ML17335A303

Requests Relief from Provisions of 1989 ASME Code,Section XI for CSS Nozzle Welds,Per 10CFR50.55a(g)(5)(iii).Relief Request Is Applicable to Both CSS Heat Exchangers in Units 1 & 2

ML17335A303
Person / Time
Site:	Cook
Issue date:	10/20/1998
From:	Powers R AMERICAN ELECTRIC POWER CO., INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:0969BO, AEP:NRC:969BO, NUDOCS 9810270066
Download: ML17335A303 (7)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTIOh SYSTEM (RIDS)

ACCESS10N NBR:9810270066 DOC.DATE:-98/10/20 NOTARIZED: NO DOCKET ¹ FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH.NAMP AUTHOR AFFILIATION POWERS,R.P. American Electric Power Co., Inc.

RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Requests relief from provisions of 1989 ASME Code,Section XI for CSS nozzle welds,per 10CFR50.55a(g)(5)(iii).Relief A

recpxest is applicable to both CSS heat exchangers in Units 1 &. 2.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution E NOTES: G RECIPIENT COPIES RECIPIENT COPIES 0 ID CODE/NAME LTTR ENCL , ID CODE/NAME LTTR ENCL PD3-3 LA 1 1 PD3-3 PD 1 1 STANG 1 1 Y

INTERNA 1 1 NRR/DE/ECGB/A 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

E N

NOTE TO ALL'RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 41S-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 12

American Electric~r Nuclear Generations 500 CirCle Drive

'Buchanan, Ml 491071373 October 20,,1998 AEP:NRC:0969BO Docket Nos: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-P1-17 Washington, D. C. 20555-0001 Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 CODE RELIEF REQUEST FOR THE CONTAINMENT SPRAY SYSTEM NOZZLE WELDS Following a walkdown of the containment spray system (CTS) heat exchangers, it was determined that relief from the provisions of the 1989 ASME Code,Section XI is required. The CTS heat exchanger nozzle-to-shell weld has a nozzle reinforcing plate covering the nozzle-to-shell weld, making the code required outside surface examination impossible to perform. Relief for this weld was not required for the first and second ISI intervals because the code editions applicable during these intervals exempted the CTS heat exchangers. This exemption is not contained in the 1989 code edition, which is used for the third ten-year interval that began July 1, 1996. The need for relief was not recognized when the third ten-year plan was submitted.

This relief request (attachment) is being submitted under the provisions of 10 CFR 50.55a (g) (5) (iii), conformance with a code requirement is impractical. The relief request is applicable to both CTS heat exchangers in unit 1 and unit 2.

The CTS heat exchanger nozzle-to-shell welds are scheduled for examination during the second inspection period for'nit 1 and during the third inspection period for unit 2. The second period ends June 30, 2003, and the fourth period ends June 30, 2006.

Approval of the requests is requested prior to the beginning of the second inspection period, July 1, 1999.

Sincerely, P: Powe Vice President

/gmc Attachment

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UPS. Nuclear Regulatory Commission AEP:NRC:0969BO Page 2 c e J. A. Abramson L. Caldwell, w/attachment MDEQ DW & RPD NRC Resident Xnspector, w/attachment J. R. Sampson, w/attachment

Attachment to AEP:NRC:0969BO Containment Spray Heat Exchanger Nozzle-to-Shell Relief Weld Request I

Attachment to AEP:NRC:0969BO Page 1 Backcaround The unit 1 and unit 2 containment spray (CTS) heat exchanger nozzles are fabricated with a welded reinforcement that prevents access to the nozzle-to-shell weld. Because of the presence of the reinforcement, an ASME Section XI, 1989 Edition required surface examination of the outer weld surface cannot be performed.

S stem/Com onent for Which Relief is Re ested Two class 2 nozzle-to-shell welds out of four total that exist on two CTS heat exchangers per unit require examination.

Code Re irements ASME Section XI, 1989 Edition, Table IWC-2500-1, Examination Category C-B, Item No. C2.11, requires a surface examination of the outer surface of nozzle-to-shell welds on one of multiple non-exempt class 2 vessels of similar design, size, and service.

Basis for Code Relief The required surface examination of the outer surface of the CTS heat exchanger nozzle-to-shell welds is impractical due to a welded reinforcement pad installed over the nozzle-to-shell weld. Access to the weld from the outside of the vessel is not possible without removing the attachment welds of the nozzle reinforcement pad and removing the reinforcement pad.

Alternative Method It is proposed that, in lieu of the code required surface examination on the outer surface of the CTS heat exchanger nozzle-to-shell weld, a surface examination shall be performed on the inner surface of the class 2 nozzle-to-shell welds. This examination will be performed whenever the flanged cover of one of the CTS heat exchangers is disassembled for maintenance or other activities.

Justification for Grantin Code Relief A surface examination on the outer surface of the CTS heat exchanger nozzle-to-shell weld is not possible due to a welded reinforcement pad covering the weld. The alternative, performing a surface examination on the inner surface of the weld when the flanged cover of the heat exchanger is disassembled for maintenance or other activities, will provide a method for assessing the structural integrity of the weld.

There are no reported industry failures of these welds based on review of industry event reports. It is, therefore, concluded that the code relief requested above will not endanger life or property or otherwise compromise the common defense and security.

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