ML12227A439
| ML12227A439 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/07/2012 |
| From: | - No Known Affiliation |
| To: | Division of Operating Reactor Licensing |
| References | |
| Download: ML12227A439 (15) | |
Text
WBN2Public Resource From: Boyd, Desiree L [dlboyd@tva.gov]
Sent: Tuesday, August 07, 2012 1:18 PM To: Epperson, Dan; Wilson, George; Poole, Justin Cc: Arent, Gordon; Hamill, Carol L; Boyd, Desiree L
Subject:
TVA letter to NRC_08-07-2012_WBN U2 Code Cases N-520-4 & N-520-5 Attachments: 08-07-2012_WBN U2 Code Cases N-520-4 & N-520-5_Final.pdf Please see attached TVA letter that was sent to the NRC today.
Thank You,
~*~*~*~*~*~*~*~*~*~*~
Désireé L. Boyd WBN Unit 2 Licensing dlboyd@tva.gov 423-365-8764 1
Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 725 Mail Envelope Properties (7AB41F650F76BD44B5BCAB7C0CCABFAF30A18583)
Subject:
TVA letter to NRC_08-07-2012_WBN U2 Code Cases N-520-4 & N-520-5 Sent Date: 8/7/2012 1:17:43 PM Received Date: 8/7/2012 1:17:48 PM From: Boyd, Desiree L Created By: dlboyd@tva.gov Recipients:
"Arent, Gordon" <garent@tva.gov>
Tracking Status: None "Hamill, Carol L" <clhamill@tva.gov>
Tracking Status: None "Boyd, Desiree L" <dlboyd@tva.gov>
Tracking Status: None "Epperson, Dan" <Dan.Epperson@nrc.gov>
Tracking Status: None "Wilson, George" <George.Wilson@nrc.gov>
Tracking Status: None "Poole, Justin" <Justin.Poole@nrc.gov>
Tracking Status: None Post Office: TVANUCXVS2.main.tva.gov Files Size Date & Time MESSAGE 264 8/7/2012 1:17:48 PM 08-07-2012_WBN U2 Code Cases N-520-4 & N-520-5_Final.pdf 197868 Options Priority: Standard Return Notification: No Reply Requested: Yes Sensitivity: Normal Expiration Date:
Recipients Received:
Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 August 7, 2012 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391
Subject:
WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - REQUEST TO USE AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) BOILER AND PRESSURE VESSEL CODE, CODE CASES N-520-4 and N-520-5, ALTERNATIVE RULES FOR RENEWAL OF ACTIVE OR EXPIRED N-TYPE CERTIFICATES FOR PLANTS NOT IN ACTIVE CONSTRUCTION, SECTION III, DIVISION 1
References:
Unit 2 - Request to Use American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Code Case N-520-2, Alternative Rules for Renewal of Active or Expired N-Type Certificates for Plants Not in Active Construction,Section III, Division 1 (TAC No. MD8314)
- 2. NRC letter dated May 22, 2008, Watts Bar Nuclear Plant, Unit 2 -
Request for Additional Information Regarding Renewal of Active or Expired N-Type Certificates for Plants Not in Active Construction (TAC No. MD8314)
Request to Use American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code, Code Case N-520-2, Alternative Rules for Renewal of Active or Expired N-Type Certificates for Plants Not in Active Construction,Section III, Division 1 - Response to Request for Additional Information (TAC No. MD8314)
- 4. NRC letter dated October 2, 2008, Watts Bar Nuclear Plant, Unit 2 -
Request for Relief Regarding Alternative Rules for Renewal of Active or Expired N-Type Certificates (TAC No. MD8314)
U.S. Nuclear Regulatory Commission Page 2 August 7, 2012
Unit 2 - Request to Use American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Code Case N-520-3, Alternative Rules for Renewal of Active or Expired N-Type Certificates for Plants Not in Active Construction,Section III, Division 1 - (TAC No.
