ML072360293
| ML072360293 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/22/2007 |
| From: | Spina J Constellation Energy Group, Constellation Generation Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML072360293 (12) | |
Text
James A. Spina Vice President 0
Constellation Energy Generation Group Calvert Cliffs Nuclear Power Plant, Inc.
1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495.3500 Fax August 22, 2007 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
Document Control Desk'ý Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Third Ten-Year Inservice Inspection Interval Requests for Relief from ASME Section XI Reauirements
REFERENCE:
(a)
Letter from C. H. Cruse (BGE) to Document Control Desk (NRC), dated June 1, 1999, Submittal of Third Ten-Year Interval Inservice Inspection Program Plan In Reference (a), Calvert Cliffs Nuclear Power Plant submitted the Third Ten-Year Interval Inservice Inspection Program Plan.
Requests for alternatives and relief related to the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code),Section XI requirements were embedded within this Plan; however, timely Nuclear Regulatory Commission (NRC) approvals were not obtained.
A number of the requested reliefs and alternatives were subsequently approved via routine regulatory processes (i.e., Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division I) during the Third Ten-Year Interval (see Attachment 1).
Two relief requests remain unapproved and are presented herein (see Attachment 2). Written NRC approval of the remaining relief requests is requested prior to the conclusion of the Interval on June 30, 2009.
Should you have questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219.
Very truly yours, JAS/MJY/bjd Attachments:
(1)
(2)
Request for Alternatives and Relipf Request Index Revised Third Ten-Year Interval Inservice Inspection Program Plan Relief Requests cc:
D. V. Pickett, NRC S. J. Collins, NRC Resident Inspector, NRC R. I. McLean, DNR Safety Program Manager, State of Maryland PM0
ATTACHMENT (1)
REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX Calvert Cliffs Nuclear Power Plant, Inc.
August 22, 2007
ATTACHMENT (1)
REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX Section 5.0 of the Third Ten-Year Interval Inservice Inspection Program (Program), as revised on April 24, 2007, contains the following summary listing and revision status of all Requests for Alternatives and Relief Requests related to the Program at Calvert Cliffs Nuclear Power Plant, Units 1 and 2. The unapproved Requests for Alternatives and Relief Requests are contained in Section 6.0 of the Program and are provided as Attachment (2) of this letter.
Some of these requests were originally submitted with the Program to the Nuclear Regulatory Commission (NRC) on June 1, 1999. However, review and approval for use of these relief requests was not specifically requested as part of the submittal of the Third Ten-Year Interval Inservice Inspection Program Plan.
Since the original submittal, many of the relief requests in Table 5.1 have been incorporated into later revisions of Regulatory Guide 1.147 as Code Cases, absorbed into the RI - ISI program scope, or are no longer required due to component replacements.
Therefore all of the relief requests in Table 5.1 that have been incorporated into Regulatory Guide 1.147, absorbed into the RI-ISI program scope, or are no longer applicable, due to component replacements may be withdrawn. Those relief requests remain listed for tracking and historical purposes and are annotated as "WITHDRAWN".
TABLE 5.1 INSERVICE INSPECTION REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX NRC REQUEST NO.
APPROVAL PAGES REV.
DATE TOPIC STATUS WITHDRAWN N/A 6-2 to 6-5 N/A N/A Withdrawn during the ISI-01 Third Interval as part of RI-ISI application.
Approved as RR-RI-ISI-2.
WITHDRAWN N/A 6-6 to 6-8 0
7/1/99 Alternative Surface ISI-02 Examination Criteria for Control Rod Drive Housing Welds.
Withdrawn during the Third Interval as a result of the replacement of both Unit I and Unit 2 reactor pressure vessel closure heads.
WITHDRAWN N/A 6-9 to 6-10 0
N-307-3 incorporated into ISI-03 RG 1.147 Revision 14.
Alternative Examination Criteria for Reactor Vessel Closure Studs and Reactor Coolant Pump Studs.
ATTACHMENT (1)
REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX TABLE 5.1 INSERVICE INSPECTION REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX NRC REQUEST NO.
APPROVAL PAGES REV.
DATE TOPIC STATUS WITHDRAWN N/A 6-11 to 6-14 0
7/1/99 N-416-1 incorporated into ISI-04 RG 1.147 Revision 12 Alternative Pressure Test Requirement for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2 and 3.
WITHDRAWN N/A 6-15 to 6-17 0
7/1/99 N-498-3 incorporated into ISI-05 RG 1.147 Revision 14.
Alternative Rules for 10-Year System Hydrostatic Testing for Class 3 Systems.
WITHDRAWN N/A 6-18 to 6-20 0
7/1/99 N-532-1 incorporated into ISI-06 RG 1.147 Revision 14 Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report.
WITHDRAWN N/A 6-21 to 6-23 0
7/1/99 N-533-1 incorporated into ISI-07 RG 1.147 Revision 14.
Alternative Requirements for Insulation Removal During Class 1, 2, or 3 Pressure Tests at Bolted Connections in Systems.
