ML17334A893

Requests Relief from Provisions of ASME Boiler & Pressure Vessel Code Section Xi,Subsection IWC-5000 for Auxiliary Spray to RCS & Pressurizer.One Oversize Drawing Encl. Aperture Card Available in Pdr.Fee Paid

ML17334A893
Person / Time
Site:	Cook
Issue date:	07/15/1985
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:0070U, AEP:NRC:70U, NUDOCS 8507230262
Download: ML17334A893 (10)

Text

REGULATOR'f>>lFORMATION DISTRIBUTION S EM (RIDS)

ACCESSION NBR;8507230262 DOC ~ DATE: 85/07/15 NOTARIZED: NO DOCKET FACIL>>:50"315 Donald C. Cook>> Nuclear Power Plantr Unit ii Indiana L 05000315 AUTH INANE AUTHOR AFFILIATION ALEXICH~M.P. Indiana 8 Michigan Electric Co ~

RECIP, NAME>> RECIPIENT'F f IL'IATION DENTONiH ~ Re Office, of Nuclear Reactor Regulationi Director

SUBJECT:

Requests r elief from provisions of ASME Boiler 8, Section XI<Subsection Il<C. 5000 for auxiliary Pressure'essel Code spray to RCS L pressurizer+One, oversize drawing encl.

Aperture card available, in PDR Fee paidQ ~

DISTRIBUTION CODE! A047D COPIES RECEI VED t LTR 'NCL SIZE:

TITLE: OR Submittal: Inservice" Inspection/Testing NOTES: 05000315 OL:10/25/74 RECIPIENT'D COPIES RECIPIENT COPIES CODE/NAME>> LTTR ENCL' ID CODE/NAME LTTR ENCL' NRR ORB1 BC 01 7 INTERNAL; ACRS 10 10 ADM/LFMB 0 16'LD/HDS3 1 0 NRR/DE/MEB 15. 1 NRR/D. - EB 14 1- NRR/DL/TAPMG 1 1 FI 04 1 1 RGN3 1 EXTERNAL: 24X NRC PDR'2' 1 1 LPDR NSIC 03 05 1

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~/c I c.>>-K @ /ho TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 26

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INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 July 15, 1985 AEP:NRC:0070U Donald C. Cook Nuclear Plant Unit No. 1 Docket No. 50-315 License No. DPR-58 INSERVICE INSPECTION PRESSURE TEST-CODE RELIEF Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

This submittal and its attached flow diagram are made pursuant to 10 CFR 50.55a(g)(6)(i). Code relief is requested from the provisions of ASME Boiler and Pressure Vessel Code Section XI, subsection IWC-5000. This request is in addition to those requested in our letter of May 17, 1985 (AEP:NRC:0070R). We request code relief and alternate tests as proposed for the following piping section:

1. Auxiliary Spra to Reactor Coolant System and Pressurizer, CVCS Reactor Letdown and Char in S stem, Drawin 1-5129 Pi in Boundaries:

Valves QRV-51 CS-326 Valves QRV-61 CS-322 Valves QRV-62 ISI Code Class 2 Requirement:

I For a 'design 'pressure of 2735 psig, Article IWC-5000 of the ASME Code,Section XI, requires that the piping be tested at a pressure of 3418 psig, and a temperature not less than 100 0 F.

Code Relief Re uest:

It is proposed to test the above section of piping at a pressure of 2800 psig.

Basis for Code Relief:

In order to perform the pressure test in this ISI Class 2 Section of piping, valve QRV-51 has to be used as an isolation

'alve. This 1,500 lb. class, air-operated, control valve is BpD50R7230262 8507~5 8 < 0500031/

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Mr. Harold R. Dent AEP:NRC:0070U designed to withstand a test of 3418 psig in the open position. However, it cannot pressure be used as an isolation valve because it was designed for a differential pressure of 1200 psig.

The valve cannot be kept closed during pressure testing at 3418 psig without extensive, temporary rigging. The modification would require: (1) removal of the air operator and installation of a "strong back" to keep the valve closed during the testing, (2) removal of the strong back after the testing, and (3) re-installation of the air operator on the valve and restoring the valve to operable condition before returning to service. The valve is located inside the re-generative heat exchanger room which is a very high radiation area and plant personnel would be subjected to radiation exposure of 5 to 7 man rems.

As an alternative, the possibility of using a freeze seal plug downstream of QRV-51 was considered. This would involve extensive working time in the Pressurizer Relief Tank area close to the pressurizer spray valves, which is a high radiation area.

This alternative was rejected because plant personnel would be subject to an even higher radiation exposure of 8.5 man rems during the formation, monitoring, and removal of the freeze seal plug.

We believe that this is a reasonable code relief request since the proposed test pressure is in fact higher than the normal operating pressure of 2235 psig in the approximately 30 feet long section of piping for which code relief is requested.

We are requesting the relief because the above piping system cannot be tested to ASME Code requirements without modifying the System and/or exposing personnel to unnecessary radiation hazards.'n order to avoid unnecessary delays and to restore the unit to power on a timely basis, we are requesting a response from the NRC as soon as possible. If you have any questions or concerns about the material contained herein, please do not hesitate to call us.

'f Although this code relief request has been'eviewed by appropriate technical and managerial personnel at both AEPSC and the Plant, this document has not yet been reviewed in concert by either our Plant or Corporate Safety Committees.

committees shortly, and if It is scheduled to be reviewed by both those reviews result in any changes, we will notify you accordingly.

A check in the amount, of $ 150.00 is attached with this letter for the NRC processing of the request.

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Mr. Harold R. Den AEP:NRC:0070U This document has been prepared following Corporate procedures which incorporate a reasonable set. of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, M. P. lexich Vice Preside t ~4~5~

cm Attachments cc: John E. Dolan (w/o attachments)

W. G. Smith, Jr. - Bridgman (w/attachments)

R. C. Callen (w/o attachments)

G. Bruchmann (w/o attachments)

G. Charnoff (w/o attachments)

NRC Resident Inspector Bridgman (w/attachments)

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