B12687, Forwards Relief Request 6.0 for Relief from ASME Code Section XI Requirements for Sys Hydrostatic Test.Request Due to Variations in Elevation Test Boundary That Do Not Allow for Testing within Pressure Range Required by Code.Fee Paid

Forwards Relief Request 6.0 for Relief from ASME Code Section XI Requirements for Sys Hydrostatic Test.Request Due to Variations in Elevation Test Boundary That Do Not Allow for Testing within Pressure Range Required by Code.Fee Paid

ML20235H125
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/23/1987
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
B12687, NUDOCS 8709300384
Download: ML20235H125 (4)

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.a ATOMIC POWER COMPANY C CONNECTICUT YANKEE T E LE PHONE P.o box 270 B E R L I N, CONNECTICUT HARTFORD. CONNECTICUT 06141 0270 203-665-s000 September 23,1987 Docket No. 50-213 B12687 Re: 10CFR50.55a(g)

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Haddam Neck Plant Request for Relief from ASME Code Section XI Requirements for System Hydrostatic Testing (Relief Request 6.0),

Pursuant to 10CFR50.55a(g)(3)(iii), Connecticut Yankee Atomic Power Company (CYAPCO) requests relief from performing the system hydrostatic test within the required test pressure range for all elevations within the RCP Seal Water Return System.

This request is being made because there are unisolable portions of the system that, because of variations in elevation in the test boundary, do not allow testing within the pressure range required by the code.

I Attachment I contains Relief Request 6.0. Should you have any additional questions on this relief request, please contact us d.irectly.

Pursuant to the requirements of 10CFR170.12(c), enclosed for Relief Request 6.0 is an application fee of $150.00.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY E. J ifocika g H

Sen[ior Wce President

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D cc: W. T. Russell, Region 1 Administrator F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant dI$05g j:

3. T. Shediosky, Resident Inspector, Haddam Neck Plant /

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Docket No. 50-213 B12687 Attachment 1 Relief Request 6.0 September 1987

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- U. S. Nuclear Regulatory Commission B12687/Page1 September 23,1987 Relief Request Code Class: 2 Examination Category: D-B Item Number B2.10 i i

System i d

RCP Seal Water Return System (System operating pressure is between 40 and 60 psig.)

1 Components l Piping and components included in the system hydrostatic test boundary. 1 l

Code Requirement Section XI of the ASME B&PV code,1980 Edition with Addenda through Winter l 1980, subarticle IWA-5256(b) states in part, "... the imposed pressure on any j component, including static head, will not exceed 106% of the specified test pressure for the system." j l

Code Relief Request Pursuant to 10CFR50.55a(g)(5)(iii), relief is requested from performing the system hydrostatic test at the required test pressures for all elevations within the system.

Reason for Relief Unisolable portions of the above system within the hydrostatic test boundary exist such that there are variations in elevation within the boundaries that would result in imposed pressures in excess of 6% of the specified test pressure. From the lowest portion of the system (floor level where the seal water heat exchanger is located, elevation-19') to the highest portion of the system (BA-MOV-366 and 369 are located - at the first level of the PAB) represents an elevation difference of 45' and corresponds to a static head of approximately 20 psi. This differential is greater than the allowed range of test pressures for the RCP Seal Water Return system. The minimum allowed test pressure for the Haddam Neck Plant RCP Seal Water Return system is 154 psig while the maximum allowed test pressure is 106% of this or 163 psig. This allows only a 9 psig range. Therefore, unless the system can be isolated to limit the ef fects of a static head to less than 9 psi (which it cannot be), the Code requirements cannot be met. Therefore, it is Connecticut Yankee Atomic Power Company's desire to limit the test pressure imposed on system components to 106% of the specified test pressure (as required by paragraph IWA-5265(b)). Thus, due to the ef fects of static head, portions of the piping at higher elevations will be subjected to a test

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U. S. Nuclear Regulatory Commission B12687/Page 2 September 23,1987 pressure lower than that specified. There is no practical method for isolating the piping segments to achieve the required test pressure at all elevations.

Proposed Alternative Examination Hydrostatic testing of the RCP . Seal Water Return system that cannot be isolated to meet the system test pressure at the test boundary high point and the 106% system test pressure maximum at the test boundary low point shall be conducted by pressurizing to 106% of the system test pressure at the low point in the test boundary. Instrumentation will be set up at the lowest accessible point to indicate when 163 psig is attained. Pressure indication at the first level of the PAB will also be noted and is expected to be approximately 140 psig.

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