ML20216J000
| ML20216J000 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/09/1997 |
| From: | Naslund C UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3647, NUDOCS 9709170132 | |
| Download: ML20216J000 (6) | |
Text
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September 9,1997 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mall Stop pt 137 Washington, DC 20555 0001 l
ULNRC 3647 Gentkmen:
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DOCKET NUMilER 50-483 CALLAWAY PLANT UNIT I FACILITY OPERATING LICENSE NPF-30 REOUEST FOR USE OF N 5081 AT cal.l.AWAY STATION Pursuant to the provisions of 10CFR 50.55a(aK3Xi), Union Electric Comp ny requests NRC approval to use ASME Code Case N 508-1," Rotation of Serviced Snubbers and Pressure Relief Valves for the Purpose of Testing." This Code Case has been approved by the American Society of Mechanical Engineers, and is published in ASME Code Case Supplement 9.
A copy of the Code Case is attached. A summary describing Code Case provisions and implementation methods is also attached. His summary demonstrates the acceptability'of N 5081 alternatives. Implementation of N 5081 will reduce costs, but will not reduce component safety, quality, or acceptability.
Approval is requested by December 1,1997, in order to facilitate use of N 5081 during Callaway's Spring,1998 Refueling outage.
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C. D. Naslund
- Manager, Nuclear Engineering l'[ 2 C Ub CDN/ts i
Enclosure hl jj 9709170132 970909
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ULNRC-3647 Page 2
. e, IllOUEST EO]t USE OF N 508-1 AT cal.1,AWAY STATIO_N llackcround:
The 1989 Edition of ASME Section XI governs repair / replacement activities at the Callaway Plant. Snubber and pressure relief valve replacements fall within the scope oflWA 7000.
N 5081 provides an alternative to the administrative controls ofIWA 7000 for snubbers and pressure relief valves that are, for testing purposes, rotated from stock and installed. This alternative reduces costs by climinating redundant administrative and documentation controls, l
liasis for Annroval of the Proposed Alternative:
Snubbers 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, l
installing a replacement, then testing the removed component at a later time. Current ASME l
Code rules stipulate that each snubber / pressure relief valve rotation comply with IWA 7000 requirements. Resulting ASME imposed administrative and documentation controls are extensive, and include:
ASME Section XI Replacement Plan preparation ANil Review and concurrence e
NIS 2/NIS 2A form generation e
Tracking as an ASME Section XI Replacement These ASME provisions are appropriate for replacementa due to failures or design changes, but constitute an unwarranted burden for snubbers and relief valves rotated from existing stock.
Callaway has a program for controlling and tracking snubber and pressure relicf valve rotations.
The added administrative burden imposed by the ASME Code is redundant and imposes unwarranted costs. Code Case N 5081 provides an effective alternative for snubber / pressure relief valve rotation that will enable Callaway to implement existing program controls without the added burden of redundant ASME requirements. Specific N 5081 provisions, and the Callaway Plant methods of compliance with these provisions, are addressed in the following paragraphs. Code Case requirements are shown in italics, with Callaway applicability addressed in the accompanying bulleted paragraph.
(a) " Items being removed and installedshall be of the same design and construction. "
+ The Callaway Plant work authorizing document records the serial number of each removed snubber / pressure relief valve, and records the serial number of the replacement component. Each snubber / pressure relief valve is tracked by this serial number, which provides traceability to component design and cocstruction information. Engineering and Quality Control verifications assure that the rep!acement component is the same design and construction as the removed component. Note that, when current design has been changed to accept alternate items or components, these alternates are considered to be "of the same design and construction" as the original component.
ULNitC-3647 Page 3
. e, (6) " hems being renwved shall have no evidence offailure at the time ofremoval. "
+ Component failures fall within the scope of Callaway's ASME Section XI Repair / Replacement Program. Evidence of failure excludes the component from the scope of N 5081, and invokes an evaluation for suitability in accordance with IWA-7000.
(c) " Items being rotated shall be removed and installed only by mechanical means. "
+
Welding, brazing, and metal removal activities on ASME items fall within the scope of Callaway's ASME Section XI Repair / Replacement Program. His program requires that metal removal or welding associated with snubber / pressure relief valve removal or replacement be considered an ASME Section XI Repair / Replacement activity.
(d) " hems being installedshallpreviously have been in service. "
+
Callaway program controls will restrict N 5081 applicability to previously installed components. Replacements that install components which have not previously been in service will not fall within the scope of N 508 1, and will, therefore, be addressed as ASME Section XI Replacements in accordance with the requirements ofIWA 7000.