MD8314)
- 6. NRC letter dated September 29, 2010, Watts Bar Nuclear Plant, Unit 2
- Request for Relief Regarding Alternative Rules for Renewal of Active or Expired N-Type Certificates (TAC No. MD8314)
Pursuant to 10 CFR 50.55a(a)(3)(i), TVA requests approval for the use of the provisions of approved ASME Code Cases N-520-4 and N-520-5, Alternative Rules for Renewal of Active or Expired N-type Certificates for Plants Not in Active Construction,Section III, Division 1. The attached Code Case N-520-5 (which includes the changes from Code Case N-520-4) is an advance copy from ASME and will be issued in Supplement 10 to the 2010 ASME Edition Code Cases. These Code Cases will be applied for specific use as part of the construction activities associated with the ASME Section III Division 1 systems and components in WBN Unit 2.
Following original construction of WBN Unit 2, TVA allowed their ASME N-Type Certificates to expire. Code Case N-520 provides a process whereby expired Certificate Holders can obtain a temporary Certificate for the purpose of transferring the responsibility for completing a plant to a new Certificate Holder. The holder of the new temporary Certificate is referred to as either the temporary Certificate Holder or expired Certificate Holder. The ASME activities such as procurement and fabrication were performed during original construction under the N-Type Certificates which were active at that time. No new ASME Code work is being performed under the N-520 temporary Certificates.
The NRC staff authorized, pursuant to 10 CFR 50.55a(a)(3)(i), a temporary Certificate of Authorization to TVA for use of the alternatives in Code Case N-520-3 to conduct the transfer of N-type certificates at WBN Unit 2 (References 1 through 6). The use of this Code Case was authorized until such time as the Code Case is published in a future version of Regulatory Guide (RG) 1.84 and incorporated by reference in 10 CFR 50.55a(b). As a condition, TVA must comply with the duration and terms of the temporary certificates and for renewals as delineated in the Code Case.
Code Case N-520-2 authorized a single one-year extension of the temporary Certificate of Authorization. Code Case N-520-3 authorized two one-year extensions of the temporary Certificate of Authorization. Code Case N-520-4 is an administrative revision approved by ASME to separate and clarify the requirements for active Certificate Holders versus expired Certificate Holders. This revision added headings, repeated a requirement for active Certificate Holders, and renumbered the paragraphs for expired Certificate Holders.
Since there was no change to the requirements for expired Certificate Holders (which is the process for WBN Unit 2), TVA has not previously submitted a Relief Request for N-520-4 for WBN Unit 2.
U.S. Nuclear Regulatory Commission Page 4 August 7, 2012 cc (Enclosures):
U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381
U.S. Nuclear Regulatory Commission Page 5 August 07, 2012 bcc (Enclosures):
George Wilson U.S. Nuclear Regulatory Commission MS 8 B1A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Fred Brown, Deputy Regional Administrator for Construction U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257
ENCLOSURE 1 WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - REQUEST FOR RELIEF TO USE AMERICAN SOCIETY OF MECHANICAL ENGINEERS (ASME) BOILER AND PRESSURE VESSEL CODE, CODE CASES N-520-4 AND N-520-5, ALTERNATIVE RULES FOR RENEWAL OF ACTIVE OR EXPIRED N-TYPE CERTIFICATES FOR PLANTS NOT IN ACTIVE CONSTRUCTION, SECTION III, DIVISION 1 Executive Summary:
Pursuant to 10 CFR 50.55a(a)(3)(i), TVA is requesting approval to use the provisions of ASME Code Cases N-520-4 and N-520-5, Alternative Rules for Renewal of Active or Expired N-type Certificates for Plants Not in Active Construction,Section III, Division 1. In July 2012, Code Case N-520-5 was approved by ASME. The attached Code Case N-520-5 (which includes the changes from previous ASME approved Code Case N-520-4) is an advance copy from ASME and will be issued in Supplement 10 to the 2010 ASME Edition Code Cases. These Code Cases will be applied for specific use as part of the construction activities associated with the completion of ASME Section III systems and components in WBN Unit 2.