Borated for the Purpose of Controlling Reactivity.
ISI-08 Not 6-24 to 6-25 0
7/1/99 Use of ASME Section II, Approved as V, and IX Code Cases.
of 3/1/2007 WITHDRAWN N/A 6-26 to 6-27 0
7/1/99 N-566-2 incorporated into ISI-09 RG 1.147 Revision 14.
Alternative Corrective Actions for Leakage Identified at Bolted Connections.
2
ATTACHMENT (1)
REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX TABLE 5.1 INSERVICE INSPECTION REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX NRC REQUEST NO.
APPROVAL PAGES REV.
DATE TOPIC STATUS WITHDRAWN N/A 6-28 0
7/1/99 N592 incorporated into ISI-10 RG 1.147 Revision 14.
Use of ASNT Central Certification Program.
WITHDRAWN N/A 6-29 to 6-33 0
7/1/99 N-616 incorporated into ISI-I 1 RG 1.147 Revision 14.
Alternative Requirements for Insulation Removal During Class 1, 2, or 3 Pressure Tests at Corrosion Resistant Bolted Connections in Systems Borated for the Purpose of Controlling Reactivity.
WITHDRAWN N/A 6-34 to 6-37 0
N/A Withdrawn during the ISI-12 Third Interval as part of RI-ISI application.
Approved as RR-RI-ISI-2.
WITHDRAWN N/A 6-38 to 6-40 0
N/A Withdrawn during the ISI-13 Third Interval as part of RI-ISI application.
Approved as RR-RI-ISI-2.
ISI-14 Not 6-41 to 6-44 0
7/1/99 Alternative Pressure Approved as Testing Requirements for of 3/1/2007 RPV Flange Leak Detector Piping WITHDRAWN N/A N/A 0
N/A Code Case N-623 ISI-15 incorporated into RG 1.147 Revision 14.
ISI-16 APPROVED N/A 0
N/A Request to Enter Third June 21, 1999 Interval using the 1983 Edition of ASME Section XI.
ISI-17 APPROVED N/A 0
N/A Deferral of Completion March 21, percentages.
2001 3
ATTACHMENT (1)
REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX TABLE 5.1 INSERVICE INSPECTION REQUEST FOR ALTERNATIVES AND RELIEF REQUEST INDEX NRC REQUEST NO.
APPROVAL PAGES REV.
DATE TOPIC STATUS ISI-18 APPROVED N/A 0
N/A Approval to use the 1998 April 5, 2000 Edition of ASME Section XI.
ISI-19 APPROVED N/A 0
N/A Replacement Steam March 6, Generator Girth Welds.
2003 RR-RI-ISI-1 APPROVED 6-45 to 6-47 0
10/27/00 Relief from Period March 21, Percentage Requirements 2001 for Class 1 and 2 Piping Weld Examinati6ns.
RR-RI-ISI-2 APPROVED 6-48 to 6-50 0
11/12/02 Relief to Implement a April 16, RI-ISI Program Based on 2003 Code Case N-578.
4
ATTACHMENT (2)
REVISED THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUESTS Calvert Cliffs Nuclear Power Plant, Inc.
August 22, 2007
ATTACHMENT (2)
REVISED THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUESTS REQUEST NUMBER: ISI-08 (Page 1 of 1)
COMPONENT IDENTIFICATION Code Classes:
1, 2, and 3
References:
IWA-2440 Code Case N-555 Examination Categories:
Not Applicable Item Numbers:
Not Applicable
==
Description:==
Use of ASME Section II, V, and IX Code Cases Component Numbers:
All Class 1, 2, and 3 Components Subject to Inservice Inspection, Inservice Testing, or Repair/Replacement Activities CODE REQUIREMENT Section XI does not allow generic use of Section II, V, and IX Code Cases.
ASME Section XI, IWA-2440 establishes the criteria for the application of code cases.
ASME Section XI, IWA-2443 states that the rules for application of code cases from Code Sections other than Section XI are in the course of preparation.
BASIS FOR ALTERNATIVE Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested on the basis that the proposed alternatives provide an acceptable level of quality and safety.
ASME,Section XI, has prepared the rules for application of code cases from other Code Sections. These rules appear in Code Case N-555, but have not been incorporated into ASME Section XI.
Section XI has evaluated the code cases of ASME Sections I, V, and IX and determined that if they were
- used in the construction of a component, then. they are appropriate for use during repair/replacement activities on that component. In addition,Section XI has evaluated additional code cases for use during Section XI activities, and hasdetermined that several are suitable for use because they provide an acceptable level of safety. Code Case N-555 lists the specific code cases that may be used for inservice inspection, inservice testing, or repair/replacement activities in accordance with Section XI.
PROPOSED ALTERNATIVE ASME Section II, V, and IX code cases that were used in the construction of a component may be used at CCNPP, Units I and 2, for repair/replacement activities on that component.
