ML18153A976

Requests That Encl Code Case N-416-1 Be Approved for Use During Third 10-yr Intervals in Leu of Relief Request 9 Submitted by 930716 Ltr.Relief Request 9 of Unit 1 ISI Program No Longer Necessary & Hereby Withdrawn

ML18153A976
Person / Time
Site:	Surry
Issue date:	06/22/1994
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
94-320, NUDOCS 9406280143
Download: ML18153A976 (3)

Text

e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June--22, 1994 United States Nuclear Regulatory Commission Serial No.94-320 Attention: Document Control Desk SPS/ETS Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen, VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 INSERVICE INSPECTION PROGRAM ASME CODE CASE N-416-1 ASME Code Case N-416-1 (attached), "Alternative Pressure Test Requirement for Welded Repairs or Installation of Replacement Items by Welding, Class 1, 2, and 3 Section XI, Division 1," was approved by the ASME Code on February 15, 1994.

However, this Code Case has not yet been endorsed in Regulatory Guide 1.147, "lnservice Inspection Code Case Acceptability ASME Section XI Division 1," due to its recent approval by ASME. Therefore, pursuant to 10 CFR 50.55a(a)(3), it is requested that Code Case N-416-1 be approved for use during the Surry Units 1 and 2 third 10-year intervals in lieu of the previously submitted relief request.

By letter dated July 16, 1993 (Serial No.93-420), Relief Request 9 of the third interval ISi Program for Surry Unit 1 was submitted to the NRC for approval. This request addresses post weld repair and replacement testing requirements, which are similar to the requirements delineated in Code Case N-416-1. Since the ASME Code now addresses post weld repair and replacement hydrostatic testing requirements through Code Case N-416-1, Relief Request 9 of the Unit 1 ISi Program is no longer necessary and is hereby withdrawn.

In past situations we have found it necessary to defer hydrostatic tests or ask relief from post ASME Section XI hydrostatic tests following repair or replacement activities.

This was due to various reasons of impracticality in testing, ranging from boundary valve isolation problems to incorporation of the steam generators within the hydrostatic test boundary. These situations are typically unexpected and are usually only identified during the actual inservice inspection. As a consequence, some of these situations have necessitated immediate communication with the NRC to avoid exceeding limiting conditions of operation or startup delays.

Use of hydrostatic test deferrals, which are presently allowed in the current Code Case N-416 for Class 2 components, are not a satisfactory solution because the test must eventually be performed, and it is the performance of the test itself that is considered 9406280143 940622 PDR ADOCK 05000280 Q PDR

e burdensome. Deferred hydrostatic testing requirements should be assessed considering that the 10-year hydrostatic test is no longer required with the NRC endorsement of Code Case N-498, Alternative Rules for 10-year Hydrostatic Pressure Testing for Class 1 and 2 SystemsSection XI, Division 1.

Code Case N-416-1 provides increased testing flexibility to the Owner, which should considerably reduce, if not eliminate, relief request requirements associated with post welded repair/replacement hydrostatic testing. This is accomplished while maintaining an acceptable level of safety and quality as determined by the ASME Code.

Unit 2 is currently scheduled to start its refueling outage in January of 1995. The Unit 1 refueling outage is currently scheduled to start in September of 1995. If permanent approval for use of Code Case N-416-1 cannot be obtained in the time period remaining prior to the refueling outages, it is requested that Surry be granted interim approval to use Code Case N-416-1 for the next refueling outages.

If you have any questions, please contact us.

Very truly yours,

~ y{J7JCLrv8~

James P. O'Hanlon Senior Vice President - Nuclear Attachment cc: U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Atlanta, Georgia 30323 Mr. Morris Branch NRC Senior Resident Inspector Surry Power Station

e CASE N-416-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: February 15, 1994 See Numeric Index tor expiration and any reaffirmation dates Case N-416-1 placement items by welding, system leakage test may Alternative Pressure Test Requirerrent for Welded be used provided the following requirements are met.

RepaiIS or Installation of Replacement ltellti by (a) NDE shall be performed in accordance with the Welding, Class 1, 2 and 3 methods and acceptance criteria of the applicable Sub-Section XI, Division 1 section of the 1992 Edition of Section III.

(b) Prior to or immediately upon return to service, a visual examination (VT-2) shall be performed in con-junction with a system leakage test, using the 1992 Edi-Inquiry: What alternative pressure test may be per- tion of Section XI, in accordance with para. IWA-5000 formed in lieu of the hydrostatic pressure test required at nominal operating pressure and temperature.

by para IWA4000 for welded repairs or installation of ( c) Use of this Case shall be documented on an NIS-replacement items by welding? 2 Form.

Reply: It is the opinion of the Committee that in lieu If the previous version of this case were used to defer of performing the hydrostatic pressure test required by a Class 2 hydrostatic test, the deferred test may be elim-para. IWA-4000 for welded repairs or installation of re- inated when the requirements of this revision are met 649 SUPP. 8 - NC