ML20214M178

Safety Evaluation Granting Util 860324 & 870114 Requests for Relief from Certain Requirements of ASME Code Section XI & to Use ANSI N45.2.6-1978 in Lieu of ASME Code Requirement of ANSI N45.2.6-1973

ML20214M178
Person / Time
Site:	Crystal River
Issue date:	05/26/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214M169	List: ML20214M167 ML20214M178
References
NUDOCS 8706010209
Download: ML20214M178 (8)

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Enclosure 1 SAFETY EVALUATION BY THF 0FFICE OF NUCLEAR REACTOR REGULATION RELATING TO RELTEF FROM CERTAIN REQUIREMENTS OF SECTION XI 0F THE ASME CODE FLORIDA POWER CORPORATION CRYSTAL PfVER UNIT 3 DOCKET NO. 50-302

1.0 INTRODUCTION

The Technical Specifications for Crystal River Unit 3 require that in-service examinations of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Code as required by 10 CFR 50.55a(g)(4) except where specific written relief has been granted by the Comission. Some plants were designed in conformance to early editions of this Code section, consecuently certain requirements of later editions and addenda of Section XI are impractical to perform because of the existing design, geometry, and material of construction of the com-ponents. Paragraph 10 CFR 50.55a(g)(6)(1) authorizes the Commission to grant relief from those requirements upon making the necessary findings.

In letters dated March 24, 1986 and January 14, 1987 Florida Power Cor-poration (FPC), the licensee, identified specific ASME Code requirements that FPC determined to be impractical to perform at Crystal River and re-quested relief from these requirements. The staff has evaluated the licensee's supporting technical justification and finds them to be accep-table.

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2.0 EVALVATION Of RELIEF REQUESTS The staff reviewed the information provided in the licensee's letters as related to the design, geometry, and materials of construction of the componentspursuantto10CFR50.55a(g)(6)(1)and10CFR50.55a(a)(3).

A.I. Code Requirement (ReliefRequestNo.220) i' ASME Section XI, 1980 Edition including Addenda through Winter 1981, requires the following hydrostatic tests:

Examination Item '

Category No.

i B-P B15.51 A VT-2 visual examination is required of all ASME Code Class 1 pressure retaining components during the system hydrostatic test at or near the end of each inspection interval. For a test temperature of 100*F or less, the required test pressure is 1.10 times the nominal operating pressure cor-responding with 100% rated reactor power.

Paragraph IWB-5222(b) stipulates that when-ever a system hydrostatic test is conducted in which the reactor vessel contains nuclear fuel and the vessel is within the system test boundary, the test pressure shall not exceed the limiting conditions specified in the plant Technical Specifications.

C-H C7.40 A VT-2 visual examination is required of the ASME Code Class 2 pressure retaining boundary including only those portions of the systems required to operate or support the safety system function up to and including the first

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nomally closed valve (including a safety or relief valve) or valve capable of auto-matic closure when the safety function is required. The system hydrostatic test pressure shall be at least 1.10 times the system pressure P sv for systems with design temperature of 200*F or less, and at least 1.25 times the system pressure P gy for systems with design temperature above 200'F.

The system pressure P 3yshall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

B.1. Code Relief Request

] The licensee requests relief from performing.the hydrostatic test and VT-2 visual examination for portions of ASME Code Class 1 and 2 piping of the core flood, decay heat, and makeup systems.

C.I. Pasis For Requesting Relief The components addressed by this request are as follows:

Core Flood Piping from CFV-5 through CFV-1 (FSAR Figure 6-2)

Core Flood Piping from CFV-6 through CFV-3 (FSAR Figure 6-2)

Decay Heat Piping from DHV-6 through CFV-1 (FSAR Figure 9-6)

Decay Heat Piping from DHV-5 through CFV-3 (FSAR Figure 9-6)

Makeup Piping from MllV-27 and MUV-24 through MUV-43 (FSAR Figure 9-?)

