NG-08-0201, Revised Request to Allow Use of the Provisions of IWA-4132 for Remainder of the Fourth Ten-Year Inservice Inspection Interval
| ML080990626 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 03/28/2008 |
| From: | Richard Anderson Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NG-08-0201 | |
| Download: ML080990626 (7) | |
Text
FPL Enry D uane Arnold Enei'gy Cenqe' March 28, 2008 FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 NG-08-0201 10 CFR 50.55a(a)(3)(i)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Revised Request To Allow Use Of The Provisions Of IWA-4132 For Remainder of the Fourth Ten-Year Inservice, Inspection Interval Referen ce:
1*...
Letter, Richard L. Anderson (FPL Energy Duane Arnold) to Document Control Desk' (USNRC), "Request To Allow Use Of
-T,, e Provisions Of IWA-4,132 For Remaindfr'o f the Fourth Ten-
,Ypr~lnservice Inspection Intrv'al," dated'February 28, 2008, NG-0'8-01 37 On February,,28, 2008-FPL Energy Duane Arnold, LLC (hereafter, FPL Energy Duane Arnqld),submitted th,!e relief request of Reference 1-In l phone calls dated March 13, 200-8 and Mrch 17, 2008, the NRC provide comments concerning Reference 1. This relief request supersedes that of Reference 1.
Pursuant to 10 CFR 50.55a(a)(3)(i), FPL Energy Duane Arnold hereby requests NRC approval of the enclosed request for the remainder of the fourth ten-year Inservice Inspection Interval. The Duane Arnold Energy Center is currently in the 4 th 10-year ISI interval, which began on November 1, 2006. This request is for the "
application of the provisions of IWA-4132 to the stock rotation of Recirculation Pump Seal Flange Assemblies.
It is important to,.,note that the ASME StandardsComm-ittee recently approved Record, Number,07-1j37 whimh r'evises 'IWA-4132 to permit items rotated from stock to include-components that are rotated solely for the pL'rp.se~of~testing.'and preventive maintenance.
FPL Energy Duane Arnold'requests approvalf this request by February 28, 2009.
FPL Energy Duane Arnold no longer requires appro'vai of this re'quest by April 4, 2008, since a mid-cycle,-shut6down to perform-corr6ctive maintenance on the "B",
Recirculation Pump Mechanical Seal, as well as other activitie's'is,sno longer:
planned. The mid-cycle shUtdOwn is no onger planned due in to the stable conditions of the seal. ---The conditions of the "B'. Recirculation Pump Mechanical XW7
NG-08-0201 March 28, 2008 Page 2 of 2 Seal continue to be monitored. FPL Energy Duane Arnold plans to maintain communication with the NRC regarding the condition of the "B" Recirculation Pump Mechanical Seal and the need for this relief.
This letter contains no new commitments nor revises any previous commitments.
If you have any questions or require additional information, please contact Steve Catron at (319) 851-7234.
Richard L. Anderson Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC Enclosure cc:
Administrator, Region Ill, USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC
Enclosure to NG-08-0201 Page 1 of 5 ENCLOSURE (Relief Request NDE-R009)
Request To Allow Use Of The Provisions Of IWA-4132 For The Remainder Of The Fourth Ten-Year Inservice Inspection Interval
Enclosure to NG-08-0201
/
Page 2 of 5 ENCLOSURE (Relief Request NDE-R009)
Request To Allow Use Of The Provisions Of IWA-4132 For The Remainder Of The Fourth Ten-Year Inservice Inspection Interval
- 1. ASME Code Component(s) Affected Code Class:
1
References:
IWA-4000 IWA-4132 Examination Category:
N/A Item Number:
N/A
==
Description:==
Relief to use the provisions of IWA-4132 for the stock rotation of Recirculation Pump Seal Flange Assemblies Component Number N/A
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers (ASME) Section Xl, 2001 Edition with the 2003 Addenda.
3. Applicable Code Requirement
The Duane Arnold Energy Center (DAEC) fourth ten-year interval uses the ASME Section XI, 2001 Edition with the 2003 Addenda.
IWA-4132 "Items Rotated From Stock" states:
"For snubbers and pressure relief valves rotated from stock and installed on components (including piping systems), the following requirements may be used in lieu of all other requirements of IWA-4000, provided the rotation is only for testing the removed items."
(a) Items being removed and installed shall be of the same design and construction.
(b) Items being removed shall have no evidence of failure at the time of removal.
(c) Items being rotated shall be removed and installed only by mechanical means.
(d) Items being installed shall previously have been in service.
(e) Preservice inspections shall be performed as required by IWA-4500.
Enclosure to NG-08-0201 Page 3 of 5 (f) The Owner shall track the items to ensure traceability of inservice inspection and testing records.
(g) Use of an Inspector and an NIS-2 form are not required.
(h) Testing of removed snubbers, including required sample expansions, shall be performed in accordance with Subsection IWF.
4. Reason for Request
IWA-4132 of the 2001 Edition with the 2003 Addenda of ASME Section Xl provides specific requirements for items rotated from stock for the purposes of testing. The items specifically mentioned are snubbers and relief valves. FPL Energy Duane Arnold believes the criteria established in IWA-4132 for snubbers and pressure relief valves for testing can also be applied to the stock rotation of Recirculation Pump Seal Flange Assemblies for preventative maintenance, given that all the cited stock rotations involve mechanical joints on pressure retaining items and that none of these stock rotations involve a repair/replacement activity.
