ML18096A069
| ML18096A069 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/11/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18095A972 | List: |
| References | |
| NUDOCS 9106210027 | |
| Download: ML18096A069 (15) | |
Text
ENCLOSURE UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20666 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF PUBLIC SERVICE ELECTRIC AND GAS COMPANY'S REQUEST FOR RELIEF FROM ASME SECTION XI NOE AND HYDROSTATIC PRESSURE TESTING REQUIREMENTS PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION, UNIT 1 DOCKET NO. 50-272
1.0 INTRODUCTION
Pursuant to 10 CFR 50.55a(g) it is required that examinations and tests of nuclear power facility piping and components to be performed in accordance with the requirements of the applicable ASME Section XI Code edition and addenda.
If it is impractical to meet the requirements, the licensee of the facility is required to notify the Comnission and submit information in support of the determination that a requirement is impractical to perform.
By letters dated July 17, 1987, June 61 1988, and November 28, 1988, Public Service Electric and Gas Company (PSE&G) (licensee) submitted requests for relief from certain ASME Section XI requirements for the first ten-year
- interval. The licensee's First Ten-Year ISI program is based on ASME Section XI, 1974 Edition through Su11111er 1975 Addenda (1974 Code).
In addition, the licensee's Second Ten-Year ISI Program was approved by NRC letter dated April 17, 1990 and is based on the requirements of the 1983 Edition through SulYlller 1983 Addenda of Section XI of the ASME Code (1983 Code).
Furthermore, in some cases, the licensee's request for relief dated July 17, 1987 from the requirements of the governing 1974 Code to perform certain inspections.
are no longer required because the requirements either have been deleted or revised in the 1983 Code.
The licensee's requests for relief from certain ASME Section XI requirements for the first ten-year interval are evaluated herein pursuant to 10 CFR 50.55a(g)(6)(i) to determine if the necessary findings can be made to grant the request *.
2.0 EVALUATION A.
RELIEF REQUEST (RR) NUMBER 1 - RELIEF FROM VT EXAMitlATIONS OF CLASS 1 INTERIOR CLAD SURFACES OF VESSELS OTHER THAN REACTOR VESSELS (07/17/87 LTR., TAC NO. 66013)
COMPONENT ID~NTIFICATION System:
Component
Description:
Various Class 1 Pressurizer, Heat Exchanger, and Steam Generator Cladding ASME CODE SECTION XI FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edition through Su11111er 1975 Addenda Class 1, Category B-I-2, Item No. 82.9 (Pressurizer) and Category B-I-2, Item No. 83.8 (Heat Exchanger and Steam Generator) requires visual examination.
RELIEF REQUESTED Relief is requested from 100% visual examination of patch areas of cladding on the Pressurizer, Heat Exchangers and Steam Generators.
LICENSEE'S BASIS FOR RELIEF The ASME Code has recognized that cladding is not part of the pressure retaining boundary, nor is it relied upon for structural integrity. Also, visual examinations performed on cladding patches of the Salem Reactor Vessel Head and on the No. 12 Steam Generator have not identified any unacceptable conditions.
These examination requirements have been deleted from the later editions of the Code which have been approved by the NRC and incorporated into 10 CFR 50.55a.
Recognizing this deletion and intent of the ASME Section XI examinations to provide monitoring of component degradation over the plant's service interval, it is our position that the radiation exposure and costs associated with the cladding visual examinations are not commensurate with the increase in safety realized.* Therefore, PSE&G requests relief from perfonning these examinations~
- See Radiation Considerations Section below.
ALTERNATIVE EXAMINATION Ho additional examinations in these categories since later editions and addenda of ASME Section XI approved by the NRC and incorporated into 10 CFR 50.55a no longer require cladding examinations.
PLANT QUALITY & SAFETY Other examinations performed, together with system pressure tests (as applicable) provide an acceptable level of assurance of system integrity and plant safety.
