ML20245C729
| ML20245C729 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/31/1987 |
| From: | Capra R Office of Nuclear Reactor Regulation |
| To: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8711030481 | |
| Download: ML20245C729 (4) | |
Text
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October 31c 1987 i
Docket No. 50-318 DISTRIBUTION (Docket-Fileg JScinto NRC PDR TFoley, RI Local PDR LTripp, RI Mr. J. A. Tiernan PDI-1 Rdg.
JWiggins, RI Vice President-Nuclear Energy SMcNeil CWooohead Baltimore Gas & Electric Company RCapra ACRS(10) i P. O. Box 1475 CVogan TMurley-Baltimore, MD 21203 BBoger JSniezek SVarga FMiraglia
Dear Mr. Tiernan:
CRossi EJordan JPartlow TBarnhart(4)
SUBJECT:
AUTHORIZATION TO USE ASME B0ILER AND PRESSURE VESSEL CODE CASE N-416 GPA/PA ARM /LFMB The Commission staff has completed their review of your request for NRC approval to use the ASME Boiler and Pressure Vessel Code Case N-416 as requested in your submittal dated October 31, 1987, as supplemented on October 31, 1987. This request was necessitated by the development of a leak (through wall crack) in
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Calvert Cliffs Unit 2's #22 steam generator bottom blowdown line (2 inch line; line number EB-06-2008) at the third elbow interior of the containment wall.
8 You effected replacement and repair by partial penetration welding a new 2 inch
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line in replacing the line section from the second to the third elbow interior
'of the containment wall in accordance with the requirements of Articles IWC-3000, IWA-4000 and IWA-7000 of Section XI of the 1983 Edition of the ASME Code.
Following replacement of this section of Class 2 piping, you were required by IWA-4400 to perform a hydrostatic pressure test on the portion of pipe repaired /
replaced. 'Your request stated that the performance of this hyrdostatic pressure test is impractical as this line of pipe is unisolable from the #22 steam generator, thus the steam generator would experience an unnecessary pressure transient above its design pressure as a result of the hydrostatic pressure test. The operational lifetime of the steam generator is limited by the number of times it is permitted to be hydrostatically pressure tested above its design pressure.
Consequently, you have requested NRC approval in accordance with 10 CFR 50.55a(a)(3) to use ASME Code Case N-416 rather than performing the required hydrostatic pressure test.
Footnote 6 to 10 CFR 50.55a permits the use of Code Cases not accepted in Regulatory Guide (R.G.) 1.84 or R.G.1.85 upon authorization by the Director of the Office of Nuclear Reactor Regulation upon ' request pursuant to Section 50.53a(a)(3).
Alternatives to the reoufrements of Section XI of the ASME Code l
are permitted by 10 CFR 50.55a(a)(3) if the applicant can demonstrate that
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(i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements of this section would result in hardship or unusual difficulties without a compensating increase in I
the level of quality and safety.
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l 8711030401 871031 PDR ADOCK 05000318 P
PDR m
R.G. 1.147, Revision 5, " Inservice Inspection Code Case Acceptability ASME Section XI Division I", dated August 1986, lists Code Cases that are generally acceptable to the NRC staff for implementation in the inservice inspection of light-water cooled nuclear power plants.
Code Case N-416 is endorsed in R.G.1.147.with no exceptions taken by the NRC staff to the Code Case. This Code Case states that following repair or replacement of Class 2 piping that cannot be isolated by existing valves or that requires securing safety or relief valves for isolation, the deferral of Class 2 piping hydrostatic pressure tests is permitted until the next regular?y scheduled system hydrostatic pressure test.
This deferral is. contingent upon the performance of the appropriate NDE weld examination and of a visual examination for leakage prior to or immediately upon return to service.
These alternative examinations will provide an adequate assurance of the integrity of the welds in the Class 2 piping in questio,1 w the performance of the next required system hydrostatic pressure test.
