ML042730334

Request for Relief No. 04-ON-008

ML042730334
Person / Time
Site:	Oconee
Issue date:	09/13/2004
From:	Rosalyn Jones Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
04-ON-008
Download: ML042730334 (14)

Text

Duke RON A. JONES rs Powers Vice President A Duke Energy Company Oconee Nuclear Site Duke Power ONOI VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3158 864 885 3564 fax September 13, 2004 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Duke Energy Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, -287 Request for Relief No. 04-ON-008 Pursuant to 10 CFR 50.55a(a)(3)(ii), attached is a Request for Relief from certain Non-Destructive Examination (NDE)requirements of the code of record for Oconee Nuclear Station.

Oconee Nuclear Station is performing a modification on each Unit which will upgrade a section of existing piping such that additional NDE will be required. However, a portion of that piping on each Unit is embedded such that NDE inspection of that portion would involve extreme hardship without a compensating increase in the level of quality and safety. Therefore, Duke Energy requests that the NRC grant relief as authorized under 10 CFR 50.55a(a)(3)(ii).

Details are included in the attached request.

If there are any questions or further information is needed you may contact R. P. Todd at (864) 885-3418.

Very ru yours, R. . J es Si e ice President Attachment www.dukepower.com

U. S. Nuclear Regulatory Commission September 13, 2004 Page 2 xc wlatt: Mr. William D. Travers Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St., SWW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 xc(w/o attch):

M. C. Shannon Senior NRC Resident Inspector Oconee Nuclear Station Mr. Henry Porter Division of Radioactive Waste Management Bureau of Land and Waste Management SC Dept. of Health & Environmental Control 2600 Bull St.

Columbia, SC 29201

OCONEE NUCLEAR STATION Units 1, 2 and 3 Request No. 04-ON-008

1. System/Component for Which Relief is Requested:

Oconee Reactor Building Emergency Sump (RBES) embedded drain pipe. The section of pipe is between the RBES and the Auxiliary Building wall.

This piping is part of the drain path from the RBES to the Liquid Waste Disposal (LWD)

System. In addition, following implementation of NSM ON-33106, it will provide part of the High Pressure Injection (HPI) Pump(s) min flow return path to the RBES following a Loss of Coolant Accident (LOCA).

The particular section of piping of concern is the 4" drain piping from the RBES (located in the Reactor Building) up to the inside edge of the Auxiliary Building wall (Ref. OFD-107D-3.2, Attachment 1). The 4" and 2" section of pipe in the Auxiliary Building will be inspected.

Using the definition in the UFSAR, PIP 0-02-1233 identified a discrepancy for this pipe.

The UFSAR, Section 3.2.2.1, states that "Class 11 (Duke Class B) systems nonnally contain radioactivefluid whose temperature is above 2120 F, and in addition, those portionsof EngineeredSafeguardSystems outside the Reactor Building which may see recirculated reactorbuilding sump wvaterfollowving a Loss of Coolant Accident (LOCA). Class III (Duke Class C) systems, orportions of systems, are those which would nonnally be Class 1 except that the containedfluidis less than 212° F. " Currentdesign temperaturefor the RBES drain piping is 3000 F.

NSM ON-33106 will replace the existing LWD pipe with new piping starting approximately 8" from where the embedded pipe exits the Auxiliary Building wall through valve 3LWD-103. The piping and associated components installed by NSM ON-33106 will be Class II, (Duke Class B). The remaining pipe, all that is embedded plus the 8" must be upgraded to Class II (Duke Class B) as required by the UFSAR due to the addition of the HPI pump min flow return path as well as resolve PIP 0-02-1233. Specific welds and item numbers are provided below.

Weld Number Isometric Dwg. No. Rev. No.

62 3-59-0016 14 63 3-59-0016 14 64 3-59-0016 14 65 3-59-0016 14 66 3-59-0016 14 67 3-59-0016 14 68 3-59-0016 14 69 3-59-0016 14

2. Code Requirement:

As stated in PIP 0-02-1233, the current piping classification does not conform to the requirements set forth in UFSAR section 3.2.2.1.

Following implementation of NSM ON-33106, the embedded piping will provide part of the High Pressure Injection (HP]) Pump(s) min flow return path to the RBES following a Loss of Coolant Accident (LOCA). The HPI pump min flow can be considered recirculated reactor Embedded_PipeRR.doc Page I of 5 7/16/2004

OCONEE NUCLEAR STATION Units 1, 2 and 3 Request No. 04-ON-008 building sump water and Class 11 requirements apply. Therefore, the embedded piping of the RBES drain line must be upgraded to Class II (Duke Class B).