RADIATION CONSIDERATIONS The Man-hour/exposure estimate for removal of one steam generator manway:
- 40 man-hours 4 man-rem exposure
- ~
B. STAFF EVALUATION AND CONCLUSIONS The Code requirements to visually examine, during each inspection interval, 100% of the patch areas for Pressurizer, Heat Exchanger and Steam Generator Cladding is impractical because of the radiation exposure of 4 man-rem for the removal of one steam generator manway.
In addition, the 1974 Edition through Sunmer 1975 Addenda, Item No. 82.9, Category B-I-2 and Item No. 83.8, Category B-I-2 requirements have been deleted from later editions of the Code. Furthermore, the later editions of the Code have been approved by NRC and incorporated into 10 CFR 50.55a.
Therefore, the staff has determined, pursuant to 10 CFR 50.55a{g){4){iv)
{the license for full power was issued on December 1, 1976) the licensee may use the later Code editions approved in 10 CFR 50.55a(b). Visual inspection of the cladding for the Pressurizer, Heat Exchanges and Steam Generators is no longer required by later editions of the Code, compliance with the specific ASME requirement would result in hardship due to the high radiation exposure and the visual inspection would not contribute to quality and safety operation of the plant.
COMPO~ENT IDENTIFICATION System:
Component
Description:
Reactor Coolant System Reactor Coolant Pump Casings ASME CODE SECTION FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edit.ion through Summer 1975 Addenda, Item No. 85.7, Category B-L-2 requires that one pump in e.ach of the group of pumps performing similar functions in the system shall be {visually) examined during each inspection interval. This examination may be performed on the same pump selected for the Category B-L-1 {volumetric) examination.* *---
RELIEF REQUESTED Relief is requested from performing visual examination of the pump internal pressure retaining surfaces.
LICENSEE'S BASIS FOR RELIEF Currently there are no plans for disassembly of any of the Reactor Coolant Pump Casings for maintenance.
NRC Safety Evaluation dated August 12, 1981 granted relief from the volumetric requirements of the Code Item 85.6 Category B-L-1 such that only surface examination on the external surface of the weld is required to be performed.
As such, PSE&G has been evaluating new techniques for volumetrically examining the pump casing welds. Such a technique exists us;ng the Miniature Linear Accelerator (MINAC) which was built under an EPRI sponsored program. This equipment has been made available to other ut;lities, and currently constitutes the only method available for the volumetric examination of reactor coolant pump casing welds. This
.. examination was performed at Ginna in the spring of 1981, at Point Beach Unit 1 in the fall of 1981, at Turkey Point Unit 3 early in 1982, and at H.B. Robinson Unit 2 later in 1982.
No problems with welds were found at any of the sites.
The successful performance of this volumetric examination using the MINAC demonstrates that the method is capable of satisfying ASME Section XI examination requirements. Based on the following information, however, PSE&G does not plan to use this technique.
The volumetric examination method is radiographic and is performed by placing the MINAC inside the pump casing and placing film on the outside of the pump.
To perform the examination, the pump must be completely disassembled.
This disassembly is far beyond that performed for normal maintenance.
In addition, insulation must be removed from the exterior of the pump casing.
The performance of the examination has shown that there is a relatively high radiation exposure associated with it. The total exposure associated with insulation removal, disassent>ly, examination, and reasseri>ly of the pump has averaged about 40 man-rem.
The pumps casing examinations are also not justified from a cost/benefit perspective. The pump disassembly, examination and reassend:>ly is estimated to cost $750,000.
Based on the preceding factors, PSE&G does not consider it justifiable to disassemble these pumps solely for the purpose of performing these examinations. Therefore, relief is required from performing visual examination of the pump internal pressure retaining surfaces.
ALTERNATE EXAMINATION Visual examination will be performed on the external pressure boundary surfaces of the pump casing weld in conjunction with the surface examinations performed.
erna ive exam na ions performed, together with system pressure tests (as applicable) provide an acceptable level of assurance of system integrity and plant safety.
RADIATION CONSIDERATIONS The total exposure associated with insulation removal, disassembly, examination, and reassembly of the pump has averaged about 40 man-rem.
