ML20199K421

Requests NRC Approval of Encl Relief Requests RR-27 Re Class I Pressure Test Requirements of IWA-5242(a) of 1989 Edition of ASME Section Xi.Relief Requests Will Provide Acceptable Level of Quality & Safety for Class I Bolted Connections

ML20199K421
Person / Time
Site:	Farley
Issue date:	11/18/1997
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9712010118
Download: ML20199K421 (8)

Text

< . I Dave Morey Southern Nuclear Scs Presdent Operating Company f atley Project PO Boa 1295 Bemingham. Alabama 35201

. Tel 2ffs 932.5131 s

SOUTHERN November 18, 1997 COMPANY  !

Energy to Serve hur Wid' l Docket Nos.: 50-348 10 CFR 50.55 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk j Washington, DC 20555 l

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Joseph M. Farley Nuclear Plant Mief Request No. 27 Ladies and Gentlemen:

In accordance with the provisions of 10CFR50.55a(a)(3)(i), Southern Nuclear Operating Company (SNC) is requesting NRC approval of enclosed Re:icf Requests RR-27 (one for Unit I and one for Unit 2) concerning the Class I pressure test requirements oflWA-5242(a) of the 1989 Edition of ASME Section XI. Paragraph IWA-5242(a) requires that for systems borated for the purposes of controlling reactivity, insulation shall be removed from pressure retaining bolted connections prior to performing visual examinations. Thc visual examination are performed each outage during startup with the Class 1 piping and components at normal operating pressure and at near normal operating temperature.

This is a new Code requirement for Farley that becomes efTective on December 1,1997, with the implementation of the 1989 Code. Afler evaluation of this new requirement, SNC believes this requirement to pose both nuclear and personnel safety concerns at Farley. These concerns are:

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1. Loose insulation would be in the containment during a mode in which a LOCA must be /'/

considered. If a LOCA occurred during re-installation of the insulation, the insulation could Systems.

Cooling migrate to the containment sumps and restrict the suction / of f the Eme

2. There are incret. sed hazards for personnel due to the high contact temperature of the bolting and due to the high containment ambient temperature.

SNC believes that use of the alternate examinations delineated in the relief requests will provide an acceptable level of quality and safety for Class I bolted connections, while climinating nuclear and personnel safety concerns. A similar version of this relief request has been approved for use on Class I bolted connections at SNC's Vogtle Electric Generating Plant per the NRC's Safety Evaluation dated October 24,1997. Approvalis requested by 9712010118 971118 Its im if t 11:Hifilli PDR ADOCK 05000348 ll'!HE N 'lailltlidI!Dl'l!!Ill lu.

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l U S. Nuclear Regulatory Commission ' Page 2 February 28,1998, to support pressure testing during the Unit 2 refueling outage, currently scheduled to commence in March 1998. l Ifyou have any questions, please advise.

Respectfully submitted.

SOUTHERN NUCLEAR OPERATING COMPANY b ?llWf Dave Morey M1A/ cit:bolicov. doc

Enclosures:

1. Unit 1 - Third Ten Year Intervs Request for Relief No. RR-27

2. Unit 2 - Updated Program Request for Relief No. RR-27 cc: Mr. L. A. Reyes, Region 11 Administrator -

Mr. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector 4

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l ENCLOSUREI Farley Nuclear Plant - Unit 1 Third TELYratlokm1Brancst for Relief No. RR 27

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. Enclosure 1 Unit i Third 'l en Year interval Rr_qusst for Relief No. RR-27

1. System / Component (s) for Which Reliefis RtQufited Bolted connections located in the Class I reactor coolant system pressure boundary.

II. CodcAtguirrnical: ASME Section XI,1989 Edition, Paragraph IWA 5242(a) requires that for systems borated for the purposes of controlling reactivity, insulation shall be removed from pressure retalning bolted connections prior to performing the visual examination. Table IWB 2500-1, Examination Category B P requires a system leakage test (IWB-5221) and corresponding VT-2 visual examination on Class I components each refueling outage prior to plant startup. Table IWB-25001, Examination Category B-P also requires a hydrostatic test (IWB-5222) and corresponding VT-2 visuel examination be performed on Class I components on a ten year frequency. (Note: FNP intends to use Code Case N-498-1, as requested in Relief Request RR-21 by SNC letter dated May 28,1997, es an alternative to the hydrostatic test).

III. Code RcQuirement for Whicideligfis Regunted: Insulation will not be removed from pressure-retaining bolted connec: ions prior to performing VT-2 visual examinations during the conduct of pressure tests.

