ML17256A474

Forwards Info Completing Response to 811230 SER Re SEP Topic III-1, Quality Group Classification of Components & Sys. Topic Complete

ML17256A474
Person / Time
Site:	Ginna
Issue date:	01/24/1983
From:	Maier J ROCHESTER GAS & ELECTRIC CORP.
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
TASK-03-01, TASK-3-1, TASK-RR NUDOCS 8301310322
Download: ML17256A474 (31)

Text

RE'GULATORY ORMATION DISTRIBUTION SYS (RIDS)

ACCESSION NBR;8301310322 DOC ~ DATE: 83/Oi/24 NOTARIZED; NO FACIL:50-244 Robert Emmet Ginna Nuclear Plantg Uni't ig Rochester G

AUTH,NAME AUTHOR AFFILIATION MAIERgJ,E~

Rochester Gas 8 Electr ic Corp+

RHC IP ~ NAME RECIPIENT AFFILIATION ORUTCHF IELDp D ~

Oper ating Reactor s Branch 5

il SUBJECT; Forwards info completing response to 811'230 SER ve SEP Topic III"1~ "Quality Group Classification of 'Components 8

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~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649 JOHN E. MAILER Vice Presklent 7ELEPHDNE ARE* CODE 716 546 2700 January 24, 1983 Director of Nuclear Reactor Regulation Attention:

Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch No.

5 U.S. Nuclear Regulatory Commission.

Washington, D.C.

20555 '

Subject:

SEP Topic III-1, Quality Group Classification of Components and Systems R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Crutchfield:

The NRC provided RG&E with a Safety Evaluation Report regarding this topic, by letter dated December 30, 1981.

Also included was a Franklin Research Center Technical Evaluation Report TER-5257-429.

RG&E responded to a number of the issues raised in a letter dated June 25, 1982.

The purpose of this letter is to document the completion of the balance of the required evaluations.

For simplicity, the attachment to this letter will repeat the infor-mation contained in our June 25, 1982 letter, such that all of the information needed to respond to the December 30, 1981 SER/TER is available collectively.

RG&E concludes that SEP Topic III-1 is complete, with no additional analysis or modifications required.

Very truly yours, Joh E. Maier Attachment 830i3i0322 830i24 PDR ADOCK 05000244 P

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Attachment:

Resolution of Fracture Toughness Exemptions for Items Noted in 12/30/81 SER Regarding SEP Topic III-1, Classification In Section V.l of the December 30,

1981, SER it was noted that for many of the 77 components, insufficient information was provided to define exemption from fracture toughness requirements.

RG6E has reviewed Table 5-1 of the FRC TER, and is providing the following information to complete the evaluation for these components.

Com onent Reason for Exem tion Pressurizer Pressurizer Relief Tank Accumulators with Piping and Valves to RCS and from N2 Supply Piping and Valves to CSS Pumps from RWST and from Spray Additive Tank Interconnnecting Piping and Valves from CSS Pump Discharge to CSS Spray Nozzles See Evaluation 1

This tank is not safety-related; is not required to meet code requirements 8d (pipes, fittings, pumps, and valves, with nominal pipe size of 6 inch diameter or less) 8e (austenitic stainless steel) for accumulator piping See Evaluation 2 for accumulators 8a (thickness

< 5/8")

Sd 8d Non-Regenerative Heat Exchanger Shell Side 8a Charging Pump Accumulators 8e Excess Letdown Heat Exchanger Shell Side Seal Water Heat Exchanger Shell Side 8a 8a 1

T e reasons for exemption (e.g.,

8a, 8d) are those used in FRC Report TER-5257-429 which addressed this SEP Topic

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Com onent Deborating Demineralizer Valves in Piping (Loop A)

Line Via Excess Letdown Heat Exchanger To and Including Valve HCV 133 Valves in Charging Line from Pump Discharge to Containment Isolation Valve Reason-for Exem tion Non Safety-Related Sd 8d Valves in Remainder of Interconnecting Piping and Valves 8d Valves from TCV145 Via Demineralizer to Valves 1106 and 1107 Sd Valves from BAT Via Boric Acid Transfer Pump and Filter RHR Heat Exchanger Shell Side CCW Pumps CCW Heat Exchanger Shell Side CCW Surge Tank Interconnecting Piping and Valves Service Water Pumps Piping and Valves Required for Containment Cooling Remaining Piping and Valves and Those Outside the Turbine Building Main Steam Safety Valves Main Steam Piping and Valves Sd 8a See Evaluation 3

