ML20203G003
| ML20203G003 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/25/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9803020146 | |
| Download: ML20203G003 (3) | |
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Cuct t a 11. C::tu lliitimore Cm end Liectric Company Cah en Clifh Nuclear l'ow er I'lant Vke President 1650 Cahert Clif h l'arkw ay Nuclear 1.nergy Lusby, Mary land 20657 410 495-4435 February 25,1998 U. S. Nuclear Regulatory Commission Washingtci, DC 20$55 ATTENTION:
Document Control Desk SUIUECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50 318 Relief Request to Use Code Case N-416-1 as an Alternative to AShiE Section X! Code Requhementi
REFERENCES:
(a)
Letter from Mr. R. A. Capra (NRC) to Mr. G. C. Crect (IlGE), dated January 11, 1990, Approval of Second Ten Year Inservice inspection Program Plan for Calvert Cliffs Unik I and 2 (Unit 1 TAC 67094; Unit 2 TAC No. 67095)
(b)
Drall Regulatory Guide DG 1050 (Revision 12 to Regulatory Guide 1.147), inservice inspection Code Case Acceptability ASME Section XI, Division 1, February 1997 Pursuant to 10 CFR 50.55a(a)(3)(i), llaltimore Gas and Electric Company hereby proposes an alternative to the American Society of Mechanical Engineers (ASME) floiler and Pressure Vessel Code (Code) requirement concerning the Calvert Cliffs Nuclear Power Plant Repair / Replacement pressure testing of Code Class 1,2, and 3 components for the Second Ter Year Inservice inspection (ISI) interval. Calvert Cliffs Yechnical Speci0 cation 4.0.5 states in part," Inservice inspection of ASME Code Class I,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 $0, Section." 55a(g).... "
Paragraph 50.55a(a)(3)(i) allows the use of alternativa to the requirements of Paragrapn 30.55a(g), that provide an acceptable level of quality and safety, when authorized by the Director of the Office of Nuclear Reactor Regulation.
The Second Ten Year ist Program Plan for Calvert Cliffs Units 1 and 2 meets the requirements of the p
1983 Edition, Summer 1983 Addenda of Section XI of the ASME Code, as approved by Nuclear J r xp '/
Regulatory Commission (NRC) letter dated January 11,1990 (Reference a). Subsection IWA in ' '
Section XI describes the general requirements for Repairs and Replacements, including examination and pressure testing. As an alternative to the hydrostati: pressure testing requirements of IWA-4000, llattimore Gas and Electric Company proposes to use ASME Section XI Code Case N-416-1, which 9003020146 90022S ^
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Document Control Desk February 25,1998 Pa'ge 2 provides alternative pressure testing requirements for welded repairs or installation of replacernents by welding for Class 1,2, and 3 components.
The NRC staff issued Reference (b), which proposed a list of those AShiE Section XI Codo Cases that are generally acceptable to the NRC staff for implementation in the ISI of lity.vect ccoled nuclear power plants. Code Case N 4161 is one of the Code Cases listed in Referme (b) as acceptable to the NRC staff," subject to the following condition in addition to those condition? speellied 'a the Code Case.
Additional surface examinations should be performed on the root (pass) layer i rv,,, and socket welds of trio pressure retaining boundary of Class 3 components when the surface examination method is used in accordance with Section 111."
COMPONENT FOR Wii[Cll_REI.f rF IS REOUESTED
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Clnss 1,2, and 3 Components with welded repairs or replacements installed by welding.
CDDEEQUIREMENTS FOR WillCII RELIEF IS REQUESTED American Society c Mechanical Enginects Code,Section XI,1983 Edition, with the Summer 1983 Addenda, Subsecti a iWA, paragraph IWA 4400, requires a hydrostatic pressure test following repairs by welding or the installation of replacement items by welding. The specific requirements foi hydrostatic pressure testing of Class 1, 2, and 3 components are described in Articles IWH 5000, IWC-5000 and IWD 5000, respectively.
PROPOSED ALTERNATIVl' The alternative to hydrostatic pressure testing provided by AShiE Code Case N 4161, subject to the condition outlined in Reference (b), will be utilized.
American Society of hicchanical Engineers Code Case N-4161 states that, in lieu of a hydrostatic pressure test, a system leakage test may be used provided the following requirements are met.
a) Non destructive examination shall be performed in accordance with the methods and acceptance criteria of the applicable Subsection of the 1992 edition of AShiE Section 111.
b) Prior to or immediately upon return to service, a visual examination (VT 2) shall be performed in conjunctie with a system leakage test, using u.e 1992 edition of Section XI, in accordance with paragraph Iw'A 5000, at nominal operating pressure and temperature, c) Use of this Case shall be documented on an NIS 2 Form.
The condition outlined in Reference (b) is that additional surface examinations should be performed on the root (pass) layer of butt and socket welds of the pressure retaining boundary of Class 3 components when the surface examination method is used in accordance with Section 111.
SUPPORTING INFORMATION American Society of hiechanical Engineers Code Cae N-416-1 is based on research that demonstrated that Section XI hydrostatic test pressures (1.10 to 125 times design pressure) do not provide a meanittgfu' assessment of structural integrity, in lieu of hydrostatic testing. Code Case N 416-1 permits the use of a system leakage test at noanal operating pressure. This system leakage test is, in many ways, superior to a hydrostatic test. For example, a hydrostatic test exposes a system to slow uniform I'
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e Document Control Desk i
l'ebruary 25,1998 l
Pa*ge 3 pressurization under controlled conditions. System pressure is carefully raised, test pressure is held constant for a short period of time (often ten minutes), then the system is depressurized. Conversely, an inservice leakage test exposes a system to heat up, vibration, thermal growth, and various other conditions encountered only during system operatloa. Therefore, st,bstitution of ar. Inservice leakage test for a hydrostatic pressure test is not considered a reduction in requirements.
The performance of hydrostatic pressure testing following welded repairs and installation of replacements by welding could result in additional radiation exposure without a commensurate increase in the level of safety. The additional endiation exposure is due to the activities required for setting up the testing equipment, performance of valve.line-ups, and performance of the actual testing itself. The i
amount of exposure varies greatly depending on the system requiring testing and the complexity and scope of testing required.
SAFErv coMMnTEE REVIEW 3
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1hc proposed relief request has been reviewed by our Plant Operations and Safety Review Committee, and they have concluded that the proposed alternative provides an acceptable level of quality and safety.
s SCIIEDULE During planning for the upcoming Calvert Cliffs Unit I spring 1998 refueling outage (scheduled to begin i
on April 3,1998), we have identifled several jobs that would require hydrostatic pressure testing. We request that the NRC review and approve our proposed alternative for use during this outage.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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for C.11. Cru e Vice President Nuclear Energy CilC/GT/ dim i
cc:
R. S. Fleishman, Esquire
- 11. J. Miller, NRC J. E. Silberg, Esquire Resident inrpector, NRC A. W. Dromerick, NRC R.1. McLean, DNR 4
Director, Project Directorate 1 1, NRC J.11. Walter, PSC
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