STAFF EVALUATION AND CONCLUSIONS The requirement to visually inspect the internal pressure boundary surfaces of the Reactor Coolant Pumps (RCP) is impractical because of the relatively high radiation exposure from insulation removal, disassembly, examination,
- . and reasselllbly of the pumps.
In addition, to disassemble the pumps for the sole purpose to inspect the internal pressure boundary surfaces may be counterproductive due to the possibility of causing damage to the pump internals during disassenmly and/or reasseri>ly of the pumps.
The staff has determined that the alternative inspection proposed by the licensee will provide adequate assurance of the structural integrity of the Reactor Coolant Pump's casings with the exception that the licensee perform the required Code inspections when a RCP is completely disassembled for a scheduled maintenance activity. Pursuant to 10 CFR 50.55a(g)(6)(i), we conclude that relief from the ASME Boiler and Pressure Code requirement may be granted as requested by the licensee provided the licensee performs the required Code inspections when a RCP is completely disassenmled for a scheduled maintenance activity.
C.
RELIEF RE UEST NUMBER 3 - RE LIEST FROM CLASS 1 VALVE VT EXAMINATIONS L
TAC N
- 1 COMPONENT IDENTIFICATION System:
Various Component
Description:
Valve Bodies ASME CODE SECTION XI FIRST INTERVAL INSPECTION REQUIREMEMTS 1974 Edition through Su11111er 1975 Addenda, Item No. 86.7, Category B-M requires that visual examination of the internal pressure boundary surfaces, on valves exceeding 4 inches of the same constructional design, e.g., globe, or check valve, manufacturing method and manufacturer that performs similar functions in the system shall be examined during each inspection interval.
The examination may be performed at or near the end of the inspection interval.
RELIEF REQUESTED Relief is requested from performing a visual examination of the interior surface of valves 4 inch nominal pipe size and larger.
LICENSEE'S BASIS FOR RELIEF Disassembly of a valve which has been functioning within acceptable parameters for the sole purpose of examination is contrary to good maintenance practices since the likelihood of failure may be increased.
These components are subjected to an alternate form of performance and/or leakage monitoring such as inservice valve testing, or priinary coolant system leak detection. Valves in this category are constructed of cast austenitic stainless, which have been identified as unlikely to experience failure by cracking. Finally, considering the uncertain benefit involved, it is difficult to justify the additional radiation exposure which would be incurred as a result of the disassembly, examination, and reassembly of the valve.
e e PSE&G believes that performing a visual examination of the interior of one valve in a group of similar valves within the Class 1 pressure boundary at Salem Generating Station Unit 1 during the first Ten Year Inservice Inspection Interval does not provide an increase in safety above that provided by routine inservice valve testing and pressure testing required by ASME Section XI. Therefore, the costs and radiation exposure associated with this examination also are not justifiable.*
PSE&G has performed visual examinations on internal surfaces of all but (2) groups of valves identified at Salem.
One group is associated with the lRHl, 1RH2 valves and the other with 11 through 14SJ56 valves.
- See Radiation Considerations Section below.
ALTERNATE EXAMINATION In lieu of examination of each similar valve's interior on lines 4 inch nominal pipe size and large during the interval, PSE&G proposes to examine only those valves in this category which are disassembled during the re~ainder of the interval for maintenance purposes.
PLANT QUALITY & SAFETY The examinations as performed, together with the completed leakage, hydrostatic and other pressure tests (as required), provide an acceptable level of assurance of integrity of the valve body pressure retaining boundary.
RADIATION CONSIDERATIONS Man-hour/exposure estimate for disassembly of lRHl valve and reassembly:
- 145 man-hours 4 man-rem exposure STAFF EVALUATION AND CONCLUSIONS The Code requirement to visually examine the internal pressure boundary surfaces, on valves exceeding 4 inches nominal pipe size is impractical because of the radiation exposure associated with the disassembly, examination, and reassembly of the valves.
