ML20244D225

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Comments on Util Application for Authorization to Utilize Alternate Requirements of 10CFR50.55a Re RCPB Components. NB-2211 Requirements of Section III for Class 1 Components Not Met
ML20244D225
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 02/15/1985
From: Knight J
Office of Nuclear Reactor Regulation
To: Novak T
Office of Nuclear Reactor Regulation
Shared Package
ML20238A944 List:
References
FOIA-87-438 NUDOCS 8502210392
Download: ML20244D225 (3)
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.t g NUCLEAR REGULATORY COMMISSION W ASHINGTON, D. C. 20555

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FEB 151985' ".

Docket No. 410 MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing '

Division of Licensing FROM: James P. Knight, Acting Director Division of Engineering

SUBJECT:

APPLICATION FOR AUTHORIZATION TO UTILIZE AN ALTERNATE TO THE REQUIREMENTS OF 10 CFR 50.55a FOR THE NINE MILE POINT NUCLEAR STATION UNIT 2 DOCKET NO. 50-410 The Mechanical Engineering Branch has completed its review of the Niagara Mohawk Power Corporation (NMPC) application for authorization to utilize an alternate to the requirements of 10 CFR 50.55a(c)(1). 10CFR 50.55a(c)(1) requires components which are part of the Reactor Coolant Pressure Boundary (RCPB) neet the requirements for Class I components ir.

Section III of the ASME Boiler and Pressure Vessel Code. 10CFR 50.55a(a)(3) further states.that alternates to the requirements of paragraph (c) of this section may .be used when euthorized by the Director of the Office of Nuclear Reactor Regulation under certain conditions.

NMPC proposes to utilize as a main steam isolation valve (MSIV) a valve that meets all the requirements of the ASME Code for Section III, Class 1, components with the exception of paragraph NB-2211. NB-2211 requires that the material for the tensile and impact test specimens be heat treated in the same manner as the component including an allowance for any subsequent heat treatment. The one MSIV under consideration is identified as valve 7A and is located outside the primary containment in steam line A. This -

24-inch valve (cne of eight) was designed and fabricated by Gulf &

Western Manufacturing Company / Fluid Systems Division (currently Crosby Valve Divistor of Moorco Company) under their ASME Section III program and Certificate of Authorization and was Code stamped N Class I. The valve body, which was manufactured by cameron Iron Works, is a ,

carbon-manganese steel forging conforming to the requirements of material l specification SA 350 Grade LF2. During a review of documentation on the MSIV's, it was discovered that the material used for the test specimens for valve body 7A was nonnalized, austenitized and water quenched and then tempered for six hours at 1200'F, whereas, the valve body itself was normalized, austenitized and water quenched, tempered for six hours at 1200*F and then subjected to approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> of postweld heat treatment (PWHT) at 1125'F. Therefore, the requirements of NB-2211 of Section III for Class I components have not been met and the body of valve 7A is not in conformance with the ASME Code. That is, while the

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d Thomas M. Novak ..

N i heat treatment on the test material specimens and the valve body are identical the test material specimens were not subjected to simulated PWHT as required by the ASME Code. l In order to demonstrate that MSIV.7A is acceptable, an independent metallurgical evaluation was conduct'ed by Dr. R. D. Stout of Lehigh L University to determine the effects of the time at temperature during PWHT, Although the valve body received approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> of PWHT, i

PWHT in the future if needed during plant life.the evaluation was p The evaluation showed that because temperature is the domin6nt factor, tempering has the major effect on the additional material properties and that PWHT has a negligible effect.  !

There would not, therefore, have been a significant difference in the test results if the test material specimens had been subjected to simulated PWHT.  ;

L Since the test values are considerably ~

above the minimum values required by the material specification, this l difference material would not have caused the values to fall below those of the specification.

The valve body is, therefore, acceptable.

Actions which could be taken to bring MSIV 7A into total compliance with Section III, unusual Class 1, of the ASME Code would result in hardship and difficulty.

These actions are (1) cutting and testing specimens from the valve itself, or. (2) complete replacement of the valve body.

Both of these actions involve extensive rework and would not result in a compensating increase in the level of quality and safety of the plant.

Therefore, the NRC staff finds that MSIV 7A as currently fabricated and installed is acceptable and will provide an acceptable level of safety.

Since MSIV 7A is not in total compliance with Section III of the ASME Code for Class 1 components and, therefore, should not have a Code N-Symbol Stamp or a completed Data Report (Form NPV-1), we require the following actions be implemented by NMPC to reflect the current status of the valve: -

(1) Revise the Design Specification as appropriate. Advise the manufacturer and the ANI who signed the Certificate of Compliance and Certificate of Shop Inspection on the Data Report Form NPV-1 that your findings indicate that the Code Rules have not been met Formtheir and records to this should be so modified. < Annotate the Data Report effect.  ;

i (2)

Remove or deface the Code N-Symbol Stamp on the' valve nameplate.

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?1g Thomas M. Novak '

In addition to.the above, MSIV 7A shall remain within the scope of the' hine Mile Point Unit 2 Quality Assurance Program that is in conformance with 10 CFR 50, Appendix B for RCPB components and shall be tested as a Category A valve in accordance with an Inservice Testing Program that is L in conformance with Section XI of the ASME ..

Code.

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f James P. nigh , Acting Director ivision of Entjineering cc: M Miraglia DL A. Schwencer, DL M. Haughey, D W. Johnston, DE B. D. Liaw, DE ,

W. Hazelton, DE D. Sellers, DE -

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R. Bosnak, DE '

H. Brammer, DE R. Kirkwood, DE CONTACT: R. Kirkwood, DE: NEB, x28436 l

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