SBK-L-08173, Request for Use of a Subsequent Edition and Addenda of the ASME Code
| ML082760468 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/30/2008 |
| From: | St.Pierre G Florida Power & Light Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-08173 | |
| Download: ML082760468 (5) | |
Text
FPL Energy Seabrook Station FPL F"MBMY P.O. Box 300 Seabrook, NH 03874 Seabrook Station (603) 773-7000 September 30, 2008 Docket No. 50-443 SBK-L-08173 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Seabrook Station Request for the Use of a Subsequent Edition and Addenda of the ASME Code Pursuant to 10CFR50.55a(g)(4)(iv), FPL Energy Seabrook, LLC (FPL Energy Seabrook) requests approval to use a subsequent edition and addenda of the American Society of Mechanical Engineers (ASME) Code for non-destructive examination of the Seabrook pressurizer skirt weld.
FPL Energy Seabrook is examining the pressurizer skirt weld, RC E-10-SKIRT, during the upcoming ten-year inservice inspection (ISI) period. Seabrook is required to perform this examination pursuant to 10 CFR 50.55a. The Code of record (ASME Boiler and Pressure Vessel Code Section XI, 1995 Edition, including Addenda through 1996) requires that a surface examination (liquid penetrant (PT) or magnetic particle (MT)) of the skirt weld be performed on both the inside and outside surface of the skirt weld. In, FPL Energy Seabrook proposes to use a later edition of the ASME Code.
This later edition requires that a surface examination be performed on the accessible side of the skirt weld only.
Access to the inside surface of the skirt weld is made difficult due to heater penetrations, structural steel and the surge line. Additionally, this surface is in the as-welded condition which will inhibit performance and evaluation of the examination. The amount of grinding needed to achieve a suitable surface from which an examination could be performed is extensive. The access limitations, extent of grinding and high dose rates in this area would result in an increase in personnel radiation exposure without a compensating increase in the level of quality and safety.
Since 1981, two ASME Code Cases have been issued to address this type of welded attachment. The requirements of the later Code Case were incorporated into the ASME Code via the 1997 Addenda.
Both C6de Cases allowed for an examination of the attachment weld from the accessible side only. The current Code year incorporated by reference in 10 CFR 50.55a(b)(2) is the American Society of Mechanical Engineers an FPL Group company
U. S. Nuclear Regulatory Commission SBK-L-08173 Page 2 (ASME) Boiler and Pressure Vessel Code Section XI, 2001 Edition, including Addenda through 2003.
FPL Energy Seabrook requests review and approval of this proposal to support the Seabrook Unit 1 refueling outage in the fall of 2009.
If you have any questions regarding this submittal, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.
Sincerely, FPL Energy Seabrook, LLC Gene St. Pierre Site Vice President cc:
S. J. Collins, NRC Region I Administrator G. E. Miller, NRC Project Manager W. J. Raymond, NRC Resident Inspector to SBK-L-08173
ATTACHMENT 1 2AR-06, Rev.0 REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(4)(iv) for ISI Item
-USE OF SUBSEQUENT CODE EDITION AND ADDENDA AT SEABROOK UNIT 1-ASME Code Component Affected Code class:
1 System:
RC Examination Categories:
B-K Item No.:
B 10.10, Pressure Vessel, Attachment Welds ISI Component ID:
RC E-10 SKIRT
Applicable Code Edition and Addenda
FPL Energy Seabrook, LLC (FPL Energy Seabrook) is currently in the 2nd 10-year Inservice Inspection (ISI) interval. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) of record for the current 10-year ISI interval isSection XI, 1995 Edition, including Addenda through 1996.
Proposed Subsequent Code Edition and Addenda Pursuant to 10CFR50.55a(g)(4)(iv),
Seabrook proposes to use the Table IWB-2500-1 requirements from the 2001 Edition including Addenda through 2003 of ASME Section XI for the Item No. listed in Section 1.0. This edition the Code is approved for use pursuant to 10CFR50.55a(b)(2).
Related Requirements FPL Energy Seabrook is requesting to use a subsequent edition of the ASME Section XI Code for the examination of category item B-K, Item No. B10.10. In making this request, FPL Energy Seabrook will comply with all related requirements of the 2001 Edition including Addenda through 2003 of the ASME Section XI Code which are listed for reference below.
- 1. Examination
- a. IWA-2300, Qualification of Nondestructive Examination Personnel
- b. IWA-2221, Magnetic Particle Examination, or
- c. IWA-2222, Liquid Penetrant Examination
- 2. Acceptance Standard
- a. IWB-3526, Standards for Examination Category B-K, Welded Attachments for Vessels, Piping, Pumps and Valves
Duration of Proposed Request The approved use of this subsequent Code Edition and Addenda request will be for the duration of up to and including the last outage of the current 2nd 10-year ISI interval.