In addition, the disassembly and reassembly of the valves could be counterproductive due to the possibility of causing damage to the inter"als of the valve. The staff has determined that the alternative inspections will provide adequate assurance of the structural integrity of the valve's internal pressure boundary surfaces. Pursuant to 10 CFR 50.55a(g)(6)(i), we conclude that relief from the ASME Boiler and Pressure Code requirement may be granted as requested by the licensee.
D.
COMPONENT IDENTIFICATION System:
Component
Description:
Various Integrally-Welded External Support Attachments ASME CODE SECTION XI FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edition through Su1m1er 1975 addenda, Item No. 84.9, Category B-K-1 requires that volumetric examination of integrally-welded external support attachments. This includes the welds to the pressure retaining boundary and the base metal beneath the weld zone and along the support attachment member for a distance of two support thicknesses.
RELIEF REQUESTED Relief from volumetric examination of integrally-welded external support attachments.
LICENSEE'S BASIS FOR RELIEF Due to geometric configuration, full coverage has not been obtained using standard UT techniques. Coverage typically equals 90% of the total percentage required by the 1974 Edition of the Code.
In the 1983 Edition of Section XI, examination requirements for B-K-1 welds have been changed from volumetric to surface. This edition has been approved by the NRC and incorporated into 10 CFR 50.SSa.
ALTERNATE EXAMINATION Surface examination as allowed by ASME Section XI, 1983 Edition 1983 Sunner Addenda, Item 810.10, Category B-K-9.
PLAMT QUALITY AND SAFETY The required system operational, leakage, hydrostatic and other pressure tests {as applicable), provide an acceptable level of assurance of the pressure retaining boundary integrity where the ;ntegrally-welded external support attaches.
RADIATION CONSIDERATIONS None STAFF EVALUATION AND CONCLUSIONS The Code requirements for volumetric examination of integrally-welded external support attachments is impractical because of the geometric configurations and full coverage has not been obtained using standard UT techniques.
Furthermore, ASME Code, 1983 Edition of Section XI 1983 Surrmer Addenda, examination requirements for B-K-1 have been changed from volumetric to surface. The staff has determined that the alternative inspection (surface) proposed by the licensee will provide adequate assurance of the structural integrity of the external support welds to the pressure retaining boundary and the base metal beneath the weld zone and along the support attachment member for a distance of two support thicknesses.
In addition, the piping system would have to be redesigned in order to perform the required Code inspections thus, imposing a burden on the licensee. Pursuant to 10 CFR 50.55a(g)(6)(i), we conclude that relief from the ASME Boiler and Pressure Code requirement may be granted as requested by the licensee.
E.
RELIEF REQUEST NUMBER 5 - RELIEF FROM VOLUMETRIC EXAMINATION OF CLASS 1 BRANCH CONNECTION WELDS EXCEEDING SIX {6) INCHES IN DIAMETER (07/17/87 LTR.,
COMPONENT IDENTIFICATION System:
Component
Description:
Various Class 1 Branch* connection welds exceeding six inches in diameter.
ASME CODE SECTION XI FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edition through Surrmer 1975 Addenda, Item No. 4.6, Category B-J requires volumetric examination of pipe branch connections. This shall include the weld metal, the base metal for one pipe wall thickness beyond the edge of the weld on the pipe run and at least two (2) i~ehes of base metal along the branch run.
RELIEF REQUESTED Relief is requested from volumetric examination of pipe branch connections.
LICENSEE'S BASIS FOR RELIEF The geometric configuration makes the complete coverage of the volume specified in the 1974 Edition of the Code prohibitively difficult. Typical.
coverage is 90i of the required volume.
The volume specified in the 1983 Edition of the Code has been reduced to the lower 1/3 and supplemented with a surface examination. This edition of the Code has been approved by the NRC and incorporated into 10 CFR 50.55a.
F. ALTERNATE EXAMINATION Volumetric and surface examinations of branch connection welds exceeding six (6) inches as required by ASME Section XI 1983 Edition, 1983 Summer Addenda.
Item 89.30 Category 8-J.