IV. llasit.fgr Relief: These system pressure tests are performed during startup when the Reactor Coolant System is at nominal operating pressure and at near operating temperature. The re-installation ofinsulation after the performance of system pressure testing is considered to pose potential nuclear safety and personnel safety issues, as follows.

1. Loose insulation would be in the containment during a mode in chich a LOCA must be considered if a LOCA occunM during re installation of the insulation, the insulation could migrate to the comamment sumps and restrict the suction of the Emergency Core Cooling Systems.

2. There are increased hazards for personnel due to the high contact temperature of the bolting and due to the high containment ambNnt temperature.

V. Alternate Examination: Insulated Class I pressure-retaining bolted connections will be uninsulated and VT-2 examined once each refueling outage while the connections are at atmospheric or static pressures. The bolted connections will subsequently be examined (aller the insulation is re-installed) during the regularly scheduled system pressure test conducted at nominal operating pressure and at near operating temperature. This re-examination 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 ruching nominal system operating pressure.

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linclosure 1 RRt27 - Unit i VI. histiEcation for GrAatiaghliff: The pressure test with 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, providing a means of detecting any significant leakage with the insulation in place. Secondly, by removing

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the insulation each refueling outage, any boric acid residue can be detected. This two-phase approach provides an acceptable level of quality and safety for Class 1 bolted j connections; therefore, the proposed alternative should be authorized pursuant to 10CFR50.S$a(a)(3)(i).

Vll. Impkmentation Scheduk: This request for reliefis applicable to the Third Ten-Year Interval beginning December 1,1997.

Vill. ReliefRequesLSlaitu: This is a new third interval relief request, awaiting NRC approval.

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ENCLOSURE 2 Farley Nuclear Plant - Unit 2 lladattdhegram ikqunLfor ReliefNo RR-27

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- Enclosure 2 Unit 2 Updatedhogram - keouest for Relief No. RR 27 l t

1. System / Component (s) for Which Reliefis Requested: Bolted connections located in the Class I reactor coolant system pressure boundary.  !

i i 11. Cnde.kquitement: ASME Section XI,1989 Edition, Paragraph IWA-5242(a) requires that for systems borated for the purposes of controlling reactivity, insulation .

shall be removed from pressure retaining bolted connections prior to performing the visual examination. Table IWB 2500-1, Examination Category B-P requires a system leakage test (IWB 5221) and corresponding VT-2 visual examination on Class 1 1 components each refueling outage prior to plant startup. Table IWB-2500-1, Examination Category B P also requires a hydrostatic test (IWB 5222) and corresponding VT-2 visual examination be performed on Class I components on a ten year frequency. (Note: FNP intends to use Code Case N-498-1, as requested in Relief Request RR 21 by SNC letter dated May 28,1997, as an alternative to the hydrostatic test). ,

III. Codc.kguitsment for Which Reliefis kgucited: Insulation will not be removed from '

pressure-setaining bolted connections prior to performing VT-2 visual examinations during the conduct of pressure tests.

IV. Dasis for Rdief: These system pressure tests are performed during startup whc, the Reactor Coolant System is at nominal operating pressure and at near operating j temperaturc. The re-installation ofinsulation after the performance of system pressure testing is considered to pose potential nuclear safety and personnel safety issues, as follows:

1. Loose insulation would be in the containment during a mode in which a LOCA must be considered. If a LOCA occurred during re-installation of the insulation, the insulation could migrate to the containment sumps and restrict the suction of the Emergency Core Cooling Systems.

2. There are increased hazards for personnel due to the high contact temperature of the bolting and due to the high containment ambient temperature.

V. AlternatcluminatinD: Insulated Class I pressure-retaining bolted connections will be uninsulated and VT-2 examined once each refueling outage while the connections are l at atmospheric or static pressures. The bolted connections will subsequently be examined (afler the insulation is re-installed) during the regularly scheduled system pressure test conducted at nominal operating pressure and at near operating temperature. This re-examination 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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, . Enclosure 2 RR 27 - Unit 2 VI. Justification for Granting Relief: The pressure test with 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, prosiding a means of detecting any significant leakage with the insulation in place. Secondly, by removing the insulation each refueling outage, any boric acid residue can be detected. This two-phase approach provides an acceptable level of quality and safety for Class I bolted connections, therefore, the proposed alternative should be authorized pursuant to 10CFR50.50, )(3)(i).

VII. Implementation Schtdyle: This request for reliefis applicable to the updated program beginning Deceraber 1,1997.

Vlli. ReliefjltQuest. Status: This is a new relief request, awaiting NRC approval.

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