Non-mandatory Appendix J of the ASME Section Xl code provides guidance to help the users of the code determine the applicability of IWA-4000. This appendix establishes that repair/replacement activities are separate from maintenance activities. The examples that are given for repair/replacement activities are:
- 1.
removing weld or material defects;
- 2.
reducing the size of defects to a size acceptable to the applicable flaw evaluation criteria;
- 3.
performing welding or brazing;
- 4.
adding items;
- 5.
system changes, such as rerouting of piping;
- 6.
modifying items;
- 7.
rerating.
The stock rotation of seal flange assemblies does not fall under these examples.
The disassembly and re-assembly of the mechanical connection for the stock rotation of spare Recirculation Pump Seal Flange assemblies is considered a maintenance activity and thus, the use of IWA-4132 for these activities provides an acceptable level of quality and safety, per 10 CFR 50.55a.
The requirements in IWA-4100 would not apply unless there was a repair/replacement activity performed on the spare Recirculation Pump Seal Flange Assembly prior to installation.
Enclosure to NG-08-0201 Page 4 of 5
5. Proposed Alternative and Basis for Use
The Recirculation Pump Seal Flange Assembly consists of the seal cartridge and the seal flange. The seal flange is a pressure boundary component that supports the seal cartridge. The entire assembly (seal flange and seal cartridge) is bolted to the pump casing. During maintenance on the seal cartridge the complete assembly (seal cartridge and flange) is rotated as a single unit.
The normal activity of testing components under the criteria of IWA-4132 involves their removal from their installed location by mechanical means (i.e., disassembly and re-assembly of mechanical joints); this activity constitutes the basis for IWA-4132. IWA-4132 recognizes that, rather than re-install the same component tested, a similar component from stock can be rotated into service in its place.
FPL Energy Duane Arnold believes the criteria established in IWA-4132 for stock rotation of snubbers and pressure relief valves for testing can also be applied to the stock rotation of Recirculation Pump Seal Flange Assemblies for preventative maintenance.
Per IWA-4132:
(a) Items being removed and installed shall be of the same design and construction.
(b) Items being removed shall have no evidence of failure at the time of removal.
(c) Items being rotated shall be removed and installed only by mechanical means.
(d) Items being installed shall previously have been in service.
(e) Preservice inspections shall be performed as required by IWA-4500.
(f) The Owner shall track the items to ensure traceability of inservice inspection and testing records.
(g) Use of an Inspector and an NIS-2 form are not required.
(h) Testing of removed snubbers, including required sample expansions, shall be performed in accordance with Subsection IWF.
The above criteria are planned to be adopted by FPL Energy Duane Arnold for stock rotation of Recirculation Pump Seal Flange Assemblies, as described below:
- 1.
The seal flange assembly being installed will be a like-for-like replacement (same design) and built to the same construction code.
- 2.
The seal flange assembly will have no evidence of failure (failure being defined as the pressure boundary failure).
- 3.
The seal flange assembly will be removed and installed by mechanical means.
Enclosure to NG-08-0201 Page 5 of 5
- 4.
The seal flange assembly will have been previously installed.
- 5.
Preservice and inservice inspections will be completed (i.e. Visual VT-1 of the bolting).
- 6.
As the seal flange assembly is installed, the work will be controlled under the work order process. Unique identification for each item will be tracked and controlled.
- 7.
An Inspector and NIS-2 form will not be used unless the item being installed has been repaired/replaced* in accordance with IWA-4000.
- 8.
Testing of the seal flange assembly will be completed as needed to determine acceptability.
- If there is a repair/replacement activity performed on the item to be installed, FPL Duane Arnold plans to follow IWA-4000, including the use of an Inspector, NIS-2 form, and pressure testing.
FPL Energy Duane Arnold has one spare Recirculation Pump Seal Flange Assembly for the DAEC, which is used as stock rotation for preventive maintenance. The Recirculation Pump Seal Flange Assembly is rotated from stock when the mechanical seal starts to show signs of wear prior to its failure.
This spare Recirculation Pump Seal Flange Assembly has been previously installed and subsequently refurbished by replacing seal components which are not pressure retaining. FPL Energy Duane Arnold considers this stock rotation to be a maintenance function (disassembly and re-assembly of mechanical joints) and not a repair/replacement activity, per IWA-4000.
Since IWA-4132 does not specifically include the stock rotation of Recirculation Pump Seal Flange Assemblies, FPL Energy Duane Arnold requests the use of the criteria stated above for the stock rotation of Recirculation Pump Seal Flange Assemblies as an alternative to the requirements of IWA-4000 for the fourth ten-year interval.
It is important to note that IWA-4132 of the 2004 Edition of the ASME Section Xl code includes preventative maintenance in the rotation of stock items.
Because the basic activity~of disassembly and re-assembly of the mechanical joint is the same between the requested activity and that currently permitted, the proposed alternative would provide an acceptable level of quality and safety, and would not adversely impact the health and safety of the public.
6. Duration of Proposed Alternative
This alternative will be used for the remainder of the DAEC fourth ten-year inspection interval.