8a 8a 8a See Evaluation 4 8a 8a 8d See Evaluation 5

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3 Com onent Piping and Valves from Main Steam Zine to AFW Pump Turbine 8d Reason for Exem tion Feedwater Piping and Valves See Evaluation 6

Auxiliary Feedwater Pumps Motor Driven Auxiliary Feedwater Pump

. Turbine Driven Condensate Storage Tanks Piping and Valves from Pump Discharge to Valves 4000 C,

D Piping and Valves from Pump Discharge to 4003, 4004 Piping and Valves to Suction of AFW Pumps Turbine Driven Pump Lube Oil Tank,

Pumps, and Piping Containment Isolation System 8d 8d Not Safety-Related Sd Sd Sd 8a and 8d Cl System included in above systems 2.

In Section V.2 of the December 30 SER, it was noted that information regarding radiography reguirements was needed for certain pressure vessels..

a.

Provide information regarding radiography imposed on Category C welds for specified pressure vessels:

(l)(5)

Regenerative heat exchanger and excess letdown heat exchanger (tube side).

These were originally specified as Class A vessels, rather than Class C vessels.

These will be discussed in b. below.

(2)(6)(8) Non-regenerative heat exchanger, the RHR heat exchangers, and the seal water heat exchanger.

These are Class 2

vessels on the tube side only.

Thus, no Category C weld requirements apply to the Class 2 portions of these heat exchangers.

(3)(4)(7) Accumulators, volume control tank, reactor (8)(9) coolant filter, seal water injection filter and charging pump accumulator.

The accumulators are discussed in Westinghouse Equipment, Specification E-676448, dated March 15, 1967. It requires that, all main seams of the

. accumulators are to be fully radiographed per ASME

Code, Section 8, Paragraph UW-51.

The charging pump accumulator (sometimes called the charging pump filter) composite record for Job N-8650 also indicates that all butt welds were radiographed.

Also, the above pressure vessels are included in the "Robert E. Ginna Nuclear Power Station Inservice Inspection Program Plans for Quality Groups A, B, and C Components 1980 through 1989 Interval",

SWRI Project, 17-5934, dated January 1980.

Finally, it should be noted that, althouqh these pressure vessels are Class 2 components, their fal.lure would not result in the release of significant amounts of radiation.

The failure of the volume control tank was analyzed in the Section 14.2.3 of FSAR as a Design Basis Accident.

The radiological consequences of this failure were well within the guidelines of 10CFR 100.

RG6E thus concludes that, based on the original radiography performed on some of the pressure

vessels, the inclusion of these pressure vessels in the present ISI program, and the mxnor consequences associated with any potential equipment failures, no additional radiography requirements are warranted.

b.

C.

Compare radiography requirements for the regenerative Hx and excess letdown Hx to current Class 1 requirements.

It was noted in the Ginna FSAR that the regenerative heat exchanger and the excess letdown heat. exchanger were considered Class C vessels.

However, the equipment specifications for these items actually specified the regenerative heat exchanger and the tube side of the excess letdown heat exchanger as Class A vessels.

Thus, the fatigue analysis and radiography requirement, deficiencies for these vessels do not apply.

Provide radiography requirements for Class 1 and 2

welded joints.

Confirmation that Code Case N-7 (B31.1) was applied to all Class 1 and 2 piping would resolve this concern.

RG&E has confirmed that Code Case N-7 was used specifi-cally for certain Class 1 and Class 2 piping systems, such as the primary loop and the Safety Injection System.

In the specifications for other Westinghouse-

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supplied systems, the statement is made that, ASA B31.1 and all applicable nuclear code cases would be used.

No specific mention of Code Case N-7 is made for these systems.

However, Westinghouse Equipment Specification E-676262, dated April 29, 1966 provides the weld inspection schedule for Westinghouse-supplied piping systems.

All piping from Class 2501 to Class 601R was 100% radiographed.

10% to 20% random radiography was required for the balance of the welds, with evidence of'nacceptable quality corresponding to random radiography being a

cause to require 100% radiographic inspection.