Your October 31, 1987 request justified the use of Code Case N-416 in accordance with the provisions of 10 CFR 50.55a(a)(3) by stating that requiring the performance of this hydrostatic pressure test would result in hardship without a compensating increase in the level of quality and safety due to the fact that this line is unisolable from the #22 steam generator, and consequently, the steam generator would undergo a pressure transient above its design pressure that would reduce the operational lifetime of the steam generator.
Through R.G. 1.147, the NRC staff has stated that the deferral of this hydrostatic pressure test is acceptable for Class 2 piping contingent upon the performance of the alternate tests required in Code Case N-416.
The NRC staff understands that you shall perform the Article IWA-2220 surface examinations and the VT-2 visual examination for leakage as provided in Code Case N-416. Furthermore, this line shall shall be hydrostatically tested at the nexy regularly scheduled system hydrostatic test.
The staff has determined in accordance with the provisions of 10 CFR 50.55a(a)(3) that your request for authorization to use Code Case N-416 for the section of steam generator bottom blowdown pipe as described above provides an acceptable level of quality and safety and that requiring the performance of the system hydrostatic pressure test prior to the next regularly scheduled test would result in a hardship without a compensating increase in the system's level of quality and safety. Thus, the staff has determined that this request is acceptable.
This letter shall serve as authorization of your request to use Code Case N-416 in lieu of currently performing the hydrostatic pressure test on the #22 steam generator bottom blowda in line as required for system repair / replacement by Article IWA-4400 of Section XI of the 1983 Edition of the ASME Code.
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.The Commission hereby. authorizes,this use:of!ASME" Code Case N-416'for this..
- portionof: Class 2 piping.pursuantto10CFR'50.55a(a)(3)landfinds.thatthis use:of = proposed alternatives to Article IWA-4400 (1) provides an' acceptable level of, quality.and safety,-(2) that compliance with'the Article IWA 4400 requirements would. pose undue hardship not compensated by'the resultant' increase in quality
>and' safety, and (3) is authorized by law and will not endanger life'or property _
or the common defense ~ and security and is' otherwise inethe public interest.,
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Robert A. Capra, Director o
Project Directorate >I-1,
Division of Reactor Projects, I/II cc: ' See next page q
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.10/31/87 10/31/87 10/31/87 10/31/87
i Mr. J. A.-Tiernan'
. Baltimore Gas 8 Electric Company Calvert Cliffs Nuclear Power Plant CC:'
]
Mr. John P. Gott, President Regional Administrator, Region I i
Calvert' County Board of U.S. Nuclear Regulatory Conunission
. Commissioners Office of Executive Director
(.
Prince Frederick, Maryland 20768 for 0)erations l
631 Par ( Avenue l
D.-A. Brune, Esq.
King of Prussia, Pennsylvania 19406 i
General Counsel Baltimore Gas and Electric Company
-P. O. Box 1475 Baltimore, Maryland 21203 Jay E. Silberg, Esq.
1 Shaw, Pittman, Potts and Trowbridge 1
1800 M Street, NW Washington, DC 20036 I
Mr. M. E. Bowman, General Supervisor i
Technical. Services Engineering Calvert Cliffs Nuclear Power Plant MD Rts 2 & 4, P. O. Box 1535 -
Lusby, Maryland 20657-0073 l
1 Resident Inspector j
c/o U.S. Nuclear Regulatory Commission P. O. Box 437 Lusby, Maryland 20657-0073 Bechtel Power Corporation ATTN: Mr. D. E. Stewart Calvert Cliffs Project Engineer 15740 Shady Grove Road Gaithersburg,-Maryland 20760 Combustion Engineering, Inc.
ATTN: Mr. W. R. Horlacher, III Project Manager P. O. Box 500 i
1000 Prospect Hill Road Windsor, Connecticut 06095-0500 i
Department of Natural Resources Energy Administration Power Plant Siting Program ATTN: Mr. T. Magette Tawes State Office Building Annapolis, Maryland 21204
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