Design requirements for Class 11 piping are defined in USAS B31.7 Section 2-701 and 2-702.

The design requirements for Class III piping are defined in USAS B31.7 Section 3-701 and 3-702. Both Class II and Class III default to the same set of rules, specifically USAS B31.1.0-1967. The only difference between Class II and Class III piping as specified in B31.7 is the Non-Destructive Examination (NDE) requirements.

3. Code Requirement from Which Relief is Requested:

The existing RBES embedded drain piping is Class III (Duke Class C). This piping provides a drain path for the RBES to the LWD System. However, upon completion of NSM ON-33106, this piping will also provide a path for the High Pressure Injection (HPI) pump minimum flow to the RBES following a LOCA. The HPI pump min flow can be considered recirculated reactor building sump water and Class II requirements apply. The purpose of this document is to request relief from the NDE requirements of Class II for the existing embedded piping welds. To inspect the embedded piping welds per the Class II requirements would involve extreme hardship without a compensating increase in the level of quality and safety.

Design requirements for Class II piping are defined in USAS B31.7 Section 2-701 and 2-702.

Class II piping requires the following NDE (USAS B31.7 Section 2-727 and Table A.7(b)):

a) 100% radiographic testing of all butt welds (Girth & Longitudinal) b) 100% radiographic testing of branch welds over 4" nominal pipe size c) 100% Liquid Penetrant or Magnetic Particle testing of all fillet/socket/seal/attachment/branch welds The design requirements for Class III piping are defined in USAS B31.7 Section 3-701 and 3-702. Weld inspection requirements during construction for Duke Class C components/piping were not as stringent as those for Class II piping/components. (USAS B31.7 Chapter 3-VI and Table A.7(b)) Specifically, these requirements were:

a.) RT I weld for every 10 butt welds a welder makes over 4" b.) MT/PT 1 weld for every 10 fillet/socket/branch welds over 4" diameter that a welder makes Class II and Class III both default to the same set of rules, specifically USAS B31.1.0-1967.

All new piping installed by NSM ON-33106 will be installed/inspected to the current Class II requirements. The remaining piping is embedded. Complying with the Class II requirement would result in hardship or unusual difficulty without a compensating increase in quality or safety pursuant to 10 CFR 50.55a(a)(3)(ii).

4. Basis for Relief Guidance from OS-0243.00-00-0001, Oconee Piping Specification, Appendix A and Duke Reg. Guide 1.26 was used to evaluate the piping upgrade. The portion of piping to be RR 04-ON-008 RBES Embedded PipePage 2 of 5 7/16/2004

OCONEE NUCLEAR STATION Units 1, 2 and 3 Request No. 04-ON-008 upgraded is identified on OFD-107D-3.2 (Ref. Attachment 1). There are no valves, components or instruments affected. The affected embedded piping welds are 62, 63, 64, 65, 66, 67, 68, and 69 as shown on weld isometric 3-59-0016 (Ref. Attachment 2).

NSM ON-33106 is installing new LWD piping approximately 8" from the embedded pipe through valve 3LWD-103. The new piping and valves for NSM ON-33106 are being purchased, installed, and inspected as Duke Class B ISI Class B (Class II).

Original construction code requirements will be considered in this evaluation for the embedded piping since no modifications or weld repairs have ever been performed on this portion of the RBES drain line. The following items were considered:

Piping Design The existing 4" drain piping from the Reactor Building Emergency Sump (RBES) is shown on OFD-107D-3.2 as Duke Class C (Class III) piping. However, Oconee Piping Summary (OPS-59.00-3) and original weld documentation indicates that the original piping was Duke Class E. PIP 0-02-04984 documents that this piping was upgraded from Duke Class E to Duke Class C. This PIP also performed a review to confirm that the correct NDE was performed on this piping and that the affected weld isometrics were revised.

According to OS-0243.00-00-0001 Appendix A, original Duke Class E piping was designed and installed to the same code requirements as Duke Class C (Class III). Therefore, Duke Class E piping was essentially treated as if it were Duke Class C, with the exclusion of seismic design considerations. Since Duke Class B (Class II) and Duke Class C (Class III) were designed and constructed to the requirements of USAS B31.7, a comparison between the chapters within USAS B31.7 that defined requirements for Class II and Class III was performed.

