ML18150A017
| ML18150A017 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/06/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 87-090A, 87-90A, NUDOCS 8704130179 | |
| Download: ML18150A017 (8) | |
Text
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS April 6, 1987 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 ADDITIONAL INFORMATION REGARDING THE RELIEF REQUEST ON COMPONENT COOLING HEAT EXCHANGERS Serial No.
87-090A NO/ISI:vlh Docket Nos.
50-280 50-281 License Nos. DPR-32 DPR-37 By letter Serial No.87-090, dated February 24, 1987, we requested relief from certain ASME Section XI requirements on the replacement of the Component Cooling Heat Exchanger channel heads.
In a subsequent discussion, your staff requested additional information to support our request.
The attachment to this letter provides the additional information.
Should you require any further assistance, please contact us.
Very truly yours,
\\S)~~
W. L. Stewart Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A
ATTACHMENT Request for Additional Information Provide a
comparison of the Section III requirements, to which the original heat exchangers were designed and fabricated, to the Section VIII require-
- ments, to which the replacement channel heads were designed and fabricated.
Include with this comparison the material traceability requirements.
Response
We have completed an evaluation of the design, fabrication, inspection, and testing requirements of ASME Section III, 1968 Edition, Subsection C against the current requirements of ASME Section VIII, The following chart provides the details of the Code comparison and the methodology used in the review of the two Code sections.
The results of this review conclude that the design and fabrication requirements of the current edition of ASME Section VIII will meet or exceed the original design and fabrication requirements.
Consistent with ASME Section VIII, 1968 Edition, as referred to by Section III, 1968 Edition, Subsection C, certified material test reports were required by the original component procurement specifications.
The replacement channel heads were also supplied with certified material test reports consistent with ASME Section VIII, 1986 Edition.
We have evaluated the documentation supplied with the replacement channel heads and found that it meets or exceeds the requirements of the original specifications for this component for material traceability.
DESIGN AND FABRICATION REQUIREMENTS COMPARISON ASME Section III, 1968 Edition Subsection C, Requirements for Class C Vessels Article 21, General Requirements N-2110 N-2111 N-2112 N-2113 REQUIREMENTS Subsection C covers requirements for vessels classified as Class C.
The requirement of Section VIII of the Code shall apply to the materials, design, fabrication, inspection and testing and certification of Class C vessels except that the below listed additional requirements apply.
Paragraph U-l(g) of Section VIII shall not apply to Class C vessels.
The rules of paragraph UW-2(a) of Section VIII of the Code shall apply to any Class C vessels that may contain substances whose level of radioactivity is such that their production, storage or use is subject to regulations of Federal or Local jurisdictions.
Resolution of Requirements The original design specifications required the component cooling heat exchangers to be built to ASME Section III, Class C.
The new component cooling heat exchanger chan~
nel heads were designed and fabricated in ac-cordance with the requirements of the 1986 Edition of ASME Section VIII.
These channel heads are considered replacements by ASME Section XI.
Subarticle IWA-7210(c) of Section XI allows use of a later edition of the con-struction code.
The requirements of Section XI, Subarticle IWA-7210(c) are met based on materials of construction for the replacement channel heads and the resolution of additional requirements listed below.
The new channel heads are stamped "U-PART".
Paragraph U-l(g) is not applicable.
This article does not apply since the channel heads are not subjected to radioactivity.
In addition, this article was specifically exempted in the original procurement specifi-cation of the component cooling heat exchangers.
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DESIGN AND FABRICATION REQUIREMENTS COMPARISON (CONT.)
N-2114 N-2115 Paragraph UG-125 through UG-134 of Section VIII shall not apply and the requirements of Article 9 shall be substituted.
Article 9 - Protection Against Overpressure.
Class C vessels shall be stamped with the letter "N" below the Code U - symbol in the stamping shown in Fig. UG-118 of Section VIII of the code.
Original Channel Head Material SA-515 GR 70 This requirement was exempted in the original procurement specification and does not apply to the replacement channel heads since overpressure protection is not required.
Since the component cooling heat exchanger channel heads are being fabricated to ASME Section VIII in lieu of Section III, no "N" stamp is required.
Channel heads are stamped~
"U-PART."
