ML20076K725
| ML20076K725 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/25/1994 |
| From: | Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| N-416-1, NUDOCS 9411020031 | |
| Download: ML20076K725 (3) | |
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Log # TXX 94232 2C File # 10010,1 905.4- -(( Ref.-# 10CFR50 55a(a)(3)(ii) nlELECTRIC October 25, 1994 C. Lance Terry Group Vice President U. S. Nuclear Regulatory Commission 1 Attn: Document Control Desk Washington, DC 20555 l
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) j DOCKET NOS. 50-445 AND 50-446 REQUEST APPROVAL AND USE OF ASME CODE CASE N-416 1 REF: 1) (Unit 1: 1986 Edition of ASME Code, Section XI, No Addenda. Interval Start Date August 13, 1990. First Interval: Unit 2: 1986 Edition of ASME Code, Section XI, No Addenda, Interval Start Date - August 3, 1993, First Interval) 1
- 2) ASME Code Case N 416 1, " Alternative Pressure Test Requirement for Welded Repairs or Installation of Replacement items by Welding. Class 1, 2 and 3, Section XI.
Division 1," Dated February 15, 1994 Gentlemen: TV Electric requests approval to use ASME Code Case N 416-1 (Enclosed) in r lieu of performing the code required hydrostatic pressure test for welded repairs or installation of replacement items by welding. Pursuant to 10CFR 50.55a(g)(4), ASME Code Class 1, 2 and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code, Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components " to the extent practical within the limitations of design, geometry, and materials of construction of the components. The applicable ASME Code Editions for CPSES are noted in Reference 1. Regulation 10CFR50,55a(a)(3)(ii) allows alternate requirements if compliance with the specified requirements of this section [10CFR50.55a(g)(4)] would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. TV Electric is requesting approval for the implementation of the alternative rules of ASME Section XI Code' Case N-416-1 (Reference 2) for CPSES Unit 1 and 2. t i f.'n9PQ 9411020031 941025 .h PDR ADOCK 05000445 PDR -( k i 400 N. Olive L.B. 81 Dallas, Texas 75201
TXX 94f32 Page 2 of 2 In lieu of hydrostatic pressure testing for welded repairs or installation l of replacement items by welding, Code Case. N 4161 requires a visual examination (VT 2) be performed in conjunction with a system leakage testing using the 1992 Edition of Section XI, in accordance with paragraph IWA-5000, at nominal operation pressure and temperature. This code case also specifies that NDE of the welds be performed in accordance with the applicable Subsection of the 1992 Edition of Section'III. Considering the-NDE performed on Code Class 1 and 2 systems and considering I that the hydrostatic pressure tests rarely result in pressure boundary leaks that would not occur during system leakage tests TV Electric believes that the increased assurance of the integrity of Class 1 and Class 2 welds is not commensurate with the burden of performing hydrostatic testing.
- However, for Code Class 3 components, TU Electric will implement the proposed alternative only if additional surface examinations are performed on the j
root pass layer of butt and socket welds on the pressure retaining boundary l of Class 3 components. TV Electric considers the alternate testing requirements proposed in Reference 2 to constitute a reasonable, safe alternative to the existing hydrostatic testing requirements. ? It is requested that approval of this code case be granted by the November 4, 1994, so that it may be used during the first refueling outage for Unit 2 which began on October 3,1994, and during all subsequent refueling outages for Unit 1 and Unit 2. Timely approval is requested in order to obtain, through implementation of the code case, the maximum achievable cost savings and reduction in radiation exposure. If you have any question please call Carl Corbin at (214) 812-8859. Sincerely, C. L. Terry By: D. R. Woodlan Docket Licensing Manager CBC Enclosure c-Mr. L. J. Callan, Region IV Hr. D. D. Chamberlain, Region IV Resident Inspectors (2) Mr. Tim Polich, NRR Hr. G. Bynog, TDLS l ) .i
- nclosure to TXX-44232 P$ e,c 1 of 1 CASE N-416-1 CASES OF ASME BOILER AND PRESSl'RE VESSEL CODE Approvei Date: February 15 1994 See Numeric Moes for esotration ano anv restformarron dates.
Case N-416-1 placement items by welding a system leakage test may Alternative Pressure Test Requirement for Welded be used provided the following requirements are met. Repairs or installation of Replacement items by tal NDE shall be performed in accordance with the Welding, Class 1,2 and 3 methods and acceptance entena of the applicable Sub-Section XI. Division I secnon of the 1992 Edition of Section III. (b) Prior to or immediately upon rerum to service, a visual examination (VT-2) shall be performed in con-Inquirv What a!!emative pressure test may be per-junction with a system leakage test. using the 1992 Edi-formed in lieu of the nydrostatic pressure test recuired tion of Section XI. in accordance with para. IWA-5000, by para. IWA-4000 for welded repairs or mstallation of at nominal operating pressure and temperature. replacement items e) weldmg! cs Use of this Case shall be documented on an NIS-2 Form. Rep /v: It is the opmion of the Committee that m lieu if the previous version of this case were used to defer of performmg the hydrostatic pressure test required by a Class 2 hydrostatic test. the deferred test may be elim-para. IWA-4000 for welded repairs or instalianon of re-inated when the requirements of this revision are met. i i SUPP. 8 - NC ..}}