The remaining classes of piping (601 non-radioactive,

602, 301,

302, and 151) are primarily:

-piping systems at or near the range of atmospheric temperatures up to 212'F (to which provision 2 of Code Case N-7 does not apply)

-class 3 systems For GAI supplied piping systems, GAI Specification SP-5291, dated December 23, 1966, provides the following radiography requirements:

Radiographic inspection is to be made of all field butt welds and all field nozzle welds 4" and larger, for the following systems (only those of Class 2 are discussed below):

-Main steam system up to main steam stop valves, and connected piping for main steam safety valves and steam admissz.on to the AFW pump turbine

-Feedwater piping to the first check valves outside containment, (3992 and 3993)

-steam piping to the AFW pump turbine

-auxiliary feedwater piping

-steam qenerator blowdown piping to the containment, isolation valve

-service water piping, including inside containment Also, all shop butt, welds, and all 4" and larger nozzle

welds, are required to be radiographed for the above systems.

Finally, the main steam and feedwater piping systems in the Intermediate Building and portions of the Turbine Building are included in the augmented ISI program, which required a

new base line radiographic inspection of 100% of welds in the subject high energy piping.

This program has been reviewed and approved by the NRC, most recently in the review of SEP Topic III-5.B, "Pipe Break Outside Containment",

SER dated September 4,

1981.

Based on the above evaluation, RGSE concludes that the radiography requirements imposed on the original piping and valves for Ginna compare favorably with current criteria.

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,3.

In Section V.3 of the December 30, 1981

SER, RG&E was asked to provide, on a sample basis, information regarding the design of valves in order to determine if:

-Class 2 and 3 valves meet, current pressure-temperature ratings

-Class 1 valves meet current body shape requirements RG6E has made an extensive sampling comparison, and determined that, in almost all cases, the original pressure-temperature ratings were more restrictive than those defined in ANSI B16.34-1977.

The valve specifications designate that the valve body materials be A312 Type 304, A358 Type 304, A376 Type 304 (all Group 2.1 materials),

A312 Type 316 or,A358 Type 316 (Group 2.2 materials),

A105, A216WCB (Group 1.1 materials) and A216WCC (Group 1.2 materials).

In only one instance evaluated, for ASA 1505 Class, did the Ginna specifications allow a higher working pressure for the designated temperature, and the difference was only 5 pounds (2108 vs.

2055 at 300'F, and 2405 vs.

2355 at 200'. F).

This is a very minor difference, especially since hydrostatic testing of the systems was originally performed at 125% of design pressure.

It is thus considered that the pressure-temperature ratings for the Ginna Class 2 and 3 valves compare favorably with current criteria.

It was also requested that valve body shapes for Class 1

valves be compared to current criteria designated in the ASME Code, NB-3544.

A drawing review of a sample of Class 1 valves was conducted to determine if there appeared to be any significant differences from the valve body shape requirements of NB-3544.

From the drawings, it appeared that 1) there were no sharp fillets at the intersections of the surfaces of the pressure retaining boundary at the neck to body junction (with 2

> 0.3 tm), 2) body internal contours were generally smooth in curvature,

3) flat sections were minimized, 4) body contours at weld ends were smooth and gradual.

More detail is not readily available; however, this sampling indicates that Class 1 valves installed at Ginna have body shapes which are not significantly different from present Code requirements.

Further, during the 13 years of Ginna Station operation, periodic testing, and inservice inspection, no apparent failures due to severe stress concentrations resulting from unacceptable valve body shape contours have occurred, or have been observed.

It is thus considered that valve body shape requirements for Class 1 valves at Ginna are not of concern.

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In Section V.4 of the December 30, 1981 SER, it was requested that RG&E provide the codes and requirements to which the Gas Stripper Pumps, Service Water Pumps, and Lube Oil Pumps for the Turbine Driven AFW pump bearings were designed.

RG&E is evaluating the Service Water Pumps as part of SEP Topic III-6.

This analysis is being performed to current seismic criteria.

Modifications resulting from this analysis will be performed to ensure that the Service Water Pumps are acceptable.

Current code requirements will be considered in the evaluation of these modifications.

The gas stripper pumps are not safety-related.

Thus, no additional evaluation of the requirements for these pumps are considered necessary.

Also, as noted in paragraph 3 above, the turbine driven auxiliary feedwater

pump, and its auxiliaries, perform safety functions which can be performed by other safety-related

pumps, such as the Standby Auxiliary Feedwater Pumps.