Design requirements for Class II piping are defined in USAS B31.7 Section 2-701 and 2-702.

The design requirements for Class III piping are defined in USAS B31.7 Section 3-701 and 3-702. Class II and Class III both default to the same set of rules, specifically USAS B31.1.0-1967.

Piping Components Piping design requirements for Class II piping are defined in USAS B31.7 Sections 2-703 through 2-709. The design requirements for Class III piping are defined in USAS B31.7 Sections 3-703 through 3-709. Class II and Class III both default to the same set of rules, specifically USAS B31.1.0-1967. The following two differences existed with respect to pressure design of components (reference section 2-704 and 3-704):

1)Class III allowed the use of Table A.9 stress values.

2) Flanges for Class II piping were designed to a different standard than those for Class III piping.

Following a review of drawings 0-2435B (Ref. Attachment 3) and O-59M (Ref. Attachment 4), it was determined that no flanges are installed in the embedded section of piping.

EmbeddedPipe.RR.doc Page 3 of 5 7/16/2004

OCONEE NUCLEAR STATION Units 1, 2 and 3 Request No. 04-ON-008 Materials Oconee Piping Summary 59.00-03 Rev I shows that the embedded RBES drain line between the emergency sump and valve 3LWD-103 was originally installed as stainless steel piping per Pipe Spec 151.4 (Ref. Attachment 5) which is used for Duke Class C and E piping. Pipe Spec 151.2 (Ref. Attachment 6) is used for Duke Class B piping. A comparison of the two pipe specifications show that the material requirements are the same except as listed below:

• Pipe Spec. 151.4: ASME A-312 material is specified, however SA-312 material may be used per the original requirements of Oconee

• Pipe Spec. 151.2: ASME SA-312 material is specified, however A-312 material may be used per the original requirements of Oconee.

Material requirements for Class II piping are given in USAS B31.7 Sections 2-723, 2-724, 2-725. Material requirements for Class III piping are given in USAS B31.7 Sections 3-723, 3-724, 3-725. The material used for the embedded piping was ASME A-312 which is acceptable for Class II and Class III (Reference USAS B31.7 Table 1-724).

After the piping upgrade, OFD-107D-3.2 (Ref. Attachment 1) will show that the embedded piping as Duke Class B and any future modification to this line will have to be performed in accordance with Class B guidelines.

Examination and Inspection of Welds PIP 02-04984 documents that the weld tickets for the embedded piping were reviewed to ensure that the correct NDE for Class III piping was performed when the piping was upgraded from Duke Class E to Duke Class C.

All new piping installed by NSM ON-33106 will be installed/inspected to the current Class II requirements. The remaining embedded piping cannot be inspected to the NDE requirements for Class II piping without significant hardship.

Fabrication, Assembly, and Erection Chapter 3-V of USAS B31.7 states that fabrication, assembly, and erection for Class III piping shall be in accordance with Chapter 2-V of USAS B31.7 which specifies the fabrication, assembly, and erection requirements for Class II piping. However, USAS B31.7 Section 3-711 allows the use of backing rings or consumable inserts in butt welds for Class III piping. The backing rings do not have to be removed unless they will result in an undesirable condition. USAS B31.7 Section 1-727.2.2 states that backing rings shall not be used for Class 11 piping unless removed after welding and the root examined by magnetic particle. Welding details on 0-499B (Ref. Attachment 7) show that only consumable inserts were allowed for use on the embedded stainless steel piping welds for which relief is requested.

Pressure Test Pressure test for Class II piping is specified in USAS B31.7 Sections 2-737 and 1-737. USAS B31.7 Chapter 3-VI states that examination and testing for Class III piping shall be in accordance with Chapter 2-VI of USAS B31.7 with NDE exceptions as specified in section 9.5 of this evaluation. Therefore, leak testing for Class III piping during construction was the Embedded_Pipe_.RR.doc Page 4 of 5 7/16/2004

L OCONEE NUCLEAR STATION Units 1,2and3 Request No. 04-ON-008 same as the requirements for Class II piping. No additional leak testing is required for the embedded piping since the existing embedded piping will not be modified.

5. Alternate Examinations:

No other examinations or tests are planned.

