ML20236C934
| ML20236C934 | |
| Person / Time | |
|---|---|
| Site: | McGuire  |
| Issue date: | 03/16/1989 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-68363, NUDOCS 8903220381 | |
| Download: ML20236C934 (4) | |
Text
7..
y s
DUKE POWER GOMI%NY P.O. DOX 33180 CHAnIAYTTE, N.C. 28242 HALU. TUCKER Teternone
- veou eRusinent poO oh4M1 NtiCLEAR PRODt1CvtON March 16, 1989 U.S. Nuclear Regulatory Commission Document' Control Desk Washington, D.C.
20555
Subject:
McGuire Nuclear Station, Unit 1 Docket No. 50-369 ASME Code Section XI Hydrostatic Testing Requirements Relief Request No. 88-04 (TAC 68363)
Gentlemen:
Pursuant to 10 CFR 50.55a, I submitted the subject relief request by letter dated May 5, 1988 concerning a modification to the Containment Spray Heat Exchanger lA.
You responded to my request by granting relief by letter dated February 23, 1989.
We have reviewed your response concerning this matter and disagree with your i
l finding that we have de-rated the Heat Exchanger by not performing a construction i
code hydrostatic test at 1.5 times the design pressure.
It appears that you have based your finding on the conclusion that this vessel was constructed to the commercial pressure vessel requirements of ASME Section VIII rather than the more rigorous ASME Section III requirements for nuclear components, and thus, requires a more severe hydrostatic test.
l The intent of ASME Section XI does not support that conclusion. For Section XI replacements, which includes modifications and alterations, the ASME Code Committees responsible for Section XI, invoked the original construction code requirements for design, fabrication, and inspection as inferred in IWA-7210. The code does not mention testing requirements because testing is included in ASME Section XI and was intended to supersede construction code testing requirements.
ASME Code Interpretation X7-b83-66, (see Attachment), supports that conclusion.
The Codes justification for not performing the construction code hydrostatic test was dua to:
1)
ASME's concern for personnel safety if manufacturing type tests intended for new components were routinely used on systems whose corrosion allowance was reduced due to years of corrosive service conditions; and, 2)
The possible damage that could occur due to multiple stress loading cycles from high pressure tests above design conditions.
g0d I\\
W*los8kgggggs
- est,
n
= _.
Doedment Control Desk Docket No. 50-369 Relief Request 88-04 March 16, 1989 Page 2 If your interpretation is correct, all repairs and replacements on ANSI B31.1, B31.7, and ASME Section VIII components would require hydrostatic tests at 1.5 times the design pressure since all of these construction codes are less rigorous than ASME Section Ill. dince Section XI was written to address the inservice care of nuclear components, and specifically addressed hydrostatic testing at lower pressures, we feel it is obvious that the Code was written to test only at the lower pressures. Testing at both Construction Code and Section XI requirements is not practical.
If we conclude that the ASME Section XI hydrostatic test was not required, we then need to determine what the minimal hydro pressure is required per ASME Section XI.
In IWD-5223, we see that the required pressure for hydro is 1.1 times Psv (lowest pressure setting of relief valve) or 1.1 times 135 psig equals 149 psig since 1RN-138 is set at 135 psig. By using the vessel design pressure of 200 psig, we conservatively went beyond the code required test pressure of 149 psig.
The reason for submitting Relief Request 88-04 was due to the use of a pneumatic test on the new pressure boundary materials and welds instead of the required hydrostatic test, [IWD-5210(b)). Although it is recognized that a more meaningful test, following alteration of the vessel shell, would be the performance of a hydrostatic test on the entire vessel to observe its integrity at maximum hoop l
stress loads, the Code only requires a pressure test of the new welds and l
material, which was satisfactorily completed.
You may also be interested in the fact that the National Board Inspection Code (NBIC) which, like ASME Section XI, is applicable to inservice components and only l
requires a hydrostatic test after alterations of no greater than Psv or 135 psig i
unless otherwise specified by the Authorized Inspection,,[see Section III R308.3 and Section II I-502.15(b)).
Based on our findings, as stated, we will maintain the current ratinglof the Heat Exchanger. We request that you review our comments and if you still believe the Heat Exchanger should be de-rated, please provide a response. Otherwise, We consider thic issue closed.
Should there be any questions regarding this maLLuc, please contact S.E. LeRoy at (704) 373-6233.
Very truly yours,
- s
/
y Hal B. Tucker SEL/ relief 5/sel Attachment I
v h k'.
~.
'h f:
^
=
- o.
s' 4
1 m
G Document CSutrol Desk.
Docket.No.:50-369 7\\ '
- .x LRelief,Requestl88-04 4>
a 5
March'16,.1989
Page 3-
,\\
6 a
..\\i s
..,. xc:
Mr.. S.D. Ebneter s Regional Administrator,' Region;II
\\c
'3 -
.U.S. Nuclear Regulatory.. Commission' s
'101 Mari6tta St., NW, Suite 2900' 1
Atlanta, GAE30323 1
3 Mr. Darl: Hood, Projhet Manager 3
.U.S. Nucleaf\\ Regulatory Coinmission X
Office'of Nuclear Reactor Regulation' Washington, D'.C.
20555-3..
Mr. P.K.. Van Doorn
,,~
t.
NRC Senior. Resident Inspector McGuire Nuclear Station b-
'\\ -
\\
.A
.g s
,)
s h
s
)
h-s
(
, '.i.
.- x.
t II 1
i i
i
.l 4
\\
h f
l i
l' I~
t I
.k l
s h
j
.' 1 ~
j 4
4 4 I'
..~\\;i ',j,
.f'l,
j a
I t,'
3-
\\-
~
9,
.s_
l s
ll s.
, Y:. s ;
/l]
'.. 3.
t.
s x
t i
s J.
~'p.
'{'\\,,
- s
'7' s
s s
A cg 4
-Q g.
, 'i-
.(.f,
.i
'g jg.
'(
, a;-..
4 mm -
'1
l.
DOCUMENT CONTROL DESK SOCKET NO. 50-369-s" ATTACHMENT RELIEF 8EQUEST NO. 88 <
.N Section XI - beerpretations No.16 -
X8-14345,[NI-14346
~r a
a I..:..g."-tion: XI-14345
)
'.as ; y,a:),WM;.,
,I l
4
.t.-
SubjectO : -
Section XI, Division 1, IWA-4000/7000, Signing of Form NIS-1 and NIS 2 by e the Authorized Nuclear Inservice inspector l
Date issued:
December 12, 1984 File:
BC84447 l
l Question: Is it the intent of Section XI that the Authorized Nuclear Inservice inspector sign both j
l Form NIS-1 and Form NIS-2?
\\
(.
' Reply: Yes, d
Interpretation XI-1-83-66 l
Subject:
Section XI, Division i, IWA-4000/7000, Hydrotesting of Repaired or lieplaced l
Components
)
Date issued:
December 12,1984 File:
BC64-652 Question: When performing repairs and installation of replacemefits uncler the 1977 Edition of p
Section XI., with the Surnmer 1978 Addenda and later Editions and Addanda, are the hydrostatic tests performed (and test pressure used) in accordance with Section XI or the original Construction GWe?
l Reply: When performbg a repair or instal l int; a replacement under Section Xi only, the Section XI hydrostatic tests are perfonned. The original Construction Code hydrostatic bists are not required, f
I 61 1
I z
x
-.