In Section V.5 of the December 30, 1981

SER, RG&E was requested to provide the below-listed information relative to the design of the Refueling Water Storage Tank, Boric Acid

Tanks, CVCS Holdup Tanks, CCW Surge Tank, AFW Condensate Storage

Tank, and Turbine Driven AFW Lube Oil Tank.

a 4 Confirm that the atmospheric storage tanks meet current compressive stress requirements.

This evaluation will be performed in conjunction with the seismic analysis being performed on the RWST and the boric acid storage

tanks, as required by resolution of SEP Topic III-6, Seismic Design Considerations.

Note that the evaluation will not be performed for the Condensate Storage Tank (CST), the CVCS Holdup Tanks, and the Turbine Driven AFW Lube Oil Tank, since they are not, required to perform a safety function.

Both the CST, which provides suction to the AFW System, and the Turbine Driven Auxiliary Feedwater

pump, have functions which can be performed, by other safety-related systems (the Service Water System and the Standby Auxiliary Feedwater

System, respectively).

The failure of the CVCS Holdup Tanks would not release significant activity (failure would be bounded by a Volume Control Tank rupture, which was analyzed in Section 14.2.3 of the

FSAR, and found acceptable).

It should further be noted that the CCW surge tank has a 150 psig design pressure, and should have been reviewed as a pressure vessel.

Since the fracture toughness exemption 8a applies for this tank, and the stress limits between current and present codes are comparable for Class 3 vessels (see pA-83 of the TER), no additional analysis is required for this tank.

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b.

Confirm that the 0-15 psig storage tanks meet current tensile allowables for biaxial stress field conditions.

RG&E will confirm that the tensile stresses are met, in conjunction with the seismic analyses being performed for the two kinds of tanks listed in 3a above.

c.

Provide the codes or requirements to which Refueling Water Storage

Tank, Condensate Storage

Tanks, and Turbine Driven AFW Lube Oil Tank were designed.

The analysis of the RWST is being performed to current regulatory seismic criteria.

Modifications resulting from this analysis will be performed to ensure that the RWST is acceptable.

Current code requirements will be considered in the evaluation of these modifications.

As noted in 3a and 3b above, the Condensate Storage Tanks and the Turbine Driven AFW Lube Oil Tank are not, reguired to perform a safety function.

No additional information is thus required to be submitted.

In Section V.6 of the December 30, 1981

SER, RG&E was asked to confirm the assumption used in FRC's temperature loading calculations, that the temperature drop from 100% power to 0% power is comparable to that of the Palisades Plant (64'F).

For the Ginna Plant, the temperature drop is 602.5 547

= 55.5'F.

RGSE was asked to complete sections of Table 4.2 of the Franklin TER:t Code a

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b.

C.

Charging pump accumulator SAFW including valves 9704 and 9710 AFWS Piping Related to T-D Pump ANSI B31.7-1968 ASME III (1974) Class 2

ASA B31.1 (1955) d.

CVCS Gas Stripper Pumps e.

SWS Pumps f.

AFWS Pumps Used for Lubricating Turbine Bearings g.

AFWS Turbine-Driven Lube Oil Tank Westinghouse Eguipmeyg)

Specification 676428 GAI Specification RO-2204 (9/16/66)

Westinghouse Eguipmeyp)

Specification 676428 Not available GAI Specs z.cation RO-2204 specifies that these pumps shall be designed and manufactured in accordance with accepted current standards of the electric utility industry and shall satisfy all applicable

Codes, including state and local ordinances, pertaining to the design and operation of such equipollent.

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Evaluation 1

Pressurizer

~ Table A4-4 of the Franklin Research Center TER-C5257-429 provides a fracture toughness exemption evaluation II.9 based on T

The Ginna pressurizer evaluation will be based on that cRKeria, which are a conservative adaptation of ASME Section NC-2311(a)(8).

In order to make this evaluation, the lowest service temper-ature (LST) must be defined.

This is the minimum temperature of the fluid retained by the component or the calculated minimum metal temperature expected during normal operation whenever the pressure within the component exceeds 20% of the preoperational system hydrostatic test pressure.

The hydrostatic test pressure was 3125 psia.

Thus, 20% of this pressure is 625 psia.

