ML17263A518
| ML17263A518 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/07/1994 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| TAC-M88416, TAC-M88417, NUDOCS 9401190008 | |
| Download: ML17263A518 (9) | |
Text
TION SYSTEM REGULATORY INFORMATION DXSTRXBUTXON SYSTEM (RIDS)
ACCESSION NBR:9401190008 DOC.DATE: 94/01/07 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATXON MECREDY,R.C.
Rochester Gas 6 Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R.
Project Directorate I-3
SUBJECT:
Clarifies use of code sections referred to by relief requests 25 6 26,provided via 931209 ltrs.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code D
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244 RECIPIENT ID CODE/NAME PD1-3 LA JOHNSON,A INTERNAL: AEOD/DSP/ROAB NRR/EMCB OC/LF CB E L'1 EXTERNAL: EGGG BROWN,B NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID 'CODE/NAME PD1-3 PD NRR/DE/EMEB NUDOCS-ABSTRACT OGC/HDS1 RES/DSIR/EIB EGGG RANSOME,C NSIC COPIES LTTR ENCL 1
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D D
D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACTTHE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 16 ENCL 13 D
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ROCHESTER GAS AND ELECTRIC CORPORATION o
89 EAST AVENUE, ROBERT C MECREDY Vice President Cinne Hudeer Production January 7,
1994 ROCHESTER N.Y. 14649.0001 TELEPHONE
~ COOB Tie 546-2700 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Allen R. Johnson Project Directorate I-3 Washington, D.C.
20555
Subject:
Relief Request No.
25 and 26 Clarification R.E.
Ginna Nuclear Power Plant Docket No. 50-244 TAC g's 88416 and 88417 Ref.(a):
Letter from R." C. Mecredy (RG&E) to A. R. Johnson (NRC),
Subject:
Relief Request 25, dated December 9,
1993 (b):
Letter from R.
C. Mecredy (RG&E) to A. R. Johnson (NRC),
Subject:
Relief Request 26, dated December 9,
1993
Dear Mr. Johnson:
The purpose of this letter is to clarify the use of the code sections referred to by the referenced relief requests.
This clarification is intended to replace the relief request description in their entirety.
The clarifications are noted as shaded.
We trust that these changes provide for a
more clearly defined request.
Ver ruly yours,
'f yAQ3 GJWi320 Attachment Robert C. Mecredy xc: Mr. Allen R. Johnson (Mail Stop 14D1)
Project Directorate I-3 Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
, 9401190008', 940107.
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RELIEF REQUEST NO.
25 I.
Components for which Relief is Requested.
The Class 3
portions of the Service Water System (SWS),
including SWS supply to Auxiliary Feedwater, when hydrostatic pressure tests are required due to repair or replacement activities.
II. ASME Requirements from which Relief is Requested:
Relief is requested from the requirements specified in IWA-4400 and IWD-5223(a) of the 1986 Edition, no addenda.
- a. Hydrostatic testing of repairs or replacements in Class 3
systems is required by IWA-4400.
The pressure testing rules of IWA-4400(a):
After repairs by welding on the pressure retaining boundary, a system hydrostatic test shall be performed in accordance with IWA-5000.
b.
IWA-5000 specifies that hydrostatic testing shall be performed to IWD-5223(a).
XÃ0-5223(a) states in part the following:
"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 p0.'+(g:.,::pggForg,'::,-)'Fg~gp6r" s':,. ~ts'c",'%h"'"s e
.w.:;~"".',ae':wvee::"desi'~We.4~gksea~'a 44si s@mre<e~.:ashier"';me asser Ci'::"':""'."".::.P'j~4 III. Basis Industry studies have shown that the hydrostatic pressure test specified in IWD-5223(a) is not an integrity test of the weld, but is in fact a leakage test run at a high pressure.
Using surface examination methods on different passes of the weld or volumetric examinations methods on a completed weld provide more comprehensive results in the determination of the integrity of the weld.
In addition, a system inservice or functional test and VT-2 examination will be performed on the completed welds.
The SWS is a moderate energy system whijh'::-'.".p'o'e's!::;:::iiot::;"hive,.:'..;,'safety<
i.s only 90 jsiq hyelow the code required hydrostatic test pressure o'!,,"F1~1'0-:,:;:x@1,'>.
