ML18093A966

Requests Emergency Approval of Weld Overlay Repair to 25 Containment Fan Coil Unit Svc Water Piping as Acceptable Repair,In Accordance w/10CFR50.55a(a)(3).Justification Encl

ML18093A966
Person / Time
Site:	Salem
Issue date:	07/13/1988
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLR-N88107, NUDOCS 8807260130
Download: ML18093A966 (3)

Text

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Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer JUL 1 3 1988 NLR-N88107 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen: ,:

10CFR50.55a(a) (3) - ALTERNATIVE REPAIR CONTAINMENT FAN COIL UNIT SERVICE WATER PIPING FACILITY OPERATING LICENSE NO. DPR-75 SALEM GENERATING STATION DOCKET NO. 50-311 Public Service Electric and Gas Company (PSE&G) hereby requests emergency approval of a weld overlay repair to No. 25 Containment Fan Coil Unit (CFCU) Service Water piping as an acceptable alternative repair in accordance with 10CFR50.55a(a) (3). Use of the alternative repair method would reduce personnel exposure time to both radiation and high temperatures, while assuring that quality and safety are not compromised. Justification for the alternative method is provided in Attachment 1. PSE&G requests your prompt review and approval of the alternate repair as Unit 2 is in a seven (7) day ACTION statement time limit.

Should you have any questions relative 'to this matter, please contact us immediately.

Sincerely, Attachment

Document Control Desk 2

• JUL 1 3 1988 C Mr. D. c. Fischer USNRC Licensing Project Manager Mr. R. w. Borchardt USNRC Senior Resident Inspector Mr. w. T. Russell, Administrator USNRC Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628

ATTACHMENT 1 The 10" vertical Service Water header supplying the #25 CFCU is leaking at the top vent connection. The leak is located on the l" vent pipe to header weld. The weld is to be repaired by overlaying the existing weld with weld metal in order to stop the leak. This is considered a temporary repair to be followed with a permanent repair during the upcoming refueling outage.

The temporary repair is being done at this time due to conditions at the location of the leak. The leak is located 20' above the 130' elevation close to the containment wall. The current temperature at this elevation is 120°F with a stay time based on OSHA requirements of 15 minutes. The weld overlay repair minimizes the manhours spent in containment under extreme temperature conditions. An ASME Code repair would require significantly more manhours to accomplish.

10CFR50.55a, Section (g) requires PSE&G to perform all repairs in accordance with Section XI of the ASME Code. However, 10CFR50.55a(a)(3) permits alternatives to the requirements of Section (g) when authorized by the Director of the Office of Nuclear Reactor Regulation. Paragraph (a) (3) requires that the applicant demonstrate that (i) the proposed change alternatives would provide an acceptable level of quality and safety or (ii}

the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.

The problem is a pin hole leak in the service water vent weld connection. The weld overlay repair will provide multiple layers of 6010 filler wire over the weld. The overlay will provide added strength and pressure retainment to ensure the integrity of the service water piping. The overlay technique has been used in Unit 2 service water stainless steel piping for approximately 20 months and has proven to be a reliable repair. The only difference is that this repair will be on carbon steel with different filler. Consequently, the carbon steel weld overlay will be more succeptible to corrosion; however, since a code repair will be made during the upcoming Unit 2 Fourth Refueling Outage (September 2, 1988) corrosion will not have a significant effect on the integrity of the weld.

The proposed weld overlay repair meets criteria (i) of 10CFR50.55a(a)(3) in that it provides an acceptable level of quality and safety. Furthermore, the weld overlay procedure reduces radiation exposure and minimizes the individual exposure to the high temperature environment. Thus, PSE&G believes that the alternative repair is justified in accordance with 10CFR50.55a(a) (3) and is the best repair to make under the present plant conditions.