RC-02-0093, Relief Request for Utilization of Code Case N-597

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Relief Request for Utilization of Code Case N-597
ML021350189
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 05/13/2002
From: Byrne S
Carolina Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RC-02-0093
Download: ML021350189 (4)


Text

Stephen A. Byrne Senior Vice President,Nuclear Operations 803.345.4622 May 13, 2002 A SCANA COMPANY RC-02-0093 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 RELIEF REQUEST FOR UTILIZATION OF CODE CASE N-597 South Carolina Electric & Gas Company (SCE&G) is requesting approval for relief from the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1989 Edition, (no addenda), the In-service Inspection Code of Record (Code of Record) for VCSNS. This relief would allow code case N-597 to be used for determining the structural integrity of components degraded by wall thinning as a result of flow accelerated corrosion.

The description of this alternative, including justification, is included as an attachment to this letter. SCE&G requests NRC review and approval of this request by 5/22/02 so that VCSNS can complete an evaluation of wall thinning identified in a feedwater pipe elbow. This component is the first 18" 90 degree elbow located downstream of feedwater flow control valve IFV00498-FW (Loop "C"). VCSNS is currently shutdown for its 1 3 th refueling outage. This issue must be resolved prior to startup. Replacing the elbow at this time would have a severe impact on the outage schedule due to the complexity of such an emergent task. The job could not be performed within our current window of opportunity. The overall length of the outage would therefore be extended accordingly. The wear rate evaluation shows that the elbow will be acceptable for another cycle using the N-597 methodology. Replacement of this elbow is currently scheduled for the next refueling outage utilizing improved materials not readily available on a short notice basis.

SCE&G is submitting the attached relief request in accordance with 10CFR50.55a(a)(3)(i) and a(a)(3)(ii).

SCE&G I Virgil C.Summer Nuclear Station - P.0.Box 88 . Jenkinsville, South Carolina 29065 . T(803) 345.5209

  • www.scana.com

Document Control Desk NRR 02-1518 RC-02-0093 Page 2 of 2 Should you have any questions, please call Mr. Robert Sweet at (803) 345-4080.

Very truly yours, Stephen A. Byrne RGS/SAB/dr Attachment c: N. 0. Lorick N. S. Cams T. G. Eppink (w/o Attachment)

R. J. White L. A. Reyes K. R. Cotton NRC Resident Inspector K. M. Sutton RTS (NRR 02-1518)

File (810.19-2)

DMS (RC-02-0093)

NUCLEAR EXCELLENCE - A SUMMER TRADITION!

Document Control Desk Attachment NRR 02-1518 RC-02-0093 Page 1 of 2 South Carolina Electric & Gas Co. (SCE&G)

Virgil C. Summer Nuclear Station (VCSNS)

Relief Request

Subject:

VCSNS desires to incorporate Code Case N-597 into the program used for determining the structural integrity of components degraded by flow-accelerated corrosion.

Components:

System: Miscellaneous safety related and quality related piping systems.

Components: Carbon and low-alloy steel piping components monitored for flow accelerated corrosion.

ISI Class: 2 and 3.

Current Code Requirement:

ASME B&PV Code Section Xl (IWA-3100) provides the process for the disposition of flaw examination evaluations that exceed the acceptance standards for materials and welds specified in the Code applicable to the construction of the component. This provision stipulates that the disposition shall be subjected to review by the regulatory and enforcement authorities having jurisdiction at the plant site.

Alternative Requirement:

As an alternative to the requirements of IWA-31 00, "Evaluation," the VCSNS proposes to use the provisions of ASME B&PV Code Case N-597 for the analytical evaluation of Class 2 and 3 carbon and low-alloy steel piping items subjected to wall thinning as a result of flow-accelerated corrosion rather than to repair the component if the construction code minimum wall thickness has been reached. This Code case stipulates that the methods of predicting the rate of wall thickness loss and the predicted remaining wall thickness shall be the responsibility of the owner. VCSNS has procedural controls in the Flow-Accelerated Corrosion (FAC) Program that provide direction for calculating wear rates, forecasting remaining life, and conducting inspections of piping components susceptible to FAC. The methodology is consistent

Document Control Desk Attachment NRR 02-1518 RC-02-0093 Page 2 of 2 with industry standard NSAC-202L-R2, "Recommendations for an Effective Flow Accelerated Corrosion Program," for calculating wear rates, forecasting remaining life, and conducting inspections as programmatic requirements. In the VCSNS program, the terms "should" and "shall" are treated as follows:

"Shall" indicates a mandatory requirement.

"Should" indicates a non-mandatory requirement, but is considered the preferred method to comply with a specific requirement, unless otherwise determined by engineering support personnel or management.

These terms are defined in procedure ES 421, Flow-accelerated Corrosion Program.

Basis for Request:

Code Case N-597, Requirements for Analytical Evaluation of Pipe Wall Thinning,Section XI, Division I, provides an acceptable approach for determining the structural integrity of components degraded as a result of flow-accelerated or other corrosion phenomena. The methodology specified in the code case is sufficiently conservative, and thus provides an adequate margin of safety for evaluating a component's structural integrity. Maintaining the option of using Code Case N-597 will facilitate the scheduling of the replacement of components degraded by wall thinning as a result of flow accelerated corrosion.

The NRC has previously approved the use of Code Case N-597 for Hope Creek and Salem Nuclear Generating Stations in a letter dated October 12, 2000 (TAC Nos.

MA8595, MA8600 and MA8601).

Approval to use Code Case N-597 was also granted to Surry Power Station units 1 and 2 and North Anna Power Station Units 1 and 2 in a letter dated September 10, 2001 (TAC Numbers MB2276, MB2277, MB2223, and MB2284). Note also that VCSNS has the same code of record as North Anna Unit 1 and Surry Units 1 and 2.

Implementation Schedule Upon NRC approval, the proposed alternative, i.e., Code Case N-597, will be implemented immediately.