ML20065H899

Clarifies Util Use of Code Case N-389 of ASME Boiler & Pressure Vessel Code for 1990 Calvert Cliffs Unit 2 Pressurizer Heater Sleeve Repair/Replacement Work

ML20065H899
Person / Time
Site:	Calvert Cliffs
Issue date:	04/11/1994
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9404150203
Download: ML20065H899 (3)

Text

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A Ronent E. UtxroN Baltimore Gas and Electric Compimy Vice President Ccdvert Citfs Nuclear Power Plant Nuclear Energy 1650 Calvert Citf]s Parkwery lasby, Maryland to6S7 '

410 $86-2200 Ext.44S5liscal 410 2 &)-4453 Baltimore I

April 11,1994 U. S. Nuclear Regulatory Commission n Washington,DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No. 2; Docket No. 50-318 .

ASME Code Case Clarification for the 1990 Pressurizer Heater Sleeve Renair / Replacement The purpose of this letter is to clarify Baltimore Gas and Electric Company's (BGE) use of Code-Case N-389 of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel -;

(B&PV) Code for the 1990 Calvert Cliffs Unit 2 pressurizer heater sleeve repair / replacement work.

. . 1

- In the course of the engineering preparation for the current Unit 1 pressurizer heater sleeve repair work, we discovered t. hat we had not formally requested and obtained NRC approval to use Code 1 Case N-389, as stipulated by NRC Regulatory Guide 1.147, for the Unit 2 pressurizer repair work performed in 1990. Code Case N-389, " Alternative. Rules for Repairs, Replacements, or q Modifications,Section XI, DMsion 1," allows use of Editions and Addenda of ASME B&PV Code, i Section XI, Division 1, subsequent to those specified in the licensee's inservice inspection program, provided the Edition and Addenda have been accepted by the enforcement and regulatory authorities having jurisdiction' at the plant site. Regulatory Guide 1.147 permits use of Code Case N-389 provided the applicant submits for approval the appropriate edition and addenda of the -l' L Code that is to be used for the repair, replacement, or modification, in addition to those conditions-specified in the Code Case, before start of work. '

- Baltimore Gas and Electric Company's prime contractor for the 1990-Unit 2 pressurizer repair /

replacement project, B&W Nuclear Technologies, invoked the 1986 Edition of Section XI for the design and fabrication specifications. At the time of the Unit 2 repair,Section XI,1986 Edition, was :

the latest edition approved by the NRC as referenced in Paragraph 55a(b) of 10 CFR Part 50; whereas, BGE was still committed 'to the requirements' of Section XI,1983- Edition, through Summer 1983 Addenda for inservice inspection.

Although we did not formally request NRC approval regarding the use of Code Case N-389 in order-

. to invoke Section XI,1986 Edition, we had amply notified the NRC of our intentions on a number of occasions as evidenced below.

i) In a letter to the NRC dated July 13,1989 (Reference a), we indicated our adop' tion -

of the alternative allowed by Section XI,1983 Edition with Addenda through Summer 1983, Paragraph IWA-7210(c), when we requested NRC's approval for an v r&arOHgvI n j 1404150203 940411 DR ADOCK0500g8 g[

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' Document Control Desk .j e April 11,1994 )

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1 alternative to the requirements of the Construction Code (Section III), per i 10 CFR 50.55a(a)(3). By letter dated October 27,1989 (Reference b), we amended -i our July 13 request by changing the Code edition from Section XI,1983 Edition with Addenda through Summer 1983, to Section XI,1986 Edition. By doing so, we had clearly taken advantage of Code Case N-389 provisions without formally requesting its use per Regulatory Guide 1.147.

ii) By letter dated November 3,1989(Reference c), we transmitted the Calvert Cliffs Unit 2 pressurizer heater sleeve repair / replacement plan. Enclosure 1 of that letter :

explicitly specifies the use of Code Case N-389 and the 1986 Edition of Section XI, ASME B&PV Code.

iii) On January 8,1990, during a meeting with the NRC staff, we cited as one of our meeting objectives our desire to obtain approval for the use of the 1986 Edition of the ASME Code per Code Case N-389. This is documented in Reference (d).

iv) By letter dated April 5,1990 (Reference c), NRC approved BGE's proposal for an alternative to the requirements of the ASME Construction Code (Section III). In addition to that, we presume, this letter also implicitly approved the use of Section XI,1986 Edition per Code Case N-389 for the reasons given in (i) above.

All activitics discussed above, concerning the use of the 1986 Edition of Section XI, took place prior to its use in the repair / replacement work on the Unit 2 pressurizer heater sleeves. Therefore, it is our belief that the intent of the Regulatory Guide 1.147 was met. Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, r DM i

RED /GT/ dim 9

,. b Document Control Desk

-<' Apri'.11,1994 P e3

REFERENCES:

(a) Letter from Mr. G. C. Creel (BGE) to NRC Document Control Desk, dated July 13, 1989, Proposal of Alternative to ASME Code '

Section III Requirements (b) Letter from Mr. G. C. Creel (BGE) to NRC Document Control Desk, dated October 27,1989, Revision of Proposal of Alternative to ASME Boiler and Pressure Vessel Code Section III Requirements (c) Ixtter from Mr. G. C. Creel (BGE) to NRC Document Control .

Desk, dated November 3,1989, Submittal of Pressurizer Heater s Sleeve Repair / Replacement Plan (d) Letter from Mr. D.' E. LaBarge (NRC) to Mr. G. C. Creel (BGE),

dated January,1990, NRC-BGE January 8,1990 Meeting Summary (c) Letter from Mr. R. A. Capra (NRC) to Mr. G. C. Creel (BGE), dated April 5,1990, Approval of ASME Code Use of Alternative Materials ,

for Pressurizer Penetrations cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC -

T. T. Martin, NRC >

P. R. Wilson, NRC R. I. McLean, DNR J. H. Walter, PSC l

.