ML17263A801

Requests Extension of Encl Relief Request 25 Through 1995 Refueling Outage,Based on NRC Concurrence W/Util Methodology Related to Addl Work Required to Be Performed to Replace Two Swp Discharge Check Valves 4603 & 4604 by 940929 Telcon

ML17263A801
Person / Time
Site:	Ginna
Issue date:	09/30/1994
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9410110120
Download: ML17263A801 (5)

Text

PR.LMA.I EY'

'ACCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9410110120 DOC.DATE: 94/09/30 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 JOHNSON,A.R.

Project Directorate I-3

SUBJECT:

Requests extension of encl Relief Request 25 through 1995 refueling outage, based on NRC concurrence w/util methodology related to addi work required to be performed to replace two SWP discharge check valves 4603

& 4604 by 940929 telcon.

DISTRIBUTION CODE:

A047D COPIES RECEIVED:LTR ENCL U SIZE:

TITLE: OR Submittal: Inservice/Testing/Relief f om ASME Code GL 89-04 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/SPD/RAB NRR/DE/EMCB NUDOCS-ABSTRACT OGC/HDS3 EXTERNAL EG&G BROWNi B NOAC COPIES LTTR ENCL 1

0 2

2 1

1 1

1 1

1 1

0 1

1 1

1 RECIPIENT ID CODE/NAME PD1-3 PD FILE CgggEB~.

NRR DE/EMEB OC/LFDCB RES/DS IR/EIB EG&G RANSOME i C NRC PDR COPIES LTTR ENCL 1

1 1

1 1

1 1

0 1

1 1

1 1

1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACTTIIE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIXIIVATEYOUR iAMEFRO~I DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON"I'LED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 16 ENCL 13

I 4ND ROCHESTER GASANDElECTRIC CORPORATION ~ 89FASTAtrrENUE, ROCHESTER, N. Y IrI6d9-000I ARFA CODE716 5'-2700 ROBERT C. MECREDY Vice President Nvdeor Operations September 30, 1994 U.S. Nuclear Regulatory Commission Document Control Desk Attn:

Allen R. Johnson Project Directorate I-3 Washington, D.C.

20555

Subject:

Extension of Relief Request No.

25 R.E.

Ginna Nuclear Power Plant Docket No. 50-244 Ref. (a):

Letter from W. R. Butler (NRC), to R.

C. Mecredy (RG&E),

Subject:

R. E. Ginna Nuc1ear Power Plant Third 10-Year Inservice Inspection Program Relief Requests 25 and 26, dated April 11, 1994

Dear Mr. Johnson:

In the referenced

letter, RG&E was granted relief from the provisions of ASME XI requirements for hydrostatic testing for welded repair and replacement activities associated with the service water system during the 1994 refueling outage (see Attached Relief Request f25).

Additional work is now required to be performed to replace two service water pump discharge check valves 4603 and 4604. It is expected that 4603 replacement will commence about October 3, 1994.

To support these activities RG&E requests a documented extension of Relief Request No.

25 through the 1995 refueling outage.

This request is made in accordance with the provisions of 10CFR50.55a (a)(3)(i).

Based on NRC concurrence with RG&E's methodology as discussed by a teleconference between Al Johnson of the NRC and RG&E personnel on September 29,

1994, RG&E intends to proceed with this replacement activity prior to formal receipt. of NRC documentation.

Very truly yours, Robert C. Mecr dy r t p

~

I 94ioii01,20 cst40930 PDR ADOCK 05000244 PDR og t

~

GJW4348 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

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).

IWD-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,

[or]..."For systems....not provided with safety or relief valves, the system design pressure P~ shall be substituted for Pgy."

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 which does not have safety or relief valves installed for purposes of overpressure protection.

The system operates at a nominal 75 psig, which is only 90 psig below the Code required hydrostatic test pressure of 1.10 x

P~.

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.