Following original construction of WBN Unit 2, TVA allowed their ASME N-Type Certificates to expire. Code Case N-520 provides a process whereby expired Certificate Holders can obtain a temporary Certificate for the purpose of transferring the responsibility for completing a plant to a new Certificate Holder. The holder of the new temporary Certificate is referred to as either the temporary Certificate Holder or expired Certificate Holder. The ASME activities such as procurement and fabrication were performed during original construction under the N-Type Certificates which were active at that time. No new ASME Code work is being performed under the N-520 temporary Certificates.
Code Case N-520-4 is an administrative change which separates the requirements for active Certificate Holders versus expired Certificate Holders. This Code Case revision did not affect the technical requirements for expired Certificate Holders such as WBN Unit 2 but did affect the overall format (i.e., paragraph numbering) of the sections for expired Certificate Holders. Since Code Case N-520-4 is administrative in nature only and does not affect the technical requirements applicable to WBN Unit 2, no further justification will be provided.
Code Case N-520-5 provides explicit authorization for a process for partially installed material and supporting documentation to be transferred from the expired Certificate Holder to the new Certificate Holder. This Code Case revision was developed since it was not clear whether Code Case N-520-3 addressed transfer of partially installed material and supporting documentation to a new Certificate Holder. The process will be used for instrument and sample line materials that were procured and partially installed but not welded by TVA, the Owner and expired/temporary Certificate Holder. The incorporation of Code Case N-520-5 will allow TVA to document partial installation of materials and a new Certificate Holder to complete the installation.
I. Systems and Components Affected This request will be applicable to the WBN Unit 2 safety-related systems and components required to be designed, fabricated, and constructed in compliance with the rules of the ASME Boiler and Pressure Vessel Code,Section III.
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Specifically, Code Case N-520-5 addresses ASME Section III Division 1 Code material (e.g.,
pipe, elbows, tees, etc.) that were purchased by the expired Certificate Holder and partially installed. The materials may have been cut, bent, dry fit, partially welded, and supported using engineering details and procedures.
II. Applicable ASME Code Edition and Addenda WBN Unit 2 ASME piping systems and components were designed and constructed to meet the 1971 Edition with addenda through the Summer 1973 Addenda (1971S73) of Section III Division 1, as the construction Code-of-Record. TVAs ASME Section III Division 1 Quality Assurance Manual, in effect at the time Unit 2 construction activities were suspended, was written to meet the administrative, documentation, and quality control program aspects delineated in the 1980 Edition through the Winter 1981 Addenda (1980W81). TVAs program, processes, and procedures to document the partially completed piping systems presently reflect these requirements including Code Case N-520-3.
Code Case N-520-3, Alternative Rules for Renewal of N-type Certificates for Plants Not in Active Construction,Section III, Division 1, and Non-mandatory Appendix Z to ASME Section III were adopted to allow TVA to renew a temporary Certificate of Authorization from ASME to complete and transfer documentation of the partially completed ASME Section III systems and components, to the jurisdiction of a subcontractor who will be an ASME Section III N Certificate Holder. This will allow the subcontractor to complete the construction of the WBN Unit 2 systems and complete the associated N-5 Code Data Reports to certify that the systems were constructed in accordance with ASME Section III, and will further allow TVA to document completion of Unit 2 as part of the OwnersSection III required responsibilities at the time that construction is finished.
TVAs program, processes, and procedures to document the partially completed piping systems, transfer jurisdiction to an N Certificate Holder with overall responsibility to complete construction and N-5 Code Data Reports, and document completion of WBN Unit 2 construction activities presently reflect these requirements.
III. Code Requirement At the time of the suspension of construction activities at WBN Unit 2, TVA was the N, NA, and NPT Certificate Holder for the unit. In addition, there were no clear directions in ASME Section III Division 1 regarding transfer of jurisdiction for Code activities from the expired Certificate Holder of an incomplete unit to a new Certificate Holder. The wording in ASME Section III Division 1 required these activities to be administered and controlled by N-type Certificate Holders. Apart from the earlier editions and addenda, it was recognized that circumstances may occur where construction was interrupted prior to the completion of all Code assigned responsibilities, then resumed under a different N-type Certificate Holder. To address this possibility, the ASME Section III Division 1 Committee created Code Case N-520, Alternative Rules for Renewal of N-type Certificates for Plants Not in Active Construction,Section III, Division 1. Later, the non-mandatory Appendix Z to ASME Section III was also created to incorporate the provision of the Code Case. ASME Code Case N-520 was created, approved, and published effective December 9, 1993.
