ML20153B244
| ML20153B244 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/17/1988 |
| From: | Capra R Office of Nuclear Reactor Regulation |
| To: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| References | |
| RTR-REGGD-01.147, RTR-REGGD-1.147 TAC-67353, NUDOCS 8803210557 | |
| Download: ML20153B244 (4) | |
Text
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March 17, 1988 L
Docket No. 50-318 DISTRUBTION
' Docket / Tile [
CVogan NRCPDR SMcNeil local PDR LTripp Mr. J. A. Tiernan PDI-I Rdg.
MPartzman Vice President-Nuclear Energy TMurley/Sniezek LMarsh Baltimore Gas and Electric Comoany FMiraglia 0GC-WF P.O. Box 1475 CRossi Edordan Baltimore, Maryland 21203 S7arga JPartlow P>Poger GPA/PA
Dear Mr. Tiernan:
SUBJECT:
AUTHORIZATION TO USE ASME ROILER AND PRESSURE YESSEL CODE CASE N-416 (TAC 67353)
The Commission staff has ccmpleted their review of your requests for NRC approval to use the ASME Boiler and Pressure Vessel Code Case N-416 ac provided in your submittals dated February 26, 1988 and March 14, 1988. The February 26, 1988 request was made in preparation of your upcoming inspection of the two inch ASME Code Class 2 bottom blowdown piping that is unisolable from the No 's 21 or 22 steam generators, scheduled for the February 27 - March 21, 1988 Unit 2 outage.
If repair or replacement of this two inch piping is required, it must be performed in accordance with the requirements of Articles IWC-3000, IWA-4000 i
and/or IWA-7000 of Section XI of the 1983 Edition of the ASME Code.
The March 14, 1988 request to use Code Case N-416 was made after determining that two 16-inch check valves (2FW-130 and 2 W-133), which are unisolable from t Mir associated Unit 2 steam generators, rust be repaired or replaced.
The ma feedwater oiping affected is Class 2 piping.
i Following repair or replacement of a sect on of Class 2 piping, you are required by IWA-4400 to perform a hydrosta tic pressure test on the portion of pig repaired or replaced. Your requests statet that the performance of this hydrostatic pressure test would be impractical as these lines of pipe (steam generator bottom blowdown and main feedwater) are unisolable from thair associated steam generators, thus the = team generator would experience an unnecessary pressure transient above its design pressure as a result of the hydrostatic pressure test.
The operational lifetime of the steam generator is limited by the number of times it is permitted to be hydrostatically pressure tested, cycling above its design pressure. Consequently, you have requested NRC approval in accordance with 10 CFR 50.55a(a)(3) to use ASME Code Case N-416 in lieu of performing the required hydrostatic pressure test.
Footnote 6 to 10 CFR 50.553 permits the use of Code Cases, in addition te those accepted in Regulatory Guide (R.G.) 1.84 or R.G. 1.85 090n authorization L the Director of the Office of Nuclear Reactor Regulation upon request pursuant to Section 50.55a(a)(3). Alternatives to the requirements of Section XI of the
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ASME Code ar9 permitted by 10 CFR 50.55a(a)(3) if the applicant can demonstrate that (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements of this section would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
R.G.1.147, D.evision 5, "Inservice Inspection Code Case Acceptability ASME Section XI Division I," dated August 1986, lists Code Cases that are generally acceptable to the NRC staff for implementation in the inservice inspection of light-water cooled nuclear power plants.
Code Case N-416 is endorsed in R.G.
1.147 with no exceotions taken by the NRC staff to the Code Case.
This Code Case states that following repair or replacement of Class 2 piping that cannot be isolated by existing va.1ves or that requires securing safety or relief valves for isolation, the deferral of Class 2 cipinp hydrostatic pressure tests is permitted until the next regularly scheduled system hydrostatic pressure test. This deferral is contingent upon the performance of the appropriate NDE weld examination and of a visual examination for leakage prior to or immediately upon return to service.
