ML20133E491
| ML20133E491 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/02/1997 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CO-96-0104, CO-96-104, NUDOCS 9701130052 | |
| Download: ML20133E491 (4) | |
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Wf LF CREEK NUCLEAR OPERATING CORPORATION Otto L Maynard Chief Administrative Officer January 2, 1997 CO 96-0104 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Subject:
Docket No. 50-482:
Request for Use of ASME Code Case 508-1 " Rob.ation of Serviced Snubbers and Pressure Relief Valves for the Purpose of Testing" Gentlemen:
Pursuant to the provisions of 10 CFR 50. 55a (a) (3) (i), Wolf Creek Nuclear operating Corporation requests approval for use of ASME Section XI Code Case N-508-1,
" Rotation of Serviced Snubbers and Pressure Relief Valves for the Purpose of Testing," at. Wolf Creek Generating Station.
Code Case N-508-1 was approved by the American Society of Mechanical Engineers (ASME) on May 11, 1994 and was published in Supplement 9 of the 1992 Nuclear Code Case book.
Code Case N-508-1 is not included in the most recent listing of NRC approved Code Cases in Revision 11 of Regulatory Guide 1.147,
" Inservice Inspection Code Case Acceptability - ASME Section XI Division 1."
The attachment provides the justification for the use of Code Case N-508-1 and a determination that use of the Code Case provides an acceptable level of quality and safety.
Approval for use of Code Case N-508-1 is requested by February 15, 1997, to support WCNOC's preparation for the next refueling outage. A copy of the Code Case is enclosed for your convenience.
a If you should have any questions regarding this response, please contact me at (316) 354-8831, extension 4450, or Mr. Terry S. Morrill at extension 8707.
Very truly ur,
9701130052 970102 PDR ADOCK 05000482
/// / d P
pon Otto. Mayna d OLM/jad Attachment Enclosure cc:
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J.
Callan (NRC), w/a, w/e W. D. Johnson (NRC), w/a, w/e g
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F. Ringwald (NRC), w/a, w/e g
J. C.
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Attachment to CO 96-0104 Page 1 of 2 REQUEST FOR USE OF ASME CODE CASE N-508-1 AT WOLF CREEK GENERATING STATION Backaround:
' Wolf Creek Nuclear Operating Corporation (WCNOC) is utilizing the 1989 Edition of ASME Section XI for the second ten year inservice inspection and repair / replacement programs at Wolf Creek Generating Station (WCGS).
Code Case N-508-1 provides an alternative to the current ASME Code Section XI Article IWA-7000 requirements when removing snubbers or pressure relief valves for testing.
The Code Case allows snubbers and relief valves to be rotated from stock and installed on components within the Section XI boundary without utilizing the Section XI IWA-7000 administrative and documentation requirements, provided all the requirements stated in the Code Case are met.
WCNOC will comply with all requirements of Code Case N-508-1.
As detailed below, the use of the Code Case provides an acceptable alternative to the existing requirements of Section XI IWA-7000, while reducing the documentation and personnel review time which is associated with ASME Section XI replacement activities in accordance with IWA-7000.
Basis for Relief and Proposed Alternativer When a snubber or relief valve is removed for the purposes of testing and when adequate spares are available, WCNOC rotates a replacement item into its place and tests the removed item at a later time.
This enables WCNOC to minimize the time that the system is inoperable or out of service, instead of removing the item and testing it while the system is not available and then reinstalling it.
Currently, this activity is required to be treated as a Section XI replacement activity meeting the requirements of IWA-7000.
The provisions of IWA-7000 require the use of a Repair / Replacement Program, preparation of a Replacement Plan and NIS-2 form, performance of specific Section XI reviews and evaluations, and review and concurrence of the Authorized Nuclear Inspector.
These provisions are appropriate when items are replaced due to design changes or nonconformances, but as indicated by the industry and ASME with the issuance of Code Case N-508, these provisions are excessive for the removal and installation of snubbers and relief valves solely for the purpose of testing.
