ML20216H065

SER Approving Licensee Proposed Alternative to Use Code Case N-508-1 for Rotation of Serviced Snubbers & Prvs for Purpose of Testing in Lieu of ASME B&PV Code,Section Xi,Article IWA-7000 Requirements

ML20216H065
Person / Time
Site:	Callaway
Issue date:	04/15/1998
From:	Bateman W NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216H033	List: ML20216H028 ML20216H065
References
NUDOCS 9804210034
Download: ML20216H065 (3)

Text

,

a tax y \g UNITED STATES j NUCLEAR REGULATORY COMMISSION

, f WASHINGTON. D.C. 30006 0001 I Y

SAFETY EVALUATION BY THE OFFICE OF NUCI FAR REACTOR REGULATION RFI ATED TO A REQUEST FOR RFI IEF TO USE ASME CODE CASE N-508-1 UNIOrd ELECTRIC COMPANY CAI I AWAY PLANT. UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

The Code of Federal Regulations,10 CFR 50.55a, requires that inservice inspection (ISI) of certain ASME Code Class 1,2, and 3 components be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code applicable Edition and Addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to paragraph 10 CFR 50.55a(g)(6)(i), or altematives approved pursuant to 10 CFR 50.55a(a)(3). In proposed attematives, the licensee must demonstrate that (i) the proposed altomatives provide an acceptable level of quality and safety; or (ii) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Section 50.55a authorizes the Commission to grant relief frorr ASME Code requirements upon making the necessary findings. The staff's finding with respect to granting or not granting the rdief request as part of the licensee's inservice inspection (ISI) program is contained in this safety evaluation (SE).

This SE covers a request for authorization to use the ASME Boiler and Pressure Vessel (B&PV)

Code Case N-508-1 for the Callaway Plant, Unit 1, as an attemative to the ASME B&PV Code,Section XI, Article IWA-7000, requirements submitted by Union Electric Company's letter dated September 9,1997. The licensee's ISI program for the current interval is based on the repair and replacement requirements of Article IWA-7000 of the ASME B&PV Code,Section XI,1989 Edition for the second ten-year ISI program at Callaway Plant, Unit 1.

2.0 RELIEF REQUEST The licensee requests relief.from the ASMF G&PV Code,Section XI, Article IWA-7000 repair and replacement requirements for snubbers and pressure relief valves. The licensee proposes as an altamative to the ASME B&PV Code,Section XI requirements, to use ASME B&PV Code Case N-508-1, titled Rotation of Serviced Snubber and Pressure Relief Valves for the Purpose of Testing, for the Callaway Plant Unit 1.

9804210034 980415 PDR i

ADOCK 05000483 i P pn j

t.

2.1 Licensee's Basis for Requested Rehef Snubber and pressure relief valves require periodic testing. To reduce system out-of-service time, testing is normally accomplished by removing an existing component from service, installing a replacement, then testing the removed component at a later time. The current ASME B&PV Code rules stipulate that each snubber / pressure relief valve rotation comply with Section XI, Article IWA-7000 requirements. The IWA-7000 requirements impose extensive administrative and documentation controls. The IWA-7000 provisions are appropriate for component replacements due to failures or design changes, but constitute an unwarranted burden for snubbers and relief valves that are rotated from stock. Callaway Plant Unit 1 has a program for controlling and tracking snubber and pressure relief valve rotations. The added administrative burden imposed by the ASME Code is redundant and imposes unwarranted costs. Code Case N-508-1 provides an effcetive attemative for snubber and pressure relief valve rotation that will enable Callaway Plant Unit 1 to implement oxisting program controls without the added burden of redundant ASME requirements. The Code Case allows for snubbers and relief valves to be rotated from stock provided nine specific listed requirements are met. Callaway Plant Unit 1 methods provide for compliance with all of these requirements.

The licensee concludes that (1) ASME Code Case N-508-1 provides an altemative to the administrative controls of ASME B&PV Code,Section XI, Article IWA-7000, requirements; (2)

Code Case N-508-1 imposes controls to assure that wiTiponent traceability and acceptability are maintained; (3) Code Case N-508-1 attematives affect only administrative and documentation controls, and do not affect component safety and quality; and (4) Code Case N-508-1, therefore, provides a cost-effective attemative to existing ASME Code requirements without compromising quality and safety.

2.2 Evaluation Currently, the ASME B&PV 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 an evaluation, review and concurrence by an Authorized l Nuclear Inspector. The licensee considers these Code provisions appropriate when the components are replaced due to design changes or nonconformances, but execssive for the removal and ,nstallation of snubbers and pressure relief valves solely for the purpose of testing. !

I Code Case N-508-1 provides an attemative to the current ASME B&PV Code,Section XI, Article 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 installed on components and piping svstems 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 requirements. The licensee will revise the Callaway ASME Code,Section XI, snubber and pressure relief program to allow the ,

use of the attemative provisions of Code Case N-508-1, with the restriction that only for purposes of testing can snubbers and pressure relief valves be rotated from stock and installed under the provisions of the Code Case. Further, repair and replacement activities other than l

i

l O

l snubber and pressure relief valve rotation associated with testing are excluded from the scope {

i of the Code Case, and will be addressed in accordance with the requirements of ASME Code,Section XI.

i i The licensee's proposed attemative to use the Code Case for the purpose of snubber and i pressure relief valve rotation associated with testing will eliminate unnecessary administrative

! and documentation requirements, minimizing the time during which the affected system is out of l service and conserve resources. The staff finds that the same level of quality and safety is l maintained when component rotation and testing is performed in accordance with IWA-7000 or Code Case N-508-1. j The staff has determined that the licensee's alternative application is acceptable and provides l reasonable assurance of operational readiness and that compliance with the ASME Code

requirements would result in hardship without a compensating increase in the level of quality l and safety.

3.0 CONCLUSION

l.

l The staff concludes that the licensee's proposed alternative to use Code Case N-508-1 for rotation of serviced snubbers and pressure relief valves for the purpose of testing in lieu of l ASME B&PV Code,Section XI, Article IWA-7000 requirements is authorized pursuant to j i 10 CFR 50.55a(a)(3)(ii), based on the determination that compliance with the Code  ;

l requirements would result in hardship without a compensating increase in the level of quality i l and safety.

L l

Principal Contributor: F. Grubelich  !

l l Date: April 15,1998 l l

l