The Ginna Technical Specifications require, for purpose of low temperature overpressure protection, that RCS pressure must be lower than 435 psig whenever RCS temper-ature is lower than 330'F.

Thus, the lowest temperature at, 625 psia would be 330'F.

The LST is thus taken as 330'F.

The pressurizer head material is SA-216 WCC which, according to Table A4-2 has a T of 30'F.

Thus, LST-T

= 330 30

= 300'F, which is much greater %Kan the acceptance crit%La of 90'F.

Thus, it can be concluded that the pressurizer head material is exempt from impact testing.

It should be noted that, even if a refueling temperature of 130'ere used as the LST, the LST T

= 130 30

= 100'F, which is still above the acceptance crKEria of 90'F.

The pressurizer shell material is SA-302 Grade B material, the same material as the reactor vessel.

This material has been shown to have adequate fracture toughness (see SEP Topic V-6, Reactor Vessel Integrity).

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10 Evaluation 2 - Accumulators The accumulators are constructed of SA-516, Grade 70 material.

According to Table A4-2 of the Franklin TER, the T

of this material is O'.

The lowest service temperature oPKhe accumulator wo'uld be the minimum expected normal containment temperature, approximately 60'F during refueling operations.

(It should be noted that the accumulators are isolated from the RCS during

cooldown, when RCS pressure is about 700 psig.

When the accumulators are in service and connected to the RCS, containment temperature is generally maintained at about 120'F).

For purposes of this evaluation, the lower figure will be used.

From figure A4-1, the allowable (LST T T) for material up to 2 1/2 inches thick is 30'F.

The actual (LS T~T) is 60'F 0 F = 60 F.

Thus, based on exemption evaluation method II.8.(g) of Table A4-5, the fracture toughness of the accumulators is considered adequate.

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Evaluation 3

Com onent Coolin Water Pum s

The component cooling water pump casing is of carbon steel.

The exact material specifications, and case wall thickness, are not readily available.

The pot'ential for complete failure of both Component Cooling Water pumps due to brittle fracture is considered minimal.

One CCW pump provides all required services; the second pump is a

standby pump only.

Thus, it is not expected that. both pumps would fail.

Also, for purposes of Fire Protection (10CFR 50 Appendix R

commitments),

RG6E has purchased another CCW pump, which is a

skid-mounted unit, which could be made operable in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This pump is expected to be on site prior to mid-1983.

Thus, based on the number of backup CCW pumps available, it is not considered that impact testing is required of the CCW pump material.

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12 Evaluation 4 Service Water Pum s

The Service Water pumps are vertical shaft pumps, constructed of cast.iron (discharge head) and carbon steel (intake column pipe).

The exact material grade and wall thickness of the Service Water Pumps is not readily available.

However, it is not, considered that brittle fracture is a significant consideration for these pumps.

This type of pump has been used in similar commercial applications for many years.

It is not known that there have been any problems with brittle fracture of the pump material.

Since only one of the four Service Water Pumps is needed to perform safe shutdown cooling functions, it is very unlikely that all four pumps would experience simultaneous brittle fracture.

RG&E has also made modifications during the course of the Systematic Evaluation Program to minimize the safety requirement for operation of the Serve.ce Water Pumps.

Fire hose connections have been provided for the diesel generators and for the Standby Auxiliary Feedwater

System, to allow safe shutdown operation, even in the event of a loss of the SW pumps.

Thus, it, is not considered that impact testing is required for the SW pump material.

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13 Evaluation 5

Main Steam Pi in and Valves The main steam piping greater than 20 inches is ASTM A155-65, Grade

C55, Class

.1.

Main steam piping 20" and smaller is ASTM A106-65, Grade B.

The normal service temperature for the main steam line is 514'F to 547'F at power.

Although the T T of the main steam piping material is not available, the fa% that the lowest service temperature during the great majority of the operating time of this system is greater than 500'F would indicate that a fracture mechanics evaluation is not required.

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Evaluation 6

Feedwater Pi in and Valves The feedwater piping material is ASTM A106-64, Grade C.

The normal service temperature of the feedwater piping during normal operation is about 417'F.

Although the T

of these materials is not available, the fact that the lowesFEervice temperature during the great majority of the operating time of the system is greater than 400'F would indicate that a fracture mechanics evaluation is not required.

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