ML20214A245
| ML20214A245 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/11/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8705190347 | |
| Download: ML20214A245 (7) | |
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S ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERNAN Vice PmtslotNT NUCLEAR ENtmay May 11,1987 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Relief from Replacement Requirements in Section XI of the ASME Boiler and Pressure Vessel Code, Articles IWA-7210, IWC-7600, IWD-7600, and IWF-7600 Gentlemen:
Pursuant to 10 CFR 50.55a(g)(5)(ill), we hereby request relief from certain requirements in the ASME Boiler and Pressure Vessel Code Section XI,1983 Edition with Addendum through Summer 1983.
Components for Which Relief is Requested Fasteners (studs, bolts, threaded rod, and nuts, as applicable) for those components listed in Attachment A.
This list is not complete.
We will submit a final list af ter we complete our investigation.
Code Requirement from Which Relief is Requested i
Article IWA-7210 and Article IWC-7600, IWD-7600, or IWF-7600, as applicable to Certificate of Compliance and marking requirements.
Supporting Information The above articles require that replacements meet either the requirements to which the original component or part was constructed, or requirements of later editions of ASME Section !!! if certain other criteria are met. We recently identified fasteners for those components listed in Attachment A that were purchased by our Safety-Related Commercial Quality method of procurement. In all cases, our purchase orders specified the appropriate ASTM specification. Receipt inspection was made to veri y c nformance b gg
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r Document Control Desk May 11,1987 Page 2 to purchase orders. However, we did not specify or receive Certified Material Test Reports (CMTRs) or Certificates of Compliance (C of Cs) required by the original construction code, and we did not transfer the marking code when material was cut to make more than one piece.
We have determined it is impractical to replace the fasteners for those components listed in Attachment A with fasteners that have CMTRs or C of Cs for one of the following reasons:
1.
Results of tests of the fastener ensure us that the fastener is adequate to perform its safety function.
The tests to be performed are described in Attachment B.
It would be impractical to expend the considerable effort that would be required to replace these fasteners since they are adequate to perform their safety function.
That effort would involve at least 24 manhours of preparation, radiation control, quality control, and craf t labor for each component listed in Attachment A.
Some replacements would involve work in high radiation areas and some fasteners will be difficult to replace.
2.
The fastener is similar to other fasteners tested and the results of those tests provide assurance, with a high level of confidence, that the fastener is adequate to perform its safety function.
(Our sampling program is described in Attachment C.)
As with item 1, it would be impractical to expend the considerable effort that would be required to replace these fasteners as well.
Exams Peformed in Lieu of Section XI Requirements Chemical composition, non-destructive, and hardness exams will be performed on all commercial quality pressure-retalning fasteners removed from Class I components and on a sufficient number of Class 2 and/or 3 fasteners to obtain the total sample size required by the sampling program (Attachment C). All commercial quality pressure-retalning fasteners for Class I components will be replaced and are outside the scope of this request for relief; however, fasteners removed from Class ! components will be tested as part of the sampling program.
A flow diagram for the examinations referencing the BG&E procuedures being used and acceptance criteria for the chemical composition, non-destructive, and hardness exams are given in Attachment B.
Schedule All tests will be completed prior to heatup. We estimate Unit I heatup will begin May 20 and Unit 2 on May 25. We will keep you informed of changes to our schedule.
Document Control Desk May 11,1987 Page 3 Corrective Actions Future replacement fasteners for ASME Section XI Class 1, 2, and 3 components will meet the applicable requirements of ASME Section XI. Additional controls on the use of commercial quality material have been imposed. Those personnel responsible for any aspect of instal;ing replacement fasteners (from procurement to installation) have been informed of their responsibilities.
A formal repair and replacement program procedure has been implemented for Unit 1, and will be implemented for Unit 2 upon startup. This program requires a detailed review of replacements to ensure a suitability evaluation has been made for all replacements. Training for the implementation has been conducted.
Application Fee Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1910547 in the amount of
$150.00 to cover the application fee for this request.
Should you have further questions regarding this matter, we will be pleased to discuss them will you.