W, Replacement Channel Head Material SA-516 GR 70 The replacement channel heads are fabricated with a slightly different composition low alloy steel with superior resistance to brittle fracture.
The physical properties used for design, minimum yield, minimum tensile and maximum allowable stress are identical.
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Request for Additional Information Provide a comparison of the Section III Quality Assurance requirements to the Section VIII Quality Assurance requirements specifically addressing the requirements during fabrication, third party inspections, and receipt inspection.
Response
We have reviewed the ASME Section III, 1968 Edition, Q.A.
and Q.C.
requirements and have determined that the Q.A. and Q.C. requirements of ASME Section III, 1968 Edition, for Subsection Care the requirements as described in ASME Section VIII, 1968 Edition.
Therefore, the proper comparison of Q.A.
and Q.C. requirements imposed by ASME on the original component cooling heat exchanger channel heads and the replacement channel heads is the comparison of the Section VIII, 1968 Edition, and the Section VIII, 1986
- Edition, requirements.
This comparison is provided in the following chart.
ASME VIII 1968 UG-90(a)
UG-90(b)
UG-90(c) (1)
UG-90(c)(2)
UG-91 UG-92 UG-93 QUALITY CONTROL AND ASSURANCE REQUIREMENTS COMPARISON General paragraph relating inspection and testing of pressure vessels.
Paragraph describes the manufacturers' responsibilities for Q.A. and tests.
Paragraph describes the inspections required to be performed by the Inspector.
Paragraph describes inspection requirements for multiple fabrication activities.
1968 Code requires inspections procedures for multiple fabrication to be reviewed by the Inspection Agency.
This paragraph describes certain general qualifications of an Inspector.
Describes access requirements for the inspector to manufactured parts.
Paragraph describes the requirements for acceptance of materials from the materials manufacturer.
ASME VIII 1986 Same requirements.
Requires same overall responsibilities.
In addition, the 1986 Code lists 19 specific Q.A. responsibilities of the manufacturer.
Requires same overall responsibilities but further defines inspection tasks by requiring that 14 activities be performed by the Inspector.
This edition of the Code specifies the same requirements, but also requires the procedure to be approved by an ASME designee in addition to the Inspection Agency.
e This edition expands the duties of an Inspector as defined in the 1986 Edition to include monitoring Quality Control Requirements as defined in Appendix 10 of the 1986 Edition.
This appendix describes a Q.C. system that th~
manufacturer must implement.
The 1986 Edition..,
outlines a Q.C. system while the 1968 Edition does not.
Same requirements.
The requirements in this edition are more detailed.
Specifically, the 1986 Code Edition requires more documentation in the area of material traceability.
ASME VIII 1968 UG-94 UG-95 UG-96 UG-97 QUALITY CONTROL AND ASSURANCE REQUIREMENTS COMPARISON (CONT.)
Paragraph describes marking requirements.
Paragraph describes inspection of material surfaces during fabrication.
Paragraph describes dimensional checks of component.
Paragraph describes pressure vessel inspection when near completion.
ASME VIII 1986 The 1968 Edition does not allow deep die stamping on steel plates less than 1/4" to guard against cracks.
Requirement is not mentioned in 1986 Edition, however, the Component Cooling Heat Exchanger channel head plate is more than 1/4" thick.
Same as 1968 Code.
Essentially the same as the 1968 Code.
The 1986 Edition adds requirements for the Inspector to perform any dimensional checks he deems necessary.
The 1986 Edition of the Code requires the same inspections required in the 1968 Edition.
In addition, the 1986 Edition adds visual inspection of nozzle welds and vessel lining.
e Request for Additional Information Provide a written commitment that the Component Cooling Heat Exchangers will remain on the Q-list.
Response
The Component Cooling Heat Exchangers will remain on the Q-list and will not be removed for reasons of replacing the channel heads with parts fabricated to ASME Section VIII.
Request for Additional Information Provide a written commitment that the Component Cooling Heat Exchangers will remain in the ISI Program.
Response
The Component Cooling Heat Exchangers will remain in the ISI Program and will not be removed for reasons of replacing the channel heads with parts fabricated to ASME Section VIII.
The Component Cooling Heat Exchangers will continue to be inspected per our ISI Program as a Class 3 component.