PLANT QUALITY & SAFETY The re~uired system operational, leakage, hydrostatic and other pressure tests {as applicable), provide an acceptable level of assurance of structural and system integrity for the pipe branch connections.
RADIATION CONSIDERATIONS None STAFF EVALUATION AND CONCLUSIONS The Code requirement for Volumetric examinations of pipe branch connections is impractical to perform because the geometric configuration precludes the complete coverage of the volume specified in the 1974 Edition of the Code.
The staff has determined that the alternative inspections proposed by the licensee will provide adequate assurance of the structural integrity of the Class 1 branch connection welds exceeding six inches in diameter.
In addition, the piping system would have to be redesigned in order to perform the required Code inspections thus imposing a burden on the licensee. Pursuant to 10 CFR 50.55a(g)(6)(i), we conclude that relief from the ASME Boiler and Pressure Code requirement may be granted as requested by the licensee.
COMPONENT IDENTIFICATION System:
Component
Description:
Auxiliary Feed Water Auxiliary Feedwater System Buried Piping ASME CODE SECTION XI FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edition through Su11111er 1975 Addenda, Article HJD - 2600{b) requires in the case of buried components (e.g., underground piping), valves shall be provided to permit isolation of the buried portions of piping for the purpose of conducting a system pressure test in lieu of the visual examination. A loss of system pressure during the test shall constitute evidence of component leakage.
\\,
- . RELIEF REQUESTED Relief is requested from conducting a system pressure test by using valves to isolate buried portions of piping.
LICENSEE'S BASIS FOR RELIEF
- 1.
The buried piping was initially tested by a pressure drop test by using boundary valves as prescribed in the Code.
The pressure drop test failed because of excessive leakage through the test boundary.
The leakage was suspected to be past the 12AF23 and 14AF23 valves.
In order to substantiate this suspected leakage path, the alternate test method described below was used.
Relief is being requested as the Code does not provide for an alternate method of testing inaccessible pipe.
- 2.
This matter was considered unresolved (Item 272/87-32-01) in the routine Resident Safety Inspection performed between November 3, 1987 to November 30, 1987 (NRC Combined Inspection Report 50-272/87-32 and 50-311/87-33). The inspector found the alternative test method to be a reasonable alternative to the pressure drop test since the boundary valves could not be made leak tight. The inspector also requested that a relief request be submitted to acquire a formal approval for the use of the alternate test method.
LICENSEE'S ALTERNATIVE EXAMINATION PSE&G conducted a pressure test of buried piping between valves 12AF23, 12AF21 and 12AF86 for Steam Generator #12 and 14AF23, 14AF21 and 14AF86 for Steam Generator #14 using the following alternate test method.
The header pressure was maintained with the hydrostatic test pump.
While the pressure was maintained, and for the duration of the test, both the volume of water used by the pump and that collected downstream of the leaking test boundary valves 12AF23 and 14AF23 were measured.
The two measured volumes were then compared to provide assurance that the inaccessible portion of the pipe had no identified leakage. The buried pipe in each case was approximately 190 feet i~ length.
PLANT QUALITY & SAFETY The required system operational, leakage, hydrostatic and other pressure tests {as applicable), provide an acceptable level of assurance of structural and system integrity for the buried piping in the auxiliary f eedwater system.
RADIATION CONSIDERATIONS None
G. STAFF EVALUATION AND CONCLUSIONS The Code requirement to hydrostatically test underground piping by using valves to isolate the system is impractical because the valves that are used for isolation were not designed to be leak tight. During hydro testing the valves leaked, causing the system to fail the required Code testing. The staff has determined that the alternative test proposed by the licensee will provide adequate assurance of the structural integrity of the buried piping for the Auxiliary Feedwater System.
In addition, the piping system would have to be redesigned in order to perform the required Code inspections thus, imposing a burden on the licensee.
Pursuant to 10 CFR 50.55a(g)(6)(i), we conclude that relief from the ASME Boiler and Pressure Code requirement may be granted as requested by the licensee.
