ML20205G605

SER Accepting Relief Request Re Acme Code Case N-567, Alternate Requirements for Class 1,2 & 3 Replacement Components,Section Xi,Div 1

ML20205G605
Person / Time
Site:	Hope Creek
Issue date:	03/19/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20205G601	List: ML20205G596 ML20205G605
References
NUDOCS 9904070308
Download: ML20205G605 (4)

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, j .. j NUCLEAR REGULATORY COMMISSION WAf s..NGTON, D.C. 20555-0001 ll;rt

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST RELATED TO ASME CODE CASE N 567 FOR PUBLIC SERVICE ELECTRIC & GAS COMPANY HOPE CREEK GENERATING STATION l l

DOCKET NO. 50-354 I l

1.0 INTRODUCTION

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Hope Creek Generating Station (HCGS) Technicsi Specification 4.0.5 states 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 Title 10 of the Code of Federal '

Reaulations (10 CFR) Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Section 10 CFR 50.55a(a)(3) states l that h%ernatives 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 Ed access provisions and the 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 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of the ASME Code,Section XI, incorporated by reference in 10 CFR 50.55a(b) on the date twelve 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 Hope Creek, during the second 10-year inservice inspection (ISI) intervalis 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.

9904070308 DR 990319 p ADOCK 05000354 PDR Enclosure

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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, i pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose l 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.

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By letter dated March 5,1999, Public Service Electric and Gas Company (PSE&G or the licensee), requested approval for implementing the alternative rules of the ASME,Section XI, 1 Code Case N-567, " Alternative Requirements for Class 1,2, and 3 Replacement Components, i Section XI, Division 1," for a specific situation at Hope Creek. The approval of Code Case  !

N-567 was requested for replacing a valve in the containment atmosphere control system with i an identical valve that was constructed to an earlier version of the ASME Code than that of the valve being replaced. The staff has evaluated the provisions of Code Case N-567 as applicable to the replacement valve to ensure that the use of the code case would provide equivalent protection as that of the code to the health and safety of the public and, therefore, the licensee's proposed alternative would provide an acceptable level of quality and safety.

2.0 DISCUSSION

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Component to be Replaced One inch diameter,600# Edward Model 838 YT piston check valve constructed to the ASME Code, Section Ill,1974 Edition including the Summer 1975 Addendum. l l

Replacement Component  !

Identical valve constructed to the ASME Code,1971 Edition including the Summer 1972 ]

Addendum.

Applicable Code Reauirement I l The ASME Code,Section XI,1989 Edition, Subsection IWA-7210 " Code Applicability" for j Replacement, states *(b) Any items to be used for replacement shall meet following l requirements unless the alternative of (c) below is adopted:

(1) the applicable Construction Code to which the original item was constructed; and i (2) the existing design requirements.

If the original item was constructed without Code requirements, the item to be used for .'

replacement shall be in accordance with the design, fabrication, and examination requirements for the originalitem unless the alternatives of (c) below is adopted.

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l (c) Alternatively, an item to be.used for replacement may meet all or portions of the requirements of later editions of the Construction Code or Section ill when the Construction Code was not Section Ill, provided that the following requirements are met.

The requirements affecting the design, fabrication, and examination of the item to be used for replacement are reconciled with the Owner's specification through the Stress Analysis Report, Design Report, or other suitable method that demonstrates the item is satisfactory for the specified design and operating conditions.

(2) Mechanical interfaces, fits, and tolerances that provide satisfactory performance are compatible with system and component requirements.

(3) Materials are compatible with installation and system requirements."

Code Case N-567. Alternative Reauirements for Class 1. 2. and 3 Reolacement ComponentsSection XI. Division 1 As an alternative to the requirements of IWA-7210 stated above, the Code Case N-567 imposes the following requirements to accept a component constructed to an earlier Edition or Addenda than that of the component being replaced.

(a) Any deviation from the Owner's requirements or the original Construction Code of the component being replaced shall be reconciled; (b) A report of the reconciliation shall be prepared and made part of the record in accordance with IWA-6340; and (c) Use of this code case shall be shown on the NIS-2 Form documenting installation of the component.

Licensee's Basis for Relief During the current HCGS refueling outage, the original piston check valve 1GSV-138 failed to meet the requirements of the localleak rate test and needs to be replaced. An identical replacement valve is available which was constructed to an earlier version of the ASME Code than that of the existing valve. Approval of Code Case N-567 is requested to allow use of the replacement valve, pursuant to 10 CFR 50.55a(a)(3).

3.0 EVALUATION The Owner's design specification specifies a particular construction code with edition and addenda for a component which provides the rules for design, fabrication and testing of a code component along with any additional requirements to meet its intended service during its design I life. The objective of the rules is to afford reasonably certain protection of life and property and to provide a margin for deterioration in service so as to give a reasonably long safe period of '

usefulness. However, Code Case N-567 allows use of a component constructed to an earlier edition of the code or addenda with the stipulation that any deviation from the Owner's l

requ rements or the original Construction Code of the component being replaced,is reconciled.

The code case further requires preparation of the report of reconciliation and retaining it with the Ir service Inspection Report as stated in Subsection IWA-6340 and also identifying use of the code case in the NIS-2 Fcrm. The requirement of the code case, therefore, is equivalent to having a component built to the original construction code and maintaining the records of replacement in the plant history file for the remaining life of the plant. For the specific case of the replacement valve 1GSV-138 (one inch /600# Edward Model 838YT piston check valve), the licensee intends using an identical valve constructed to 1971 ASME Code, Section Ill, with summer 1972 Addenda in place of the existing valve built to 1974 ASME Code, Section til, with summer 1975 Addenda. Both valves being identical but built to different versions of the Code, the staff made a comparison of the material, non-destructive examination and hydrostatic shell test pressure requirements of the applicable code for each valve. The staff determined that the requirements of the construction code of the replacement valve is in no way less restrictive than that of the existing valve in each of the above categories. In regard to the installation of the replacement valve, the staff, further, obtained clarification from the licensee that any and all j provisions of the licensee's quality assurance progrmn, the ASME Code administrative i requirements, ar.d other applicable regulatory requirements would necessarily be met. The )

staff, therefore, has determined that the use of the replacement valve built to an earlier version l of the Code than that of the existing valve is in compliance with Code Case N-567 and would  !

provide an equivalent protection of health and safety of the public as that of the original I Construction Code.

4.0 CONCLUSION

The staff concludes that the licensee's proposed use of Code Case N-567 for the replacement valve would provide an acceptable level of quality and safety and is, therefore, authorized pursuant to 10 CFR 50.55a(a)(3)(i). PSE&G is authorized to use Code Case N-567 for the subject component only which will be permanently installed at HCGS and remain as a plant component for the licensed life of the plant.

Principal Contributor: P. Patnaik Date: March 19, 1999 l

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