ML20070B420
| ML20070B420 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/23/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-319, NUDOCS 9406300114 | |
| Download: ML20070B420 (4) | |
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VIHOINIA Eu:CTHIC ann Pown:n COMl'ANY Iticnwoun,Vinorxia cuent i
June 23, 1994 i
U.S. Nuclear Regulatory Commission Serial No.94-319 Attn: Document Control Desk NL&P/EJW 1
Washington, D. C. 20555 Docket No.
50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen, VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA 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.
This Code Case has not been endorsed for use by Regulatory Guide 1.147,
" Inservice Inspection Code Case Acceptability ASME Section XI Division 1," due to its recent approval by ASME. Pursuant to 10 CFR 50.55a(a)(3), we request that Code Case N-416-1 be approved for use at North Anna Units 1 and 2 for the second 10-year interval requirements in lieu of the previously submitted relief request.
Relief Requests SPT-12 for North Anna Unit 1 and SPT-15 for Unit 2 were submitted by letter dated August 5,1993, (Serial No.93-435) for your approval. These relief requests address post-repair and replacement hydrostatic testing requirements which are similar to the requirements delineated in Code Case N-416-1. Since the ASME Code Case now addresses the issues and requirements specified in Relief Requests SPT-12 (Unit 1) and SPT-15 (Unit 2), these relief requests are hereby withdrawn.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 start-up 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 i
9406300114 940623 1
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burdensome.
Deferred hydrostatic testing requirements should be assessed
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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-4161 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 deterrnined by the ASME Code.
North Anna Unit 1 is currently scheduled to start its refueling outage on September 9, 1994. North Anna Unit 2 is currently scheduled to begin its refueling outage on March 11, 1995. If permanent approval for use of Code Case N-416-1 cannot be obtained t
prior to the refueling outages, we request that North Anna be granted interim approval to use Code Case N-416-1 during the next rafueling outages.
If you have any questions, please contact us.
Very truly yours, a lbntLa N
w James P. O'Hanlon Senior Vice President - Nuclear Attachment cc:
U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station I
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ATTACHMENT 1 ASME CODE CASE N-416-1
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CASE N-416-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: February 15, 1994 See Numeric Index for expiration and any reaffirmation datee Case N-416-1 placement items by welding, system leakege test may Attemmive Pressuse Test Recpirement for Welchi be used pmvided the following requirements are met.
Repairs orImtallsion of Replacement items by (a) NDE shall be performedin accordance with tic Welding, Class 1, 2 and 3 methods and acceptance criteria of the applicable Sub-Section XI, Division I section of the 1992 Edition of Section III.
(b) Prior to or immediately upon return to service, a j
visual examination (VT-2) shallbe performed in con-junction with a system leakage test, using the 1992 Edi-Inquiry: What allemative 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 i stallation of (c) Use of this Case shall be documented on an NIS-replacementitems by welding?
2 Form.
i 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 Ic clim-para. IWA-4000 for welded repairs orinstallation of re-inated when the requirements of this revision are met.
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