6. Justification for the Granting of Relief:

As stated in the previous sections, a comparison of the requirements for Class II and Class III show that the subject piping meets all requirements of Class II piping except for the NDE requirements. In order to meet the full requirements of Class II piping, all of the concrete would have to be removed to allow inspection of the subject piping. This action would result in a significant hardship without a compensating increase in the level of quality and safety.

Considering the fact that the subject piping has been in operation for 30+ years without need for maintenance or repair, it is safe to assume there is reasonable assurance supporting structural integrity. All further maintenance or repair activities will be performed according to the requirements of Class II piping.

7. Implementation Schedule:

The piping classification upgrade for the embedded piping will occur via minor modification OE-18227. The piping upgrade should occur in parallel with implementation of NSM ON-33106. The minor modification will not be allowed to be closed until acceptance of the Request for Relief has been received from the NRC. NSM ON-33 106 will be implemented during the fall of 2004. Completion should occur in 12/04.

The following individuals contributed to the development of this RFR: Rickey Burgess (Mech Mod Group), Tim Tucker (NDE Level III), Bob Leatherwood (Systems Engineer) and Basil Carney (Plant Engineering). Tommy Holland (Sponsor) compiled and completed this RFR.

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I-o J. Thomas Holland Reviewed By: Date:

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Specification No.: OS-0243.00-000, Date: January 1, 1983 Page C45 Revision 22, July 1, 2002 Specific Material Requirements PS-- 151.4 Class: D. E. F. G. & H MATERIAL: Stainless Steel of Desianated ASTM Snecification Flange Design Conditions: (B16.5-1968edition)

Pressure (psig) 275 240 210 180 150 130 120 110 Temperature (IF) 100 200 300 400 500 600 650 700 PIPE Size Range 1/2" thru 2" 2 1/2" thru 24" 24" thru 36" Construction smls or EFW smls or EFW EFW

• ASTM Spec. A-312 A-312 A-358, Cl. ll or A-312 Grade TP304 TP304 TP304 Schedule (See "Oconee Flow Diagram")

Fittings Size Range 1/2" thru 2" 2 1/2" thru 24" 24" thru 36" Construction Forged smls or EFW smls or EFW Joint Type Socket Weld Butt Weld Butt Weld

• ASTM Spec. A-182 A403 A-403 Grade F304 WP304 or WP-W304 WP304 or WP-W304 Rating/Schedule 3000# To match pipe To match pipe FlAnRes Size Range 1/2" thru 2" 2 1/2" thru 10" 12" thru 24" 26" & Larger Joint Type Socket Weld Weld Neck Slip-on Weld Slip-on Weld

• ASTM Spec. A-182 A-182 A-182 A-182 Grade F304 F304 F304 F304 Rating 150# 150# 150# 125#

Facing Raised See Table E-4 Raised Raised Raised

• ASME "SA" may be used per the original requirements of Oconee.

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Bolting: See Table E-1 Branch Connection: See Appendix D AI1lAAtAe&04 )

Specification No.: OS-0243.00-000.

Date: January 1, 1983 Page C44 Revision 22, July 1,2002 Specific Material Requirements PS- 151.2 Class: B MATERTAL: Stainless Steel of Desiannted ASMP Snectication Flange Design Conditions: (B 16.5-1968 edition)

Pressure (psig) 275 240 210 180 150 130 120 110 Temperature (IF) 100 200 300 400 500 600 650 700 PIPE Size Range 1/2" thru 2" 2 1/2" thru 24" > 24" Construction smis or EFW smis or EFW eFW

• ASME Spec. SA-312 SA-312 SA-312 Grade TP304 TP304 TP304 Schedule (See "Oconee Flow Diagramn")"

Fittings Size Range 1/2" thru 2" 2 1/2" thru 24" > 24" Construction Forged smls or EFW EFW Joint Type Socket Weld Butt Weld But Weld

• ASME Spec. SA-182 SA-403 SA-403 Grade F304 WP304 or WP-W304 WP-W304 Rating/Schedule 3000# To match pipe To match pipe Flanwes Size Range 1/2" thru 2" 2 1/2" thru 10" 12" thru 24" Joint Type Socket Weld Weld Neck Slip-on Weld

• ASME Spec. SA-182 SA-182 SA-182 Grade F304 F304 F304 Rating 150# 150# 150#

Facing Raised Raised Raised Gasket: See Table E-4 *ASTM "A: may be used per the original requirments of Oconee Boiling: See Table E- I Branch Connection: See Appendix D IRkF d.

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