Also, the code cases specified in Code Case N-555 may be used at CCNPP, Units I and 2, for inservice inspection, inservice testing, or repair/replacement activities in accordance with Section XI. If a specific code case is going to be applied, CCNPP will inform the regulatory authorities having jurisdiction at the site of their intention.
APPLICABLE TIME PERIOD Application of the alternative criteria is requested for the third interval of the Inservice Inspection Program at the Calvert Cliffs Nuclear Power Plant, Units I and 2, which began on July 1, 1999.
I
ATTACHMENT (2),
REVISED THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUESTS REQUEST NUMBER: ISI-14 (Page I of 4)
COMPONENT IDENTIFICATION Code Class:
2
References:
IWC-2500, Table IWC-2500-1 Examination Category:
C-H Item Number:
C7TIO
==
Description:==
Alternative Pressure Testing Requirements for RPV Flange Leak Detector Piping Component Numbers:
Lines CC-9-1009 and CC-9-2002 CODE REQUIREMENT ASME Section XI, Table IWC-2500-1, Examination Category C-H, Code Item No. C7.10 requires the performance of a system leakage test each inspection period on Class, 2 piping up to the first normally closed valve, or valve capable of automatic closure.
BASIS FOR ALTERNATIVE Pursuant to 10*CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with Section XI requirements would result in hardship without a compensating increase in the levels of quality and safety.
The Reactor Vessel Head Flange Leak Detector Piping is separated from the reactor pressure boundary by one passive membrane, which is an 0-ring located on the vessel flange. A second 0-ring is located on the opposite side of the tap in the vessel flange (see Figures ISI-14-1 and ISI-14-2). This piping is required during plant operation in order to indicate failure of the inner flange seal 0-ring. Failure of the 0-ring would result in the annunciation of a High Level Alarm in the Control Room. Failure of the inner 0-ring is the only condition under which this piping is pressurized.
The configuration of this piping precludes system testing while the vessel head is removed because the odd configuration of the vessel tap (see Figure ISI-14-2) coupled with the high test pressure requirement prevents the tap in the flange from being temporarily plugged or connected to other piping. The opening in the flange is only 3/16 of an inch in diameter and is smooth walled, making the effectiveness of a temporary seal very limited. Failure of this seal could possibly cause ejection of the device used for plugging or connecting to the vessel.
The configuration also precludes pressure testing with the vessel head installed because the seal prevents complete filling of the piping, which has no vent available. Additionally, a pneumatic test performed with the head installed is precluded due to the configuration of the top head. The top head of the vessel contains two grooves that hold the 0-rings. The 0-rings are held in place by a series of retainer clips that are housed in recessed cavities in the flange face. If a pressure test was performed with the head on, the inner 0-ring would be pressurized in a direction opposite to what it would see in normal operation. This test pressure would result in a net inward force on the inner 0-ring that would tend to push it into the recessed cavities that house the retainer clips. The thin 0-ring material would very likely be damaged by this inward force.
2
ATTACHMENT (2)
REVISED THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUESTS REOUEST NUMBER: ISI-14 (Page 2 of 4)
In addition to the problems associated with the O-ring design that preclude this testing, it is also questionable whether a pneumatic test is' appropriate for this piping. The use of a pneumatic test performed at RPV nominal operating pressure would represent an unnecessary safety risk to personnel in the unlikely event of a test failure, due to the large amount of stored energy contained in pressurized air.
Operational testing of this piping is precluded because it will only be pressurized. in the event of a failure of the inner O-ring. It is extremely impractical to purposely fail the inner O-ring in order to perform a test.
Based on the above, CCNPP, Units I and 2, requests the following alternative examination be performed on the Reactor Vessel Head Flange Leak Detector Piping.
PROPOSED ALTERNATIVE EXAMINATION A VT-2 visual examination will be performed on the Reactor Vessel Head Flange Leak Detector Piping during flood-up of refueling pool during a refueling outage. The hydrostatic head developed due to the water above the vessel flange during flood-up will allow for the detection of any gross indications in the piping.
This examination will be performed with the frequency specified by Table IWC-2500-1 for an IWC-5220 test (once each inspection period).
APPLICABLE TIME PERIOD Application of the alternative criteria is requested for the third interval of the Inservice Inspection Program at the Calvert Cliffs Nuclear Power Plant, Units I and 2, which began on July 1, 1999.
3
ATTACHMENT (2)
REVISED THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUESTS REQUEST NUMBER: ISI-14 (Page 3 of 4)
FIGURE ISI-14-1 REACTOR PRESSURE VESSEL HEAD FLANGE LEAK DETECTOR PIPING See Figure ISI-14-2 For Details 4
IL ATTACHMENT (2)
REVISED THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN RELIEF REQUESTS REQUEST NUMBER: ISI-14 (Page 4 of 4)
FIGURE ISI-14-2 REACTOR PRESSURE VESSEL HEAD FLANGE AND LEAK DETECTOR LINE DETAILS High Pressure Leak Detection Monitoring Top Inner Flange Seal Ring See Detail "A" Detail "A" Vessel Flange Sectional View 5