Very truly yours, n
)
JAT/ WPM / dim Attachments cc:
D. A. Brune, Esquire
- 3. E. Silberg, Esquire R. A. Capra, NRC S. A. McNeil, NRC W. T. Russell, NRC T. Foley/D. A. Trimble, NRC
e ATTACHMENT A FASTENERS FOR WHICH RELIEF 15 REQUESTED COMPONENT CONSTRUCTION CODE ASME SECTION XI CLASS Relief Valve,1-SI-409 ANSI B31.7, Class 2 2
Relief Valve, 1-51-431 ANSI B31.7, Class 2 2
Valve,1-BD-40ll ANSI B31.7, Class 2 2
Valve,1-BD-4010 ANSI B31.7, Class 2 2
Relief Valve, 1-51-439 ANSI B31.7, Class 2 2
Spool Piece, ILRT ANSI B31.7, Class 2 2
Flange, Containment ANSI B31.7, Class 2 2
Spray Piping Relief Valve, 2-51-439 ANSI B31.7, Class 2 2
Relief Valve, 2-51-431 ANSI B31.7, Class 2 2
Relief Valve, 2-51-241 ANSI B31.7, Class 2 2
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ATTACHMENT B FLOW CHART FOR MATERIALS TESTING ANO EVALUATION OF STUOS,80LTS Ale NUTS COMPONENTS IN FROM PLANTS h
etASS aEA0
/ CLEAN
\\
4 MATERIAL RECEFT/
10ENTIFICATION / 8 LOG IN (hhM)
- Note 1 i
ANALYSIS SY M ON MATER:ALS Engr.
i a ANALym3 1
l' NO
'l MATERiATL m N0m W i
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Cuf,uAnn DEFICIENjCY I
LOS
& TEST WhPER I
i NARONESS TESTS
YES.N6 r
- Note 2 o
1
. Note 2 CHEM 8 CAL ANALY888 I
M NOTE IN LOG /
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TENELE h TS (MTE STAGEE004)
IN l
APPENO IESULTS NO No M SPEC MECORO/ Sag NOTE IN LDS/
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MATERIAL g af uYES NT y ST, EM W/
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NOTE 1 Any indication which is RESULTS TO rejectable according to the RESPONS18LE ENGifEER code for the technique orployed.
NOTE 2 h acceptance criteria is specified in the applicable ASDI Specification.
...e ATTACHMENT C i
SAMPLING PROGRAM OBJECTIVE Ensure, with reasonable certainty, that the fasteners for components listed in Attachment A are adequate to perform their safety function.
SCOPE OR TOTAL POPULATION Fasteners installed in ASME Section XI Class 1, 2, and 3 pressure-retaining components and their supports purchased by our Safety-Related Commercial Quality method.
SAMPLE SCOPE Sample fasteners will be taken from ASME Section XI Class 1 pressure-retaining components first. The remaining sample fasteners that are required will be taken from the rest of the population. If we cannot determine which fastener (s) within a bolt ring were replaced, then the entire bolt ring is assumed to be one sample. All fasteners must pass for that sample to pass.
TESTING Each sample fastener will undergo non-destructive chemical composition, non-destructive, and hardness exams described in Attachment B.
If an additional exam is necessary to determine pass / fall, such as a tensile test, then it will be performed as described in Attachment B.
SAMPLE SIZE The sample size shall be sufficient to provide a 95% confidence level that more than 95%
of the total population are adequate to perform their safety function. That number is dependent on the number of failures that are found. This is illustrated below:
i Sample Size Failures
$9 0
93 1
112 2
149 3
The characteristics of each type of fastener will be assessed to ensure the samples are representative of the total population.
FE ATTACHMENT C SAMPLING PROGRAM
. This sampling program is similar to IE Bulletin No. 79-02 (Revision 2), Appendix A, Sampliag Method (b), with one exception. The Bulletin's sampling program was to be done on a system-by-system basis. That is, the total population was those items in one system. ' Oyr total population covers all ASME Section XI Class 1, 2, and 3 systems because
- the suitability of fasteners purchased Safety-Related Commercial Quality is at issue, and the source of Safety-Related Commercial Quality fasteners is similar for each system and system class.
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