ML17263A214

Forwards Request for Relief 23 from ASME Code Section XI Requirements for Hydrostatic Testing for Two Replacement Activities Re Svc Water Sys & turbine-driven Auxiliary Feedwater Sys,As Part of Third 10-yr ISI Program

ML17263A214
Person / Time
Site:	Ginna
Issue date:	04/05/1993
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9304130389
Download: ML17263A214 (9)

Text

A,CCELE ED DOCUMENT DIS UTION SYSTEM REGU ORY INFORMATION DISTRIBUT SYSTEM (RIDS) r eL

~'CCESSION NBR:9304130389 DOC.DATE: 93/04/05 NOTARIZED:

NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G

05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.

Rochester Gas

& Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSONIA.R.

Project Directorate I-3

SUBJECT:

Forwards Request for Relief 23 from ASME Code Section XI requirements for hydrostatic testing for two replacement activities re svc water sys

& turbine-driven auxiliary feedwater sys,as part of third 10-yr ISI program.

DISTRIBUTION CODE:

A047D COPIES RECEIVED:LTR 4

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SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code D

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).

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NOTE TO ALL"RIDS" RECIPIENTS:

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TOTAL NUMBER OF COPIES REQUIRED:

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~y'ug IIiIIII' SiqigiI uZZZirst i urzikll izzrsuz ROCHESTER GAS AND ELECTRIC CORPORATION ste s iN ~ 01 I4e o

89 EAST AVENUE, ROCHESTER N.Y. 14649-0001 ROBERT C MECREDY Vice President Clnna Nuctear Production April 5, 1993 TELEPHONE AREACODE 71B 546-2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn:Allen R. Johnson PWR Project Directorate I-3 Washington, D.C.

20555

Subject:

Ginna Nuclear Power Plant Inservice Program Quality Assurance Manual, Appendix B

ASME Section XI Required Examinations R.E. Ginna Nuclear Power Plant Docket No. 50-244 Ref.(a):

Letter from A. R. Johnson (NRC), to R.

C. Mecredy (RGE)

Subject:

Quality Assurance Manual Revision, Appendix B, dated January 12, 1993 (b): Letter from A. R. Johnson (NRC), to R.C. Mecredy (RGE),

Subject:

Third 10-year In Service Inspected Program Safety Evaluation Report dated August 6, 1990

Dear Mr. Johnson:

The purpose of this letter is to request relief from the provisions of the ASME Code,Section XI requirements for hydrostatic testing for two replacement activities at Ginna Station.

Because these activities are in progress during our present refueling shutdown, action on the attached Relief Request No.

23 is requested by April 15r 1993 This request is for a "one-time" use for both activities and is meant to supersede Relief Request No. 14.1 submitted in our letter of January 12, 1993 (Reference a).

Ver truly yours, REJK272 Robert C.

Me redy xc:

Mr. Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C.

20555 I30j gj U. S. Nuclear Regulatory Commission

.,Region I 475 Allendale Road

-King of Prussia, PA.

19406 U.S.

NRC Ginna Senior Resident Inspector

)))5 9304130389

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RELIEF REQUEST 823 SCOPE The first activity to be performed is the replacement of seven valves in the Class 3 Service Water System.

The second activity is the replacement of a

check valve in the Class 3 Turbine Driven Auxiliary Feedwater System.

Service Water System Seven valves within the service water system are currently being replaced:

valve numbers

4611, 4613,

4626, 4669,

4738, 4739, and 4760.

The replacement of the valves is being performed to the 1986 edition of ASME B&PV Code,Section III.

An evaluation to establish the work area test boundaries for the valve replacements was performed as discussed below (refer to drawings 33013-1250 sheets 1-3):

V-462 6:

V-4613:

The replacement valve is a gate valve.

Both the upstream and downstream isolations would require the use of butterfly type isolation valves, thus making an elevated (hydrostatic) pressure test impractical.

(see Relief Request f14 approved in Reference b)

The replacement valve is a butterfly type design.

It cannot be isolated on the discharge side (open ended pipe).

Due to the butterfly design the inlet installation welds cannot be tested.

(see Relief Request g14)

V 4611' 4669' 4738' 4739' 4760 The replacement valves are gate valves and serve as loop cross-connects.

In order to isolate the selected areas for replacement, some freeze seals would be required to maintain some systems supplied by the Service Water System operational.

The use of freeze seals as isolation boundaries is not feasible.

In order to establish test boundaries, complete service water loops would be required to be isolated, thus creating an operational hardship resulting in a reduction in nuclear safety due to rendering certain safety related equipment unavailable.

Turbine Driven Auxiliary Feedwater System The work activity being performed is the replacement of check valve 4023 in the recirculation test line.

The Code used for this work is the 1989 edition of ANSI B31.1.

Once the valve is installed, the pipe section cannot be isolated to perform the elevated (hydrostatic) pressure test.

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4 I V

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Referring to drawing 33013-1237, boundaries for the work area would be the pump suction valves (V-4024

& 4098),

the pump discharge valve (V-3996) and downstream flow control valve V-4291.

Both V-3996 and V-4291 are not designed for isolation applications, and would require the installation of test blocks.

Installation of these blocks was found to be impractical.

Part of the work area would incorporate piping having a design, pressure of 150 psi, with a required test pressure of 2619 psi, therefore, an unacceptable condition would exist.

Installation of a test block at the discharge of the pump was reviewed and found to be impractical because disassembly of the pump would be required.

RELIEF REQUESTED I.

Component for Which Relief is Requested:

A.

Service Water System, Rules for Hydrostatic Testing of

Repairs, Replacements or Modifications to pressure retaining Class 3 components.

1.

Installation of isolation valves a ~

b.

c ~

d.

e.f.

go V-4611 V-4613 V-4626 V-4669 V-4738 V-4739 V-4760 B.

Turbine Driven Auxiliary Feedwater

System, Rules for Hydrostatic Testing of

Repairs, Replacements or Modifications to pressure retaining Class 3 components.

1.

Installation of valve V-4023 II.

ASME Requirement fr'om which relief is requested:

Hydrostatic testing of Repairs, Replacements or Modifications on Class 2

or 3

systems is required by IWA-4400 which specifies that hydrostatic testing shall be performed to IWC-5222(a) and IWD-5223(a).,The system hydrostatic test pressure shall be at least 1.10 times the system pressure P>> for systems with Design Temperature of 200 F or less, and at least 1.25 times the system pressure P~~ for systems with Design Temperature above 200'F.

The system pressure Pgy shall be the lowest pressure setting among the number for safety or relief valves provided for overpressure protection within the

C I J a s

~,~

~

1 4 I

\\4 p,

r Ci boundary of the system to be tested.

For systems (or portions of systems) not provided with safety or relief valves, the system design pressure P~ shall be substituted for Pgy.

III. Proposed Alternate Method ALTERNATIVE PRESSURE TEST REQUIREMENT FOR WELDED REPAIRS OR INSTALLATION OF REPLACEMENT ITEMS BY WELDING For Class 3

Using ANSI B31.1 and ASME B

& PV Code Case N-416 as a basis for relief, Rochester Gas and Electric considers the following alternative requirements to be acceptable:

1.

Additional NDE shall be performed in accordance with the methods

'and acceptance criteria, of, Subsection ND of the 1986 Edition of Section III.

I 2.

Prior to, or immediately upon return to service, a

VT-2 visual examination shall be performed in conjunction with an inservice or functional leakage

test, using he 1986 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure and temperature.

3.

Use of this Relief Request will be documented on the NIS-2 Form for the Replacement.