The Code required hydrostatic test would not offer any significant increase in the ability to
RELIEF REQUEST NO.
25 determine the leak-tightness of the repairs over testing performed at system nominal operating pressure.
The structural integrity will be ensured by the controls instituted in the repair or replacement procedures and verified with NDE.
Since the system is in constant operation, its integrity is continually monitored.
In addition, the redundancy in SWS gives added assurance of meeting heat load requirements.
IV. Proposed Alternate Method In lieu of performing the hydrostatic pressure test required by IWA-4400 for welded repairs or installation of replacement items in the Service Water System (Class 3) by welding, the following examinations and tests shall be performed.
1.
NDE shall be performed in accordance with the methods and acceptance criteria of Subsection ND of the 1986 Edition of Section III.
In addition, when the surface examination method is used in accordance with ND-5222 for a butt weld, an additional surface examination shall be performed on the root (pass) layer.
- 2. Prior to or immediately upon return to service, a
VT 2 visual examination shall be performed in conjunction with a system inservice or functional test, using the 1986 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure and temperature.
3.
Use of this Case shall be documented on an NIS-2 Form.
0 1
RELIEF REQUEST NO.
26 I.
Components for Which Relief is Requested:
The Class 3 portions of the Component Cooling Water System (CCWS)
=when hydrostatic pressure tests are required due to repair or replacement activities.
II. ASME Requirements from Which Relief is Requested:
Relief is requested from the requirements specified in IWA-4400 and IWD-5223(a) of the 1986 Edition, no addenda.
Hydrostatic testing of repairs or replacements in Class 3
systems is required by IWA-4400.
The pressure testing rules of IWA-4400(a):
After repairs by welding on the pressure retaining boundary, a
system hydrostatic test shall be performed in accordance with
'WA-5000.
IWA-5000 specifies that hydrostatic testing shall be performed to IWD-5223(a).
IWD-5223(a) states in part the following:
The system hydrostatic pressure shall be at least 1.10 times the system pressure P> for systems with Design Temperature. of 200'F or less,
<<!,'.f orgf!f ajar!,',,For":" eject em's$not'<ipioiii daddy'filth saba'i e III. BASIS Industry studies have shown that the hydrostatic pressure test specified in IWD-5223(a) is not an integrity test of the weld, but is in fact a leakage test run at a high pressure.
Using surface examination methods on different passes of the weld or volumetric examinations methods on a completed weld provide more comprehensive results in the determination of the integrity of the weld.
In addition, a system inservice or functional test and VT-2 examination will be performed on the completed welds.
The CCWa is a modeaate energy~astern sh'lo!r~%happfri'o thawer; eesega: tej pz'atesj,'o'ii>V>.-.".'Th.';::syst'eij op only 98 psig below 'the Code required hydrostatic test pressure of:
<<C::::::10:.':::',::::X:;!P~.
The Code required hydrostatic test would not offer any significant increase in the ability to determine the leak-tightness of the repairs over testing performed at system nominal operating pressure.
The structural integrity will be ensured by
RELIEF REQUEST NO.
26 the controls instituted in the repair or replacement procedures and verified with NDE.
Since the system is in constant operation, its integrity is continually monitored.
In addition, the'redundancy in CCWS gives added assurance of meeting heat load requirements.
IV. Proposed Alternate Method:
In lieu of performing the hydrostatic pressure test required by IWA-4400 for welded repairs or installation of replacement items in the Component Cooling Water System (Class-3) by welding, the following requirements shall be performed.
1.
NDE shall be performed in accordance with the methods and acceptance criteria of Subsection ND of the 1986 Edition of Section III. In addition, when the surface examination method is used in accordance with ND-5222 for a butt
- weld, an additional surface examination shall be performed on the root (pass) layer.
- 2. Prior to or immediately upon return to service, a VT-2 visual examination shall be performed in conjunction with a system inservice or functional test, using the 1986 Edition of Section XI, in accordance with IWA-5000, at nominal operating pressure and temperature.
3.
Use of this Relief Request shall be documented on an NIS-2 Form.
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