Revision 1 to N-520 was approved and published effective October 24, 1994. Appendix Z was created and approved as part of the 2004 Edition of Section III, which was published in July 1, 2004. Revision 2 to N-520 was approved and published by Supplement 4 to the 2007 E1-2
ASME Edition of Section III Code Cases effective November 1, 2007. Revision 3 to Code Case N-520 was approved by Supplement 11 to the 2007 ASME Edition of Section III Code Cases effective November 11, 2009. Code Case N-520-4 was approved previously by ASME but has not previously been published in a Supplement to the ASME Code Cases.
Since resuming WBN Unit 2 construction completion under Code Cases N-520-2 and N-520-3, TVA has prepared the expired/temporary Certificate Holder partial N-5 Code Data Reports for the new Certificate Holder. However, small bore instrument and sample line materials that were partially installed by TVA were excluded from these Data Reports. These materials are traceable to Certified Material Test Reports and procurement documentation and were partially installed per plant design documents. However, since an N-520 expired Certificate Holder is not permitted to supply material, and the materials in question were excluded from partial N-5 Code Data Reports due to lack of welding documentation, the question arose if completion of installation using these materials was acceptable under Code Case N-520-3.
In response to a request for interpretation of Code Case N-520-3 by TVA, the ASME Section III Committee created the ASME Section Code Case N-520-5, Alternative Rules for Renewal of Active or Expired N-type Certificates for Plants Not in Active Construction,Section III, Division 1. The attached Code Case N-520-5 (which includes the changes from Code Case N-520-4) is an advance copy from ASME and will be issued in Supplement 10 to the 2010 ASME Edition Code Cases.
IV. Reason for Request TVA notified the NRC (Reference 1) of the intent to resume construction activities on WBN Unit 2 in 2007.
With the resumption of construction activities, TVA needed a means to transfer the partially completed ASME Section III piping systems and components, and the associated documentation, to the new Certificate Holder contracted to complete Unit 2. In this manner, the work previously performed under TVAs Certificates of Authorization could be credited toward the final completion of the units ASME Section III systems and components. This process is being controlled under the guidelines of Code Case N-520. Code Case revision N-520-5 was developed since it was not clear whether Code Case N-520-3 addressed transfer of partially installed material and supporting documentation to a new Certificate Holder. Code Case N-520-5 provides rules for the expired Certificate Holder to document procurement and partial installation of materials (welding not completed) and then transfer ownership of the material to the new Certificate Holder to complete installation of these materials at WBN Unit 2 under their ASME Section III, Division 1 program.
V. Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(a)(3)(i), TVA is requesting approval for the use of the provisions of ASME Code Case N-520-5, Alternative Rules for Renewal of Active or Expired N-type Certificates for Plants Not in Active Construction,Section III, Division 1, on the basis that this alternative will provide an acceptable level of quality and safety for the required quality processes of the construction of WBN Unit 2 to the rules and requirements of ASME Section III Division 1.
Code Case N-520 addresses the completion by a new Certificate Holder of ASME activities initiated by an expired Certificate Holder. The expired Certificate Holder is only allowed to E1-3
document and status ASME work performed under the original Certificates. The expired Certificate Holder is not allowed to perform new ASME Code work (i.e., procurement, design or construction) under the temporary N-520 Certificate.