These alternative examinations will provide an adequate assurance of the integrity of the welds in the Class 2 piping ir, question until the performance of the next required system hydrostatic pressure test.
Your February 26, 1988 and March la,1988 requests justified the use of Code Case N-416 in accordance with the provisiens of 10 CFR 50.55a(a)(3) by stating that requiring the performance of this hydrostatic pressure test would result in t
hardship without a compensating increase in the level of quality and safety due to the fact that these lines are unisflable from the associated steam generators, and consequently. the steam generator would undergo a pressure transient above its design pressure that would reduce the operational lifetime of the steam generator. Through R.G. 1.147, the NRC staff has stated that the deferral of this hydrostatic pressure test is acceptable for Class 2 piping contingent upon the perforF inte of the alternate tests required in Code Case N-416, i
The NPC staff understands that yo: thall perfonn the V~t-2 vi?ual examination for leakage and the Article IWA-2220 surface examinatiord for partial penetration welds or the Article IWA-2230 volumetric examinations for full penetration welas as provided in Code Case N-416.
Furthermore, sny lines repaired or replaced shcIl be hydrostatically tested at the next regularly scheduled system nydrostatic test.
The staff has determined in accordance with the provisions of 10 CFR 50.55a(a)(3) that your reouest for authorization to use Code Case N-416, for the two inch ASHE Code Class ? steam generator bottom blowdown pipe that is unisolable from its associated steam generator and for valves 2FW-130 and 2FW-133 in the main feedwater system, provides an acceptable 1 M 1 of quality and safety and that requiri':g the performance of the sy ntm hydrostatic pressure test prior to the next regularly scheduled test would j
result in a hardship without a compensating increase in the system's level of quality and safety. Thus, the staff has determined that this request is i
t acceptable.
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This letter shall serve as authorization of your request to use Code Case N-416 in lieu of performing the hydrostatic pressure test on the No.'s 21 or
?? steam generator bottom blowdown lines and on main feedwater valves 2FW-130 and 2FW-133 as required by Article IWA-4400 of Section XI of the 1983 Edition of the ASME Code if the line is repaired or replaced.
The Commission hereby authorizes this use of ASME Code Case N-416 for this portion of Class ? piping pursuant to 10 CFR 50.55a(a)(3) and finds that this use of proposed alternatives to Article IWA-4400 (1) provides an acceptable level of quality and safety and (2)'that compliance with the Article IWA-4400 rcquirements would pose utidue hardship not compensated by the resultant increase in quality and safety.
l Sincerely, i
Robert A. Capra, Director Project Directorate I-1 Division of Reactor Projects, I/II 1
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Mr. J. A. Tiernan Raltimore Gas A Electric Company Calvert Cliffs Nuclear Power Plant ec:
Mr. John M. Gott, President Regional Administrator, Region I Calvert County Board of (l.S. Nuclear Regulatory Commission Connissioners 475 Allendale Road Prince Frederick, Maryland 2n?68 King of Prussia, Pennsylvania 19406 D. A. Brune Esq.
General Counsel Baltimore Gas and Electric Company P. O. Box 1475 Baltimore, Maryland ?l203 Jay E. Silberg, Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, NW Washington, DC ?0036 Mr. M. E. Bowman, General Supervisor Technical Services Er.gineering Calvert Cliffs Nuclear Power Plant MD Rts ? E 4, P. O. Box 1535 Lusby, Maryland 20657-0073 Resident Inspector c/o U.S. Nuclear Regulatory Commission P. O. Box 437 Lusby, Maryland 20657-0073 8echtel Power Corporation ATTN: Mr. D. E. Stewart Calvert Cliffs Project Engineer 15740 Shady Grove Road Gaithersburg, Maryland 20760 Corbustion Engineering, Inc.
ATTN: Mr. W. R. Horlacher, III Project Manager P. O. Box 500 1000 Prospect Hill Road Windsor, Connecticut 06095-0500 Department of Natural Resources Energy Administration, Power Plant i
Siting Program ATTN: Nr. T. Magette i
Tawes State Office Building i
Annapolis, Maryland 21204 r
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