Whether performing the rotation of the item in accordance with IWA-7000 or in accordance with Code Case N-508-1, (1) a work package will be prepared to ec.atrol the work of removing the item and installing the replacement item from spares; (2) upon installation, the replacement item from spares will receive the required inspections and tests; (3) the removed item will be tested in accordance with the WCNOC test programs (for snubbers this is the Updated Safety Analysis Report (USAR] snubber test program, previously located in the Technical Specifications, and for pressure relief valves this is the Inservice Testing (IST) program) ; (4) the work package, and for snubbers the Managed Maintenance data base, will provide the method of tracking the required inspections and tests; and (5) if the removed item requires any repair or replacement activity, those activities will be performed in accordance with Section XI IWA-4000 or IWA-7000.
As required by the Code Case, if the item being removed shows evidence of failure, Code Case N-508-1 is not acceptable to be used, and the removal will be performed and documented in accordance
httachment to CO 96-0104 Pacje 2 of 2 with IWA-7000.
Because of the provisions in the Code case, the alternative use of the case eliminates only the administrative controls and documentation requirements associated with a Section XI replacement.
All other aspects of the replacement, such as
- design, construction, testing requirements, operational limits, and settings, would still be maintained when using the Code case.
As required by the Code Case, items being removed and the replacements being installed from spares are to be of the same design and construction.
WCNOC will implement this requirement in a manner that ensures that the item being removed and the replacement item are comparable in their design, construction, and operating parameters to the extent that installation can be performed without requiring a design or configuration change.
Where the current design has previously been changed to evaluate and accept alternative items t. with changes in model, size, manufacture, capacity or design specification, and the current design allows these alternative items that meet the design requirements for that location, WCNOC considers any of the acceptable alternatives to be "of the same design and construction."
Code Case N-508-1 does not alter any Section XI requirements if the removed item requires any repair or replacement of the item's Code parts or materials.
As required by paragraph (i) of Code Case N-508-1, repair or replacement of Code parts or materials, if required, shall be performed in accordance with IWA-4000 for repairs or IWA-7000 for replacements.
Because of this requirement, if the removed item requires a repair or replacement of Code items contained in the removed item, then this activity will be a Section XI repair or replacement, in accordance with IWA-4000 or IWA-7000, and the required Section XI documentation will be generated.
WCNOC has a snubber service life monitoring program contained in the USAR (previously contained in the Technical Specifications) which requires inspection and testing of snubbers.
Snubbers are tracked by serial number and are tracked independently from the Section XI Repair / Replacement Program. Use of Code Case N-508-1 will have no impact on the implementation of that program.
The program will continue to meet all requirements contained in the USAR.
==
Conclusion:==
For the reasons identified above, WCNOC considers the alternative provisions of Code Case N-508-1 to be a reasonable alternative to the existing requirements of ASME Section XI.
Because the use of the alternative affects only the administrative and documentation requirements of Section XI, WCNOC considers this alternative to provide an acceptable level of quality and safety.
CASE r
N-508-1 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: May 11,1994 See Numericalindex for expiration and any reaffirmation dates.
Case N 508-1 (b) Items being removed shall have no evidence of Rotation of Serviced Snubbers and Pressure Relief failure at the time of removal; Valves for the Purpose of Testing (c) Items being rotated shall be removed and Section XI Division 1 installed only by mechanical means; (d) Items being installed shall previously have Inquiry: What alternative rules to those stated in been in service; IWA-4000 (IWA-7000 for, Editions and Addenda (e) Preservice inspections and pressure tests shall prior to the 1991 Addenda) may be used when, for be performed as required by IWA-4000 (IWA 7000 the purpose of testing, snubbers and pressure relief for Editions and Addenda prior to the 1991 Adden-valves are rotated from stock and installed on com-da);
ponents (including piping systems) within the Section (f) The Owner shall maintain a method of tracking XI boundary?
the items to ensure traceability of inservice inspec-tion and testing records; Reply: It is the opinion of the Committee that, as (g) Use of an NIS-2 form is not required except as an alternative to the provisions of IWA-4000 (IWA-provided in (i) below; 7000 for Editions and Addenda prior to the 1991 (h) Testing of removed snubbers and pressure re-Addenda) and for the purpose of testing, snubbers lief valves, including required sample expansions, and relief valves may be rotated from stock and in-shall be performed in accordance with the Owner's stalled on components (including piping systems) test program; within the Section XI boundary provided the follow-(i) Repair or replacement of removed items, when ing requirements are met:
required, shall be performed in accordance with (a) Items being removed and installed shall be of IWA-4000 (IWA-4000 or IWA-7000 for Editions and the same design and construction; Addenda prior to the 1991 Addenda).
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