In most cases, the completion of WBN Unit 2 involves the new Certificate Holder removing or repairing welds, materials, components, and appurtenances and installing new ASME Section III Division 1 welds, materials, components, and appurtenances which were procured and designed by the new Certificate Holder. Some ASME Section III Division 1 Code materials (e.g., pipe, elbows, tees, etc.) were purchased by the expired Certificate Holder and partially installed. The materials may have been cut, bent, dry fit, partially welded, and supported using engineering details and procedures. Code Case N-520-5 provides explicit authorization for a process for partially installed material and supporting documentation to be transferred from the expired Certificate Holder to the new Certificate Holder. The process will be used for instrument and sample line materials that were partially installed (i.e., cut, bent, dry fit, partially welded, and supported) but not welded into place. The partially installed material was stored in place in its intended final location and configuration. Code Case N-520-5 provides the process whereby the partially installed material and associated traceability documentation is transferred to the new Certificate Holder so that installation of the material can be completed by the new Certificate Holder. Documenting previously performed ASME Section III Division 1 work does not represent new ASME activities and is thus allowed under the provisions of Code Case N-520. The partial installation performed under the original Certificates represents storage in-place of previously supplied ASME material. This material will be made available for future use and installation by an authorized Certificate Holder.
The process described herein can only be applied for material which has fully traceable and appropriate ASME Section III Division 1 documentation (e.g., Certified Material Test Reports) and which was obtained and controlled under TVAs original Certificates. TVA will not be supplying new material or performing new ASME Section III Division 1 work under this process.
The Certificate Holder which completes the installation will ensure the physical condition of the material is acceptable for use in an ASME Section III Division 1 application through evaluation or remediation. If the material is not acceptable, the material will be replaced.
The process will be documented in the expired/temporary Certificate Holders N-520 ASME Quality Assurance manual and associated procedures as well as the new Certificate Holders ASME Section III Division 1 Quality Assurance manual and associated procedures. Both Quality Assurance manuals require approval by the Authorized Nuclear Inspection Supervisor.
The NRC Staff has not yet reviewed this revised Code Case nor approved its generic use by the industry through the usual process of incorporation into regulatory guides (RGs) (e.g., RG-1.84 or RG-1.147) and incorporation into the 10 CFR 50.55a rule paragraphs.
Code Case N-520-5, like N-520-3, imposes conditions on the Owner to ensure that conveyance of documentation and associated Code items, from the organization with the expired Certificates of Authorization to the new N-type Certificate Holder, is performed in a quality manner. The following attributes were added to the provisions of the Code Case via N-520-5 to ensure that the process conforms to ASME code requirements:
2.(b) The responsibility for material and supporting documentation procured to the original Construction Code, during initial construction, may be transferred to the new Certificate Holder, provided the following requirements are met:
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(1) The material is only for use to complete the construction of items originally included as part of expired Certificate Holders scope.
(2) The material is identified and traceable to a Certified Material Test Report and applicable procurement documentation.
(3) The transfer process shall be defined and controlled by the Certificate Holders, documented in their Quality Assurance manuals, and reviewed and verified by the Authorized Nuclear Inspection Supervisor.
This process will ensure continuity between the previously performed ASME Section III work and the completion work that is to be performed by the contractor. The overall process will ensure that the appropriate Codes are applied to the construction activities at WBN Unit 2 to provide an acceptable level of quality and safety.
VI. Duration of Use of the Proposed Alternative Application of the provisions of this request will commence upon approval of this relief request and site approval of implementing instructions and will continue until such time as the WBN Unit 2 N-3 Code Data Report is completed and signed by TVA, as the Owner; or the use of the Code Case is no longer necessary, nor allowed, in accordance with the provisions of the Code Case. Should the NRC impose additional requirements, they will be implemented prior to completion of the N-3 Code Data Report.
VII. Industry Precedents Due to the unique circumstances associated with WBN Unit 2, there are no established precedents for the use of the revised ASME Section III Code Case, N-520-5.
VIII. Reference
- 1. TVA letter dated August 3, 2007, Watts Bar Nuclear Plant (WBN) Unit 2 - Reactivation of Construction Activities (ML072190047)
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ENCLOSURE 2 Code Case N-520-5, Alternative Rules for Renewal of Active or Expired N-Type Certificates for Plants Not in Active Construction,Section III, Division 1 E2-1