ML20199B037
| ML20199B037 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/22/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20199A341 | List: |
| References | |
| NUDOCS 9801280166 | |
| Download: ML20199B037 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION i
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j SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 1
OF REQUESTS FOR RELIEF RR 27 l
i JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 j
SOUTHERN NUCLEAR OPERATING COMPANY. INC.
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DOCKET NOS. 50 348 AND 50-364 1.0 INTRODUCTlON i
I Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, requires that inservice inspection (ISI) of certain American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code) Class 1,2, and 3 components shall be performed in accordance with Section XI of the applicable Edition and Addenda as required by 10 CFR 50.55a(g) excopt where specific written relief has been requested by the licensee and granted l
by the Commission pursuant to 10 CFR 50.55a(g)(6)(l). In 10 CFR 50.ti5a(s)(3)it states that 1
ottomatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if:
(1) the proposed alternatives provide en acceptable level of quality and safety, (2) compliance i
would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The provisions of 10 CFR 50.55a authorize the Commission to grant relief
' from, and authorize alternativen to, ASME Code requirements upon making the necessary findings.
L 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 l
g 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 regulations require that inservice examination of components and system pressure tests conducted during the first ten year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by l
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_ reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120 month interval, subject to the limitations and modifications listed therein. The Southem Nuclear Operating Company, Inc. (SNC) ISI program is based on the repair and replacement requirements of Section XI of the ASME Code,1989 Edition.
Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an i
examination requirement of Section XI of the ASME Code is not practical for its facility, mformation 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
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altomative requirements that are determined to be authorized by law, will not endanger life,
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2-property, or the common defense pod security, and are otherwise in the public interest, giving
- due consideration to the burden upon the licensee that could result if the requirements were t
imposed.
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By letter dated November 18,1997, SNC requested approval to use an attemative to the requirements of the ASME Code,Section XI, paragraph IWA 5242(a) for the removal of insulation from Class 1 systems, borated for the purposes of controlling reactivity, prior to performing the Code-required VT 2 visual examinations on pressure-roteining bolted connections, for Farley Units 1 and 2. SNC based its requests on its belief that the attemative provides an scooptable level of quality and safety.-
t 2.0 RELIEF 8tEQUEST l
4 These relief requests (RR 27) for both Farley Units 1 and 2 request relief from the requirements of Section XI, paragraph IWA 5242(a) of the 198g Edition of the Code, for insulated Code Class 1 bolted connections borated for the purposes of controlling reactivity, d
2.1 Licensaa's Ramla and Justification for RequestM.Rehaf i
SNC believes that the attematives given in the relief requests will eliminate nuclear and personnel safety concoms. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time will allow adequate time for any leakage to penetrate the insulation, thereby providinc a means of detecting any significant leakage with the l.
insulation in place. Also, bonc acid residue will be detected when the insulation is removed I
during each refueling outage. SNC believes that these requests are justifiable under 10 CFR 50.55a(s)(3)(i) because the altomative examinations given in the relief requests provide an i
acceptable level of quality and safety for Class i bolted connections.
2.2 Evaluation The staff has evaluated the following information provided by SNC in support of its requests for i
relief for Farley Units 1 and 2.
Requests for Relief RR 27: For systems borated for the purpose of controlling reactivity, the 1989 Edition of ASME Code Section XI, paragraph IWA 5242(a), requires the removal of insulation from pressure retaining bolted connections for VT 2 visual examination during system pressure tests. Pursuant to 10 CFR 50.55a(s)(3)(i), SNC has proposed an altomative to the.
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provisions of IWA 5242(a). SNC's attemative is stated:
Mistnate Examinatior): Insulated Class 1 pressure-rotalning bolted connections will be c
uninsulated and VT 2 examined once each refueling outage while the connections are at
-- atmospheric or static pressures. The bolted connections will subsequently be examinec' (after_the insulation is re-installed) during the gularly scheduled system pressure test it
- conducted at nominal pressure and at [or) ncar operating temperature. This reexamination will be conducted no earlier than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reaching nominal system operating pressure.
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3-t The Code requires the removal of all insulation from pressure-retaining bolted connections in i
systems borated for the purpose of controlling reactivity when performing VT 2 visual examinations during system pressure tests. As an altemative, SNC has proposed to remove insulation and VT 2 examine insulated pressure-retaining bolted connections at atmospheric or j
- static pressures each refueling outage for Class 1 components, and to perform a separate, direct, VT 2 re-examination at nominal operating pressure and at or near operating temperature t
with the insulation in place. This reexamination will be conducted no soriier than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after i
reaching nominal system operating pressure.
SNC's proposed altemative for Class 1 systems is essentially the same as that contained in
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Code Case N 533, AMemative Requirements Ibr VT-2 Visual Examkation of Class 1 Insulated v.'
Pressure-Retaining Boned Connections,Section XI, DMalon 1, which is currently under review.
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.by the staff and has not yet been approved for use by incorporation into Regulatory Guide
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1.147, inservice inspection Code Case Acceptab##y. However, the staff finds the use of the -
Code Case acceptable if SNC proposes to use a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time on Class 1 insulated systems, as is provided in RR 27.
SNC's proposed altemative for Code Class 1 systems provides a reasonable approach for l
ensuring the leak-tight integrity of systems borated for the purpose of controlling reactivity. The l
relief request applies a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> hold time during the pressure test to allow time for any leakage i
- to penetrate the insulation. This provides a means of detseting any significant leakage with the insulation in place. Secondly, by removing the insulation each refueling outage, SNC will be able to detect minor leakage that could occur by the presence of boric acid crystals or residue.
This two-phase approach provides an acceptable level of quality and safety for bolted
.. connections in borated systems.
.J.0 CONCLUSIONS The staff has reviewed SNC's submittal and has determined that for requests for relief RR 27, for Farley Units 1 and 2, the licensee's proposed altemative provides an acceptable level of quality and safety. Therefore, pursuant b 10 CFR 50.55a(s)(3)(i), the licensee's proposed altemative contained in requests for relief RR 27 is authorized for the Farley Units 1 and 2.
I PrincipalContnbutor: W.Gleaves Date:
January 22.-1998-D b
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