The design of the piping makes a hydrostatic test of these portions of piping impractical. The hydrostatic test pressure on these portions of piping would exceed allowable pressure of the reactor coolant system as stated in Technical Specification 2.1.3. As an alternative test the licensee proposes a system inservice leak test of that portion of piping from CFY-5 and DHV-6 through CFV-1; from CFV-6 and DHV-5 through CFV-3; and from MUV-27 and MUV-24 through MUV-43. This alternative will be dore in accordance with IWA 5211(a) following each refuel outage and will be implemented beginning with Refuel VI, presently scheduled for the fall of 1987, i

D.I. Staff Evaluation The staff has cortpleted the evaluation of the licensee's letter dated March 24, 1986 related to Relief Request No. 270. ASME Section XI con-tains specific qualifications that Code-required systen pressure tests shall not be performed when the test parameters exceed the limiting con-ditions specified in the plant Technical Specifications. The Crystal River Unit 3 Technical Specification 2.1.3 states that the reactor coolant system pressure shall not exceed 2,750 psia. The staff determined that l the Code reouired hydrostatic test, on the portions of piping identified by the licensee, is impractical because the test conditions would exceed the allowable pressure stated in the plant Technical Specifications.

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As an alternative examination the licensee comitted to perform the system leakage test defined in IWA-5211(a) on the sub. ject piping following each refueling outage. The Code requires the system leakage test and examina-tion after pressurization to nominal operating pressure following the opening and reclosing of a component in the system. The staff finds that

, the licensee's alternative will result in a frequency of system leakage tests and examinations that will equal or exceed the Code requirements.

Therefore, the staff concludes that the licensee has proposed an accepta-ble alternative because ASME Section XI intends that system pressure test at nominal operating conditions be substituted when the hydrostatic test parameters exceed plant Technical Specification limits.

A.2. Code Reouirement (Relief Request No. 230) l l

ASME Section XI,1980 Edition including Addenda through Winter 1981 requires in IWA-2300(c) that " Personnel performing the visual examination VT-2, VT-3, and VT-4 of IWA-2212, IWA-2213, and IWA-2214, respectively, shall be qualified by the Owner or the Owner's agent in l accordance with the comparable levels of competency as defined in ANSI N45.2.6 - 1973."

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B.2. Code Relief Request The licensee requests relief to certify personnel performing VT-2, VT-3, and VT-4 examinations in accordance with ANSI N45.2.6-1978 as an alternative to the Code requirement.

C.2. Basis For Requesting Relief Code Case N-424 contains the following reply:

i "It is the opinion of the Connittee that ANSI /ASME N45.2.6-1978 may be used instead of ANSI N45.2.6-1973 when qualifying examina-tions personnel to perform VT-2, VT-3, and VT-4 visual examina-tins for Section XI,' Division 1."

Code Case N-424 has been referenced, without conditions, in Regulatory Guide 1.147, Revision 5, dated August 1986. The licensee's commitment in the FSAR and use of ANSI N45.2.6-1978 in the NDE training program predate Relief Request No. 100 in which the licensee received approval to use portions of ASME i l

Section XI, 1980 Edition including Addenda through Winter 1981.

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D.2 Staff Evaluation The staff has completed the evaluation of the licensee's letter dated January 14, 1987 related to Relief Request No. 230 pursuant to 10 CFR 50.55a(a)(3). The regulatory position in Regulatory Guide 1.147, Revision 5, states that Code Case N-424 is acceptable to the staff, without limitations, for application in the inservice inspec-

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tion of components and their supports. Therefore, the staff con-cludes that the licensee has proposed an alternative that will pro-vide an acceptable level of quality and safety.

3.0 CONCLUSION

1 Pased on the foregoing, the Commission grants the relief requested by the licensee in Relief Request No. 220 to perform system leakage tests follow-ing each refueling outage in lieu of subjecting portions of the piping system to hydrostatic pressures that would exceed the limitations defined in the plant Technical Specifications, pursuant to 10 CFR 50.55a(g)(6)(1),

based on our finding that the required ASME Code Section XI hydrostatic test for the identified portions of pipe is impractical. The alternative testing is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

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The Commission also grants the relief requested by the licensee to use l ANSI N45.2.6-1978 in lieu of the ASME Code requirement of ANSI N45.2.6-1973 (Relief Request No. 230) pursuant to 10 CFR 50.55a(a)(3) based on our finding that the proposed alternative would provide an accep-table level of quality and safety.

Principal contributor:

M. Hum

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