ML20202B431
| ML20202B431 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 01/26/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20202B426 | List: |
| References | |
| NUDOCS 9901290080 | |
| Download: ML20202B431 (5) | |
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UNITE 3 STATES -
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g NUCLEAR REGULATORY COMMISSION wasumorow, p.c. sesamosoi SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO A REQUEST TO USE ASME CODE CASE N-5DS-j IES UTILITIES INC.
DUANE ARNOLD ENERGY CENTER DOCKET NUMBER: 50-331
1.0 INTRODUCTION
The techrucal specifications for the Duane Amold Energy Center (DAEC) 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 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(s)(3) states that attematives to the requirements of paragraph (g) may be used, when authorized by the 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 difficulty 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 incorporated 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. The applicable ASME Code,Section XI, for the third inspection interval of the Duane Amold Energy Center, is the 1989 Edition. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examinabon 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 9901290000 990126 PDR ADOCK 05000331 G
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alternative 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 September 29,1998, as supplemented on December 15,1998, IES Utilities (licensee) submitted a request for relief from the ASME Code,Section XI, paragraph IWA-7000 requirements for the removal and installation of snubbers and relief valves solely for the purpose of testing. Specifically, the licensee requested approval to implement ASME Code Case N-508-1," Rotation of Serviced Snubbers and Pressure Relief Valves for the Purpose of Testing." The staff has reviewed and evaluated the licensee's request for relief and the proposed alternative, pursuant to 10 CFR 50.55a(a)(3)(i) for the Duane Arnold Energy Center third 10-year inspection interval.
2.0 DISCUSSION
System / Component (s)
Code Classes:
1,2, and 3
References:
IWA-7000 ASME Code Case N-508-1 Examination Categories:
N/A Item Numbers:
N/A
==
Description:==
Rotation of serviced snubbers and pressure relief valves for the purpose of testing Component Numbers:
All Class 1,2 and 3 snubbers and pressure relief valves subject to testing Code Reauirement IWA-7000 requires that snubber and pressurs relief testing rotation activity be performed in compliance with a Repair / Replacement Program. The program requires the preparation of a replacement plan, completion and submittal of a Code Form NIS-2, and an evaluation, review and concurrence by an Authorized Nuclear inspector.
Licensee's Basis for Alternate Examination:
Per ASME Section XI, the rotation of snubbers and relief valves is required to be treated as a Code replacement that must meet the requirements of IWA-7000.
l This necessitates the use of replacement programs and plans, review and l
concurrence by the ANil, and maintenance of NIS-2 forms or other Section XI documentation to record the replacement. Such controls are appropriate when items are replaced for the purpose of design changes, failures, or expiration of component life, but are excessive for the removal and installation of snubbers and relief valves solely for the purpose of testing.
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5 The use of Code Case N-508-1 eliminates the inappropriate administrative controls and documentation requirements associated with an ASME Section XI replacement, while maintaining aspects such as design, manufacture, ASME Section XI pressure testing requirements, operational limits and settings.
Code Case N-508-1 does not alter any Section XI requirements if a removed item requires any repair or replacement of Code parts. As required by paragraph (i) of the Code Case, repair or replacement of the removed item, when required, shall be performed in accordance with IWA-4000 for repairs and IWA-7000 for replacements. This ensures that, if the removed item requires the repair or replacement of a Code item, the activity will be treated as a Section XI repair or replacement, and the required Section XI documentation will be generated.
The use of ASME Code Case N-508-1 as an attemative to IWA-7000 for the rotation of snubbers and relief valves for the purpose of testing provides a reduction in inappropriate administrative requirements and documentation.
Technical requirements (e.g., design, fabrication, installation and testing) are still maintained in a manner that provides an acceptable level of quality and safety that is consistent with the criteria of ASME Section XI. Pursuant to 10 Cf'R 50.55a(a)(3)(i), authonzation to use Code Case N-508-1 is requested on the basis that the proposed attematives provide an acceptable level of quality and safety.
Licensee's Altemate Examination-As an attemative to existing Section XI requirements, the DAEC will implement the attemative requirements of Code Case N-508-1 when rotating snubbers and pressure relief valves for the purpose of testing.
