ML20086Q494
| ML20086Q494 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/21/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9507280068 | |
| Download: ML20086Q494 (6) | |
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- Ctat6en snapport Departnsent 10CFR50.55a
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PECO ENERGY ~
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lg 965 Chesterbrook Boulevard Wayne, PA 19087 5691 July 21,1995 Docket Nos. 50-277 50-278 License Nos. DPR44 DPR-56 l.
U. S. Nuclear Regulatory CO.w'z':-i Attn: Document Control Desk Washington, DC 20555 Subject.
Peach Bottom Atomic Power Station, Units 2 and 3 Adoption of Code Cases N-498-1 and N-416-1 (Relief Request No.
RR 14, Revision 4)
Dear Sir:
Attached for your review and approval is Relief Request No. RR-14 Revision 4, for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, Second Ten-Year Interval inservice Inspection (ISI) Program.- In our letter dated February 27,1995, PECO Energy Company requested approval of Relief Request No. RR-14, Revision 3, and Relief Request No. RR-20, Revision 0. Based on discussions with the U. S. Nuclear Regulatory Commission (USNRC), we are withdrawing those requests for relief. In lieu of these Relief Requests, PECO Energy Company is submitting a revised Relief Request No. RR-14, Revision 4.
This Relief Request would allow authorization to utuize Code Cases N-498-1 and N-416-1. Code Case N-498-1 will allow substitution of a system pressure test, conducted at nominal operating pressure, for the ten year hydrostatic test, currently required for Class 1, 2, and 3 systems.
Code Case N-416-1 will allow substitution of a system leakage test, conducted at nominal operating pressure, for the post-repair / replacement hydrostatic teet, currently required for Class 1,2, and 3 systems.
We request your review and approval by August 11,1995. If you have any questions or require additional information, please do not hesitate to cornact us.
Very truly yours, G. A. Hunger, r.,
Director - Licensing -
Attachment O
cc:
T. T. Martin, Administrator, Region 1, USNRC
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W. L Schmidt, USNRC Senior Resident inspector, PBAPS
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ATTACHMENT i
Peach Bottom Atomic Power Station Units 2 and 3 inservice inspection Program Relief Request No. RR-14, Revision 4 f
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SpecNication a:
M-733, Rev. _
Appendix A-14 Page 1 of 4 l
RELIEF REQUEST NO. RR-14 Revision 4.
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This relief request has been developed to rer.st approval for the use of specNic ASME Section XI Code Cases in this ISI Program. base Code Cases have not yet been specNicaHy endorsed for use by the NRC, in Regulatory Guide 1.147 (reference 1.1.24).
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DISCUSSION Code Cases are periodically published by the ASME for the purpose of either clarWying the intent of Code requirements or for providing requirements for circumstances which are not currently covered by existing Code, but need to be addressed in a timely manner. Use of these ron-mandatory Code Ceet for inservice inspection is subject to NRC acceptance of the Code Case (s). Regulatory _Guid61147 lists those Code Cases that have been reviewed by the NRC.
and are generally acceptable for !mplementation in an ISI Program. Other Code Cases may be' used provided specific authorization is secured pursuant to 10CFR50.55a..
L The purpose of this relief request is to request authorizaten for the adoption of specNic Code Case (s) for implementation in the PBAPC, Units 2 and 3 Second Interval ISI Program.
Ill.
CODE CASE (S) REQUIRING AUTHORIZATION The Code Case (s) requiring specNic authorization for use in the PBAPS, Units 2 and 3 ISI Program are identWied on the attached Table (s).
IV.
ALTERNATE PROVISIONS The allemative provisions of the Code Case (s) identNied in Section lli above, shall be implemented in the PBAPS, Units 2 and 3 ISI Program for the second inservice inspection.
Interval. Any deviations from these requirements are identihed in the referenced Tables. These Tables address the specific application of the associated Code Case in the ISI Program.
V.
BASIS FOR RELIEF
- The Code Case (s) referenced in Section lit above, represent technicaNy amard=Ne allemative requirements to the ASME Section XI Code requirements..The fact that the Code Case (s) has not been endorsed in the Regulatory Guide in no way detracts from their technical adequacy, since the major reason for their omission is the timing of their publication with respect to the '
most recent revision of the Regulatory Guide. That is, the subject Code Case (s) is relatively recent and it is expected that it will be accepted in a subsequent revision of the Regulatory Guide. Adoption of the Code Case (s) provides an acceptable level of quality and safety and does not comprormse the adequacy of the PBAPS, Units 2 and 3 ISI Program in meeting the intent of ASME Section XI.
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<c 4-Specification M-733, Rev.
j l1 PBAPS 2.& 3 '
ISI Program ~
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. Appendix A-14 l
Page 2 of 4 l
l RELEF REQUEST NO. RR 14 (CONTD)
Revision 4 l
i Table RR-14-1
.I CODE CASE N-498-1; 1.
IDENTIFICATION OF COMPONENTS l
PBAPS, Units 2 and 3 Class 1,2, and 3 systems.
II.
CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED The 10-Year System Hydrostatic Pressure Testing requirements for Class 1,2, and 3 systems, as identified in Section XI. Division 1, Table IWB-2500-1, Category B-P, Table IWC-2500-1,.
l Category C-H, and Table IWD-2500-1, Categories D-A, D-B, and D-C respectively; as q
contained in the 1980 Edition of ASME Section XI, including addenda through the Winter 1981-Addendum.
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BASIS FOR RELIEF - Code Case N-498-1:
The burden imposed by the higher test pressuies associated with the current 10 year hydrostatic test requirement, is not commensurate with the increase in safety benefit.
l Hydrostatic pressure tests are performed at elevated pressures which require special maintenance activities for_ isolation of components to be tested, such as: temporary gagging or
'q removal of relief valves installed to prevent overpressurization, leaktight repair of valving which does not normally serve a pressure isolation function, and installation of portable hydrostatic pressure pumps. The higher pressures imposed on the pressure boundary components during j
hydrostatic testing do not challenge the structuralintegrity of the material, and produce only a slight enhancement in leak detection capability..The additional leakage, above that which occurs during a system pressure test at nominal operating pressure, is inconsequential in l
determining pressure boundary integrity.. Therefore, the additional burden, and in some.
'j instances additional radiological dose to personnel associated with these maintenance activities,.
can be avoided.The experience gained by the performance of these tests indicates that the -
goal of the test (i.e. to discover pressure boundary leakage or evidence of structural distress) l will still be achieved at lower test pressures.
Adoption of this Code Case will allow substitution of a system pressure test, conducted at j
nominal operating pressure, for the ten year hydrostatic test, currently requlred for Class 1, 2, and 3 systems.
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ALTERNATE PROVISIONS l
i As an attemative to the hydrostatic testing requirements, a system pressure test, at nominal i
operating pressure, may be conducted at or near the end of the interval. *ihe boundary, l
subject to test pressurization during this system pressure test, will extend to 3!! Class 1,2, and i
3 components as identified on the ASME Section XI Boundary P & ID's.
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Specification M-733, Rev. _
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PBAPS 2 & 3
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Appendix A-14 ISI Program Page 3 of 4 l
RELIEF REQUEST NO. RR-14 (CONTD)
Revision 4 i
Table RR 14 2 CODE CASE N-4161 f
1.
IDENTIFICATION OF COMPONENTS PBAPS, Units 2 and 3 Class 1,2, and 3 systems.
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CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED l
ASME Section XI,1980 Edition, Winter 1981 Addenda, Article IWA-4000 and IWA-5000 f
hydrostatic pressure test requirements.
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BASIS FOR RELIEF - Code Case N-416-1:
The above Articles require that hydrostatic pressure testing be performed after welded repair or installation of replacement items by welding on ASME Class 1,2 and 3 pressure boundary f
components.
l The burden imposed by the process of hydrostatic testing is not commensurate with the increased level of safety achieved. Hydrostatic pressure tests are performed at elevated pressures which require special maintenance activities for isolation of components to be tested, such as: temporary gagging or removal of relief valves installed to prevent overpressurization, leaktight repair of valving which does not normally serve a pressure isolation function, and installation of portable hydrostatic pressure pumps. The higher pressures imposed on the pressure boundary components during hydrostatic testing do not chalienge the structural Integrity of the material, and produce only a slight enhancement in leak detection capability.
The additional leakage, above that which occurs during a system pressure test at nominal operating pressure, is inconsequential in determining pressure boundary integrity. Therefore, the additional burden, and in some instances additional radiological dose to personnel associated with these maintenance activities, can be avoided.
Adoption of this Code Case will allow substitution of a system leakage test, conducted at -
nominal operating pressure, for the post-repair / replacement hydrostatic test, currently required l
for Class 1,2 and 3 systems.
IV, ALTERNATE PROVISIONS
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The requirements of Code Case 416-1 will be implemented as attemate provisions to the ASME Section XI Code,1980 Edition with Addenda through Winter 1981, for Class 1,2 and 3 pressure boundary component welded repairs and installation welds for replacement items.
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Specification' g
M 733, Rev..
l PBAPS 2 & 3 --
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Appendix A-14.
Page 4 of 4
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RELIEF REQUEST NO. RR-14 (CONTD) l' Revision 4 a
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TatWe RR 14 2 -
CODE CASE N 4161 i
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.IV..
ALTERNATE PROVISIONS (Contd) -
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in addition, Nondestructive Examination (NDE) of Class 1,2, and 3 repair or replacement butt e
L welds shall be performed in accordance with the UFSAR license commitments, which will equal or exceed the NDE methods and acceptance criteria of the applicable Subsection of the 1992 i
Edition of ASME Section ill. In the absence of volumetric examination requirements, a surface.
~j examination of the root pass of the butt weld shall be performed.
l Surface examination of Class 1,2, and 3 repair or replacement socket welds shall be performed on the final pass of the socket weld.
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t The above provisions provide an equivalent level of safety to that associated with hydrostatic -
testing, and are consistent with ALARA good practice..
-i Use of this Code Case shall be documented on the applicable Code Form, and included in the' ISI Summary Report.
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