ML18017A865

Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety

ML18017A865
Person / Time
Site:	Harris
Issue date:	09/08/1999
From:	Alexander D CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-99-127, NUDOCS 9909140191
Download: ML18017A865 (10)

Text

REGULA Y INFORMATION DISTRIBUTI i. SYSTEM (RIDS)

ACCESSION NBR:9909140191 DOC.DATE: 99/09/08 NOTARIZED: NO DOCKET I

, FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAPPE, AUTHOR AFFILIATION ALEXANDER,D.B. Carolina Power & Light Co.

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

SUBJECT:

Requests relief from Section XI,IWA-5242(a) requirement for HNP Class 2 bol ted connections in bora ted sys . Compliance with requirement would result in unusual difficulty without compensating increase in leve3. of quality Ec safety. A DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES 0 ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD2-2 LA 1 1 LAUFER,R. 1 1 INTERNAL: ACRS 1 1 LE CESTUI 0 1 1 Y NUDOCS-ABSTRACT RES/DET/ERAB 1

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1 EXTERNAL: LITCO ANDERSON 1 1 NOAC 1 1 NRC PDR 1 1 D

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE LISTS DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF. COPIES REQUIRED: LTTR 11 ENCL 10

~4 Carolina Power & Ught Company Harris NucIear Plant P.O. Box 165 New Hill NC 27562 SERIAL: HNP-99-127 SEP 8 1999 10 CFR 50.55a United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 INSERVICE INSPECTION PROGRAM RELIEF REQUEST NO. 2R2-008 ALTERNATIVETO ASME CODE SECTION XI, IWA-5242(a) REQUIREMENTS

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(ii), Carolina Power & Light Company (CP&L) requests relief from the 1989 Edition of the American Society of Mechanical Engineers (ASME) Code Section XI for the Harris Nuclear Plant (HNP). Specifically, CP&L requests relief from the Section XI, IWA-5242(a) requirement for HNP Class 2 bolted connections in borated systems. IWA-5242(a) specifies that insulation must be removed from pressure retaining bolted connections in borated systems for VT-2 visual examination during the performance of system pressure testing.

Compliance with this requirement would result in hardship or unusual difficultywithout a compensating increase in the level of quality and safety.

A proposed alternative to the IWA-5242(a) requirement is enclosed as relief request number 2R2-008. The alternative will consist of performing a system pressure test and VT-2 visual examination on Class 2 bolted connections each inspection period during a refueling outage, without removal of insulation. In addition, the insulation shall be removed from the bolted connections and a VT-2 visual examination shall be performed when the connection is not pressurized. The proposed alternative will provide an acceptable level of quality and safety since the insulated Class 2 bolted connections will receive pressure testing and VT-2 visual examinations each inspection period.

It is requested that the NRC review this relief request prior to March 15, 2000 to avoid adversely impacting the Refueling Outage 9 schedule. Please refer any question regarding this submittal to Mr. J. H. Eads at (919) 362-2646.

9909140191 990908 PDR ADOCK 05000400 6 PDR 5413 Shearon Harris Road New Hill NC

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Document Control Desk SERIAL: HNP-99-127 Page 2 D. B. Alexander Manager, Regulatory Affairs Harris Plant Enclosure c: Mr. J. B. Brady (NRC Senior Resident Inspector, HNP)

Mr. R. J. Laufer (NRR Project Manager, HNP)

Mr. L. A. Reyes (NRC Regional Administrator, Region II)

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Enclosure to SERIAL: HNP-99-127 Page 1 of 2 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 INSERVICE INSPECTION PROGRAM RELIEF REQUEST NO. 2R2-008 ALTERNATIVETO ASME CODE SECTION XI, IWA-5242(a) REQUIREMENTS COMPONENTS FOR WHICH RELIEF IS REQUESTED:

Class 2 pressure retaining bolted connections in systems borated for the purpose of controlling reactivity that are located inside containment.

ASME SE<CTION XI CODE< REQUIREMENTS:

The ASME Code Section XI, 1989 Edition with no Addenda, IWA-5242(a) requires that for systems borated for the purpose of controlling reactivity, the insulation must be removed from pressure retaining bolted connections in order to perform VT-2 visual examinations during system pressure testing.

CODE RELIEF REQUEST:

Relief is requested from the Code Section XI, IWA-5242(a) requirement for Class 2 pressure retaining bolted connections in borated systems.

BASIS FOR REQUESTING RELIEF:

Pursuant to 10 CFR50.55a(a)(3)(ii), relief is requested on the basis that compliance with the original examination requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Inside containment, the referenced systems are tested in an environment that is hazardous to personnel. Removing and reinstalling insulation under these conditions is difficultto perform and is not consistent with the ALARAconcept when compared to the alternate approach. In addition, the removal and reinstallation of insulation is often a critical path activity which directly affects the duration of refueling outages, therefore placing a financial hardship on the plant.

The concern that led to the Section XI requirement for removal of insulation on bolted connections, while performing pressure testing and VT-2 examinations, is that a borated-water leak from a bolted connection could cause corrosion of the bolting materials. The weakening of the bolting could be hidden by the insulation if it were not removed. Thus, the structural integrity of a safety-related system could be compromised by a small leak that could be unnoticed if the insulation remains in place during the pressure testing and VT-2 examination.

This relief request addresses the structural integrity concerns while mitigating the personnel hazards and reducing the critical path impact of the testing. It divides the

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Enclosure to SERIAL: 127 Page 2 of 2 pressure testing and the VT-2 examination into two activities that need not be performed at the same time. The proposed alternate examination is supported by the following:

(a) ASME Code Case N-533 was approved by the Section XI Code Committee, thus providing an alternative to the similar requirement for examination of insulated Class 1 pressure retaining bolted connections.

(b) By letter dated November 4, 1998 (TAC No. MA0989), the NRC approved HNP relief request 2R1-010 for Class 1 bolted connections.

(c) Similar relief requests have been approved by the NRC for other nuclear power plants (Virgil C. Summer Nuclear Station and Surry Power Station).

(d) Pre-existing boric acid leaks will be detected at atmospheric or static pressures due to residue deposits.

(e) The alternative test will not be applied to post repair/replacement activities on bolted connections.

ALTE<RNATEEXAMINATIONS:

The following alternate rules for the pressure testing and VT-2 visual examination of Class 2 pressure retaining bolted connections will be used:

(a) A system pressure test and VT-2 visual examination shall be performed each inspection period without removal of insulation.

(b) The insulation shall be removed from the bolted connections each inspection period, and a VT-2 visual examination shall be performed. The connections are not required to be pressurized. Any evidence of leakage shall be evaluated in accordance with the requirements specified in HNP relief request 2RG-009, which was approved by the NRC by letter dated November 4, 1998.

TECHNICALJUSTIFICATION FOR REQUESTING RELIEF:

The proposed alternative provides an acceptable level of quality and safety since the insulated Class 2 bolted connections will still receive pressure testing and VT-2 visual examinations each inspection period. No changes are being made to the areas that are inspected, the inspection criteria, or the VT-2 personnel qualifications.

IMPLEME<NTATIONSCHEDULE:

This Relief Request (2R2-008) is applicable to the HNP Second 10-Year Inservice Inspection Interval.

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