ML20153D259
| ML20153D259 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/21/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20153D257 | List: |
| References | |
| NUDOCS 9809250005 | |
| Download: ML20153D259 (4) | |
Text
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UNITED STATES p
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. =a "1
.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ALTERNATIVE CONTAINMENT PRESSURIZATION TEST POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCl FAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
The Technical Specifications (TSs) for the James A. FitzPatrick Nuclear Power Plant state that the inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1,2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (ASME Code) and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).10 CFR 50.55a(a)(3) states that altematives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if (i) the proposed attematives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 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 pre-
' service 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 regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorpcrated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose attemative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed. In a letter dated August 7,1998, the Power Authority of the State of New York (the licensee, also known as the New York Power Authority), requested that the NRC staff approve Enclosure 9809250005 980921 PDR ADOCK 05000333 P
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4 an altemative to the requirements of the ASME Code,Section XI pertaining to testing of the FitzPatrick containment.
2.0 EVALUATION The licensee submitted the subject request to use an alternative to the requirements of ASME Code,Section XI. The Code of record for the third interval is the ASME Code,Section XI,1986 Edition. The information provided by the licensee in support of the request has been evaluated and the bases for disposition are documented below.
2.1 Code Reauirement: Section XI, paragraph IWE-5221 states:
Except as noted in IWE-5222, repairs or modifications to the pressure retaining boundary or replacement of Class MC or Class CC components shall be subjected to a pneumatic leakage test in accordance with the provisions of Title 10, Part 50 of the Code of Federal Regulations, Appendix J.
2.2 Licensee's Code Relief Reauest:' Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee requested relief from the requirement to perform post repair testing of the FitzPatrick containment as re, quired by IWE-5221.
4 2.3 Licensee's Basis for Reauestina Relief (as stated):
The intent of 10CFR50 Appendix J is to ensure that the potential leakage of containment air to the atmosphere following a design basis accident is maintained below established limits by the performance of pneumatic leakage tests. The Type A ILRT requires extensive preparation in terms of system line-ups and installation of temporary instrumentation, as well as a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of pressure stabilization and temperature equalization, followed by leakage testing and verification at all penetrations in the containment structure. The cutting and re-installation of the planned temporary hatch in the torus shell will not impact air leakage out of the conteinment and 4s penetrations. The concems relating to cutting and re-installation of the te
. ary hatch are those of pressure vessel structural integrity and water leak t.,
oss. Since the temporary hatch repair is located completely underwater, the repaired area is water sealed against any potential air leakage. Based on the above, the requirements of 10 CFR 50, Appendix J, Option B do not apply. Therefore, an exemption to Appenoix J or a Technical Specification (TS) change is not required.
The proposed alternative testing is to pressurize the containment air volume to a minimum of 45 psig, hold that pressure for a minimum of one hour while performing a VT-2 examination of the repair area for water leakage and structural integrity. This test pressure is, as specified in TS Section 6.20.A, the peak primary containment internal pressure for the design basis loss of coolant accident. This test will subject the repair area to both the 45 psig containment air pressure and the static pressure of the standing head of water associated with a torus water level specified in the TS (i.e.,13.88 feet to 14.00 feet).
- The proposed alternative testing is also justified due to the engineering controls and non-destructive testing that will be performed in conjunction with the cutting i
2 and re-installation of the temporary hatch in the torus shell. The cut will be made outside of the area of the temporary hatch repair made in 1981. This will assure that both the condition of the shell in that location will be characterized and that the cut / repair will be outside of the heat affected zone of the previous repair.
