance with 10 CFR Part 50, Appendix J which the NRC staff concludes, will provide an acceptable level of quality and safety, and is, therefore, acceptable.
4.0 CONCLUSION
The NRC staff concludes that the alternative to pressure test ASME Class 2 safety related components and piping per the boundary established by the 1998 Edition of ASME Section XI through the 2000 Addenda, in accordance with the requirements of 10 CFR Part 50, Appendix J, provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the proposed alternative under Relief Request No. 03-GO-008, for use at Catawba, Units 1 and 2, and McGuire, Unit 2, second 10-year ISI interval, and McGuire Nuclear, Unit 1, third 10-year ISI interval. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this Safety Evaluation remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: T. Steingas Dated: April 16, 2004
Catawba Nuclear Station McGuire Nuclear Station cc:
Lee Keller, Manager Regulatory Compliance Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Ms. Lisa F. Vaughn Duke Energy Corporation Mail Code - PB05E 422 South Church Street P.O. Box 1244 Charlotte, North Carolina 28201-1244 Anne Cottingham, Esquire Winston and Strawn 1400 L Street, NW Washington, DC 20005 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P. O. Box 29513 Raleigh, North Carolina 27626 County Manager of York County York County Courthouse York, South Carolina 29745 County Manager of Mecklenburg County 720 East Fourth Street Charlotte, North Carolina 28202 Piedmont Municipal Power Agency 121 Village Drive Greer, South Carolina 29651 Ms. Karen E. Long Assistant Attorney General North Carolina Department of Justice P. O. Box 629 Raleigh, North Carolina 27602 North Carolina Electric Membership Corp.
P. O. Box 27306 Raleigh, North Carolina 27611 Senior Resident Inspector Nuclear Regulatory Commission 4830 Concord Road York, South Carolina 29745 Senior Resident Inspector U. S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntsville, North Carolina 28078 Henry Porter, Assistant Director Division of Waste Management Bureau of Land and Waste Management Dept. of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201-1708 Mr. R. L. Gill, Jr., Manager Nuclear Regulatory Issues and Industry Affairs Duke Energy Corporation 526 South Church Street Mail Stop EC05P Charlotte, North Carolina 28202 Saluda River Electric P. O. Box 929 Laurens, South Carolina 29360 Mr. Peter R. Harden, IV, Vice President Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road 12th Floor Charlotte, North Carolina 28210 NCEM REP Program Manager 4713 Mail Service Center Raleigh, North Carolina 27699-4713
Catawba Nuclear Station McGuire Nuclear Station cc:
Mr. T. Richard Puryear Owners Group (NCEMC)
Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Richard M. Fry, Director Division of Radiation Protection N. C. Dept. of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 Diane Curran Harmon, Curran, Spielberg &
Eisenberg, LLP 1726 M Street, N.W.
Suite 600 Washington, DC 20036 Mary Olson Director of the Southeast Office Nuclear Information and Resource Service 729 Haywood Road, 1-A P. O. Box 7586 Asheville, North Carolina 28802 Mr. C. Jeffrey Thomas Regulatory Compliance Manager Duke Energy Corporation McGuire Nuclear Site 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Dr. John M. Barry Mecklenburg County Department of Environmental Protection 700 N. Tryon Street Charlotte, North Carolina 28202