ML20217H718

Corrected Page 5 to 980324 SER Re Relief Requests Associated W/Second 10-year Interval Insp program.RR-21 in Error in That Component,Suction Damper Inadvertently Omitted. Corrected Page 7 of Technical Ltr Rept Also Encl

ML20217H718
Person / Time
Site:	Vogtle
Issue date:	04/01/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217H681	List: ML20217H677 ML20217H718
References
NUDOCS 9804060034
Download: ML20217H718 (2)

Text

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l 5-Regenerative Heat Exchanger (Tag No. 2-1208-E6-001)

Excess Letdown Heat Exchanger (Tag No. 2-1208-E6-002) 1.etdown Heat Exchanger (Tag No. 2-1208-E6-003)

Letdown Reheat Heat Exchanger (Tag No. 2-1208-E6-007)

Suction Damper (Tag No. 2-1208-V4-001) l l Discharge Dampener (Tag No. 2-1208-V4-002)

The licensee has requested to use the exemption criteria of IWC-1222 of the 1939 Addenda in lieu of the exemption requirements of the Code of record. In accordance with the 1989 Code, i piping NPS 4 and smaller is exempt from examination, but connected components am not. In l

the 1989 Addenda of Section XI, IWC-1222 was revised to exempt vessels, pumps, and valves, and their connections in piping NPS 4 and smaller, with the following note. "In piping is defined as having a cumulative inlet and a cumulative outlet pipe cross-sectional area neither of which

exceeds the nominal OD cross-sectional area of the designated size." This exemption is also i l

contained in Code Case N-408-2, Altemative Rules for Examination of Class 2 Piping, I Section XI, Division 1, which has been approved for general use in Revision 11 of Regulatory Guide 1.147.

The change in the Code described above parallels the logic used for the exemption of Class 1 - I l systems. Specifically, lWB-1220(b)(2) exempts " components and their connections in piping in l l

1-inch nominal pipe size and smaller," where "in piping" is defined as having one inlet and one outlet pipe, each of which is 1-inch NPS or smaller. The discrepancy between Class 1 and l Class 2 systems was recognized by the Code committee, which pattemed the exemption ,

criteria for Class 2 in the 1989 Addenda after existing exemption requirements for Class 1 i systems.

The staff has concluded that the licensee's attemative, to use the exemption criteria of the 1989 Addenda for the above specified Class 2 systems, provides an acceptable level of quality and safety in that it provides assurance of structural integrity. The approach used for the Class 2 exemption criteria found in the 1989 Addenda is similar to that used for exemption of Class 1 .

systems. In addition, the criteria has been approved by the NRC as part of Code Case N-408-2. l Therefore, the licensee's proposed altemative contained in Request for Relief No. RR-21 is '

authorized pursuant to 10 CFR 50.55a(s)(3)(i).

Request for Relief No. RR-22: Pursuant to 10 CFR 50.55a(s)(3)(i), the licensee proposed to use Code Case N-544, Repair and Replacement of Small items,Section XI, Division 1, in lieu

( of the repair and replacement requirements of the Code. The licensee proposed that it will comply with the requirements of Code Case N-544 in lieu of IWA-4000 and IWA-7000 except that the subject Code Case will not be applicable to heat exchanger tubing, sleeves, and l- welded plugs used for heat exchanger tubes in Class 1, 2, and 3 heat exchangers, including similar steam generator-related components.

l The Code requires that repairs and replacements be performed in accordance with IWA-4000 and lWA-7000, respectively. Pursuant to IWA-7400, piping, valves, and fittings NPS 1-inch and smaller are exempt from the requirements of Article IWA-7000. Hemover, Article IWA 4000 has no exemption criteria for components NPS 1-inch and smaller. Therefore, some licensees may 9804060034 980401 PDR ADOCK 05000424 G PDR

- published in a future revision of Regulatory Guide 1.147. At that time, if the licensee intends to continue to implement this Code Case, the licensee should follow all provisions in Code Case N-509, with limitations issued in Regulatory Guide 1.147, if any.

d. Reauest for Relief No. RR-21. lWC-1220. C!=== 2 Comoonents Fwamot from Framinahn Code Requirement- lWC-1220, Components Exempt from Examination, contains the exemption criteria for Class 2 components. lWC-1222 contains the requirements for components within systems other than the Residual Heat Removal (RHR), Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems. In accordance with IWC-1222, components exempt from the surface and volumetric examination requirements of IWC-2500 are as follows:

(a) Vessels, piping, pumps, valves, and other components NPS 4 and smaller.

(b) Component connections NPS 4 and smaller (including nozzles, socket fittings, and other connections) in vessels, piping, pumps, valves, and other components of any size.

(c) Vessels, piping, pumps, valves, and other components of any size in systems or portions of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig and at a temperature equal to or less than 200*F.

(d) Piping and other components of any size beyond the last shutoff valve in open ended portions of systems that do not contain water during normal plant operating conditions.

Licensee's Prooosed Alternative: Pursuant to 10 CFR 50.55a(s)(3)(i), the licensee has proposed to use the exemption criteria found in lWC-1222 of the 1989 Addenda of the 1989 Ednion of ASME Section XI for corr ponents within systems other than the RHR, ECC, and CHR systems. This Addenda does not require surface and volumetric examinations of vessels and their connections in piping 4-inch nominal pipe size (NPS) and smaller for Examination Category C-A, items C1.10, C1.20, and C1.30 (Pressure-Retaining Welds in Vessels) and Examination Category C-C, item C3.10 (Integrally Welded Attachments to Pressure Vessels). Relief is specifically requested for the following components:

Regenerative Heat Exchanger (Tag No. 2-1208-E6-001)

Excess Letdown Heat Exchanger (Tag No. 2-1208-E6-002)

Letdown Heat Exchanger (Tag No. 2-1208-E6-003)

Letdown Reheat Heat Exchanger (Tag No. 2-1208-E6-007)

Suction Damper (Tag No. 2-1208-V4-001) l Discharge Dampener (Tag No. 2-1208-V4-002)

The licensee stated:

"These exemptions exclude the applicable vessels from the surface and volumetric examinations required by IWC-2500. The remainder of the Code-required examinations (i.e., pressure tests) would be performed to assure that an acceptable level of safety and quality is' maintained for the applicable components."

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