The shell repair will attempt to reuse the plate cut from the torus shell. New plate material will be purchased and used, if required. The new plate material will be fabricated to meet, as a minimum, the same specifications as the existing torus shell and will be curved to match the radius of the torus shell at the location of the temporary hatch.
j The shell repair will be performed in accordance with the 1992 Edition with the a
1992 Addenda of Section XI Subsection IWE of the ASME Code.
Volumetric examination of 100% of the weld and adjacent weld area will be i
performed on the final weld joint. Additionally, surface examination of weld preparations on the shell and hatch pieces to be welded and visual and surface examination of the completed weld will be performed. The weld will be performed l
utilizing a welding procedure specification and materials qualified to meet notch J
toughness requirements of the original code of construction. This will assure that y
the integrity of the weld meets or exceeds current industry standards as well as j
that of the existing torus shell. Industry experience has shown that the current j
state of the art non-destructive testing techniques provide an accurate determination of the integrity of structural welds.
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The performance of a pressure test on the containment provides an acceptable level of assurance of the quality of the repair and adequately demonstrates the structuralintegrity of the containment. Therefore, the relief requested is justified.
2.4 Licensee's P.coosed Alternative Examination (as stated):
The Authority proposes to perform attemative testing to that specified in IWE-5221. The proposed attemative testing to verify structural integrity and water tightness will be to perform a pressure test of the entire containment (Drywell and Pressure Suppression Chamber) including the affected torus area. This pressure test will be performed at a torus water level specified by the TS. This test will consist of pneumatically pressurizing the containment air volume to a minimum pressure of 45 psig, which is, as specified in TS Section 6.20.A, the peak primary containment internal pressure for the design basis loss of coolant accident. The containment will be held at the test pressure of 45 psig for a minimum of one hour during which a VT-2 inspection will be performed on the torus shell to verify that there is no leakage or structural deformation. The VT-2 inspection will be done in accordance with the 1989 ASME Section XI Code.
)
< The licensee has requested relief from the Code requirements to perform leakage test following repair as required by IWE-5221 of ASME Code,Section XI. The licensee is proposing to perform an alternative testing of the FitzPatrick torus. The need for the testing occurred because during an upcoming refueling outage, FitzPatrick will be replacing the suction strainers for the emergency core cooling and reactor core isolation cooling systems within the torus. The licensee has determined that by cutting a temporary hatch in the torus wall, personnel access and movement of tools and equipment will be improved, and radiation exposure and physical stress will be reduced.
The temporary hatch will be made by cutting and removing a section of torus shell. The location for the hatch was selected based on ease of access, and to ensure that the cut is outside the heat-affected zone of welds made to re-install a previous temporary hatch. The location of this entire hatch will be below the norms! and post-accident water line in the torus.
Pursuant to 10 CFR 55a(a)(3)(i), FitzPatrick is proposing to perform attemative testing to that specified by IWE-5221, which requires a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pressure stabilization, temperature equalization, followed by leakage testing and verification of all containment penetrations, as well as extensive test preparations. The proposed attemative testing to verify structural and water leak tightness would be to perform a pressurization test of the entire containment (drywell and suppression chamber) including the affected torus area with the torus water volume at that specified by Technical Specifications. This pressurization test will consist of pneumatically pressurizing the containment air volume to a minimum of 45 psig and holding that pressure for a minimum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. During the performance of this test, a visualinspection of the torus shell in the area of the repair will be made to verify that there is no visible leakage and/or structural deformation. In addition, the shell repair will be accomplished under the rules of the 1992 Edition with the 1992 Addenda of Section XI Subsection IWE of the ASME Code.
The licensee will perform volumetric examination of 100% of the weld and the adjacent weld area for the final weld joint, in addition, surface examination of weld preparations on the shell and hatch pieces to be welded, and visual and surface examination of the completed weld will be performed. The weld will be performed using procedures and specifications qualified to meet the notch toughness requirements of the original code of construction. These measures ensure that the integrity of the repair meets or exceeds the quality requirements of the existing torus shell.
3.0 CONCLUSION
The NRC staff concludes that the licensee has provided an acceptable altemative to the requirements stated in paragraph IWE-5221 of the ASME Code,Section XI. The staff, therefore, concludes that authorization of the licensee's alternative program would provide an acceptable level of quality and safety, and is, therefore, acceptable. Pursuant tc 10 CFR 50.55a(a)(3)(i), the alternative is authorized.
Principal Contributor: J. Williams Date:
Septe m ber 21,1998