ASME Code Case N-508-1," Rotation of Serviced Snubbers and Pressure Relief Valves for the Purpose of Testing," provides attemative rules to those stated above for the purpose of testing snubbers and relief valves. The attemative requires the following:
(a) items being removed and installed shall be of the same design and construction; (b) Items being removed shall have no evidence of failure at the time of removal; (c) Items being rotated shall be removed and installed by mechanical means; (d) Items being installed shall previously have been in service; (e) Preservice inspections and pressure tests shall be performed as required by IWA-7000; (f) The Owner shall maintain a method of tracking the items to ensure traceability of inservice inspection and testing records, (g) Use of an NIS-2 form is not required except as provided in (i) below; (h) Testing of removed snubbers and pressure relief valves, including required sample -
expansions, shall be performed in accordance with the Owner's test program; (i) Repair or replacement of removed items, when required, shall be performed in accordance with IWA-4000 or IWA-7000.
3.0 EVALUATION
Currently, the ASME Code,Section XI, Article IWA-7000, requires that snubber and pressure relief testing rotation activity be performed in compliance with a Repair / Replacement Program. The program requires the preparation of a replacement plan, completion and submittal of a Code Form NIS-2, and evaluation, review and concurrence by an Authorized Nuclear Inspector. The licensee considers these Code provisions appropriate when the components are replaced due to design changes or nonconformanms, but excessive for the removal and installation of snubbers and pressure relief valves solely for the purpose of testing.
Code Case N-508-1 provides an attemative to the current IWA-7000 requirement to generate a Repair / Replacement Program when removing snubbers or pressure relief valves from a system for testing. The Code Case allows snubbers and pressure relief valves to be rotated from stock and
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installed on components and piping systems within the Section XI boundary, provided all the requirements stated in the Code Case are met. The licensee intends to meet all of the Code Case j
requirements.
l Although Code Case N-508-1 does not require the use of NIS-2 forms other than for repair or replacement of removed items in accordance with IWA-4000 or IWA-7000, this will not affect the traceability of snubbers in the DAEC Service Life Monitoring Program. NIS-2 forms are not normally used for tracking purposes in that program. The DAEC Service Life Monitoring Program consists of several elements. These elements include: (1) a " Snubber Useful Life Listing," which identifies the useful life at each snubber location based on manufacturer's recommendations, seat life studies, l
system vibration, environmenta! conditions, and inservice history; (2) a snubber database that allows retrieval of maintenance / testing inforrnation by either location or snubber serial number; (3) a DAEC database used to retrieve information on work packages; and (4) surveillance test procedures used to document the results of service life monitoring.
In addition, traceability of removed snubbers from their supported systems is maintained through the DAEC Technical Requirements Manual (TRM), a licensee-controlled document referenced in the Updated Final Safety Analysis Report (UFSAR). The TRM contains limiting conditions for operation (LCOs), surveillance requirements, and required actions for snubbers. If a snubber is removed for testing, the snubber must be retumed to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or the system (s) supported by the snubber must be declared inoperable. Wrth one or more snubbers inoperable (i.e., properly fabricated, installed, and sized, but which cannot pass the functional tesi), TRM required actions include the replacement or restoration of the snubber to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the determination that the supported component is acceptable for continued operation within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The licensee's proposed afternative to use the Code Case for the purpose of snubber and pressure relief valve rotation associated with testing will eliminate unnecessary administrative and documentation requirements while maintaining all technical requirements. Therefore, the proposed attemative will provide an acceptable level of quality and safety.
4.0 CONCLUSION
Based on its review, the staff concludes that the proposed attematives of Code Case N-508-1,
- Rotation of Serviced Snubbers and Pressure Relief Valves for the Purpose of Testing," will provide an acceptable level of quality and safety. Therefore, tne licensee's request to implement the l
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5-alternatives provided in Code Case N-508-1 is authorized pursuant to 10 CFR 50.55a(a)(3)(i). Use l
of Code Case N-508-1 is authorized for the third 10-year interval of the Duane Arnold Energy Center until such time as the Code Case is approved by reference in Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this Code Case, the licensee is to follow all provisions in Code Case N-508-1 with any limitations issued in Regulatory Guide 1.147.
PrincipalContributor: R.Laufer Date: January 26, 1999 m
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