(c) "Preservice inspections andpressure tests shall be perf<nmedas required by IWA 1000 (IWA 7000for Editions andAddendaprior to the 1991 Addenda). "
+
N 5081 provides an alternative to IWA 7000 requirements governing administration and documentation of replacement activities. These alternatives do not affect existing programs governing preservice inspections and pressure tests.
(f) "The Owner shall maintain a method of tracking the items to ensure traceability ofinservice inspection and testing records. "
+ Callaway maintains a tracking system that records the individual serial number of each snubber / pressure relief valve that is removed from or installed in the system. This tracking system is independent of the ASME Section XI Repair / Replacement Program, and satisfies this N 5081 requirement.
(g) "Use ofan NIS 2 form is not required except as providedin (i) below. "
+ Callaway's work authorizing document provides snubber / pressure relief valve traceability information. NIS 2 traceability information was a duplication of the information recorded in the work authorizing document. NIS 2 elimination, therefore, will not compromise traceability.
(h) " Testing ofremoved snubbers andpressure relief valves, inchtding required sample expansions. shall beperformed in accordance with the Owner 's test program. "
+ The alternatives provided by N 5081 do not affect Callaway snubber and pressure relief valve testing programs or sample sizes.
ULNRC 3647 Page 4 (i) " Repair or replacement ofremoved items, when required. sh 211 be performed in accordance with lIl'A 4000 (Ill'A 4000 or ill'A 7000for Editions and Addendaprior the 1991 Addenda). "
- The Callaway ASME Section XI Ilepair/ Replacement program will be revised to permit f
use of the alternative provisions of N 508-1. Only snubbers and relief valves that, for the purpose of testing, are rotated from stock and installed will be eligible for N 5081 provisions. Repair / replacement activities other than snubber / pressure relief valve rotation are excluded from the scope of N 5081, and will be addressed in accordance with the requirements of ash 1E Section XI.
I
==
Conclusion:==
AshtE Code Case N 5081 provides an alternative to the administrative controls of AShtB Section XI. N 5081 imposes controls to assure that component traceability and l
acceptability are maintained. N 5081 alternatives alTect only administrative and documentation controls, and do not affect component safety and quality. N 5081, therefore, provides a cost efTective alternative to existing AShtE Code requirements without compromising quality or safety.
1
ULNRC-3647 Pcgo 5 CASE N-508.1 CASES OF ASME BOILER AND PRESSL'RE VESSEL CODE e an Approval Date: May 11,1994 See Numericalindex for expiration and any restfirmation dates.
Case N4081 (b) Items being removed shall have no evidence of Rotation of Serviced Snubbers and Pressure Rellef failure at the time of removal; Valves for the Purpose of Testing (c) Items being rotated shall be removed and Section XI, Division 1 installed only by mechanical means; (d) Items being installed shall previously have Inquiry: What alternative rules to those stated in been in senice; IWA 4000 (IWA 7000 for. Editions and Addenda (c) Preservice inspections and pressure tests shall prior to the 1991 Addenda) may be used when, t'or be performed as required by IWA-4000 (IWA 7000 the purpose of testing, snubbers and pressure relief for Editions and Addenda prior to the 1991 Adden-valves are rotated from stock and installed on com-dt);
ponents (including piping systems) within the Section (f) The Owner shall maintain a method of tiacking XI boundary?
the items to ensure traceability of insenice inspec-tion and testing records; Replyt it is the opinion of the Committee that, as (g) Use of an NIS-2 form is not required except as an alternative to the provisions of IWA-4000 (IWA-provided in (i) below; i
7000 for Editions and Addenda prior to the 1991 (h) Testing of removed stiubbers and pressure re-l Addenda) and for the purpose of testing, snubbers lief valves, including required sample expansions, l
and relief valves may be rotated from stock and in-shall be performed in accordance with the Owner's stalled on components (including piping systems) test program; within the Section XI boundary provided the follow-(i) Repair or replacement of removed items, when ing requirements are met:
required, shall be performed in accordance with (a) Items being removed and installed shall be of IWA-4000 (IWA 4000 or IWA-7000 for Editions and the same design and construction; Addenda prior to the 1991 Addenda).
983
ULNRC 3647 Page 6 cc: U S. Nuclear Regulatory Commission (Original and I copy)
Attn: Document Control Desk Mail Stop PI 137 Washington, IX' 20555 0001 Mr. Ellis W. Merschoff Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plan Drive, Suite 400 Arlington, TX 76011 8064 Senior Resident inspector Callaway Resident Omce U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 j
Mr. Barry C. Westreich (2 copies)
Acting Licensing Project Manager, Callaway Plant Omce of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mall Stop 13E16 Washington, DC 20555 2738 Manager, Electric Department Missouri Public Service Commission PO 11ox 360 Jefferson City, MO 65102 Mr. Thomas A. llaxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.
Washington, DC 20037 -