COMPONENT IDENTIFICATION System:
Various Component
Description:
Ferritic Vessels with the Tested Systems ASME CODE XI FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edition through Su11111er 1975 Addenda, Article IWB 5222(b) states the test pressure may be reduced in accordanc~ with the following table when system hydrostatic testing is required to be conducted at temperatures above 100° F in order to meet the fracture toughness criteria applicable to ferritic materials of which the system components are constructed:
TEST TEMPERATURE 100° F 200° F 300° F 400° F 500° F RELIEF REQUESTED TEST PRESSURE 1.10 Po 1.08 Po 1.06 Po 1.04 Po 1.02 Po Relief is requested to test austenitic stainless steel portions of the Nuclear Class 1 systems that cannot be isolated from the portions that contain ferritic materials to the requirements of Article me 5222(b).
LICENSEE'S BASIS FOR REQUEST In order to protect the structural integrity of the ferritic vessels within these systems, non-isolable portions made of austenitic stainless steel should not be tested at a higher pressure and temperature than required by
1. -
H. IWB 5222(b). These requirements have been incorporated in the 1983 Edition of Section XI, which has been approved by the NRC and incorporated into 10 CFR 50.55a.
ALTERNATE EXAMINATION Austenitic stainless steel portions of the Nuclear Class 1 systems that cannot be isolated from the portions that contain ferritic materials, such as the Reactor Vessel, shall be subject to the same reduced pressure and temperatures requirements as specified in IWB 5222(b) above.
PLANT QUALITY & SAFETY The required system operational, leakage, hydrostatic and other pressure tests {as applicable), provide an acceptable assurance of structural and system integrity for the austenitic stainless steel portions of the Nuclear Class 1 systems that cannot be isolated from the portions that contain ferritic materials.
RADIATION CONSIDERATIONS None STAFF EVALUATION AND CONCLUSIONS The Code requirement to hydrostatically test austenitic stainless steel portions of Class 1 systems that can not be isolated from the portions that contain ferritic materials is a hardship for the licensee to perform.
The piping system would have to be completely redesigned in order to perform the Code required testing. Furthermore, the 1974
- edition of the Code allows reduced test pressure for components of ferritic material and later editions of the Code permit the testing of the Reactor Coolant System at reduced pressures as the temperature is increased. Pursuant to 10 CFR 50.55a{g)(6){i), we conclude that the licensee's alternative to the applicable ASHE Boiler and Pressure Code requirement may be granted as requested.
RELIEF REaUEST NO. 2 - RELIEF REaUEST FROM 10 YEAR HYDROSTATIC TEST REQOIREME Ts FOR 374 tNcR NOCLEA CLASS 2 PIPING (07/17/87 LTR. TAC NO. 66013)
COMPONENT IDENTIFICATION System:
Component
Description:
Residual Heat Removal and Safety Injectior.
3/4 inch Class 2 Piping
- 13 ASME CODE SECTION XI FIRST INTERVAL INSPECTION REQUIREMENTS 1974 Edition through Sunner 1975 Addenda, Article IWB~5200(a)[Sic]
(licensee's 07/17/87 LTR should have reference Article IWC-5220(a) for Class 2 piping) requires that the system hydrostatic test pressure shall be at least 1.25 times the system design pressure (Pd) and conducted at a test temperature not less than 100° F except as may be required to meet the test temperature requirements of IWA-5320.
RELIEF REQUESTED Relief is requested from the Code requirement that system hydrostatic test pressure shall be at least 1.25 times the system design pressure.
LICENSEE'S BASIS FOR RELIEF The following Nuclear Class 2 portions of the Residual Heat (RH) Retnaval and Safety Injection {SJ) Systems cannot be tested at the required hydrostatic pressure. Pressurization at hydrostatic pressure would require cutting open the pressure boundary, and re-welding when the test is completed, which uses resources of man-hours (48 man-hours estimated per valve} and material and radiation exposure (0.1 man-rem exposure estimated per valve). Expending these resources is not justified when an acceptable level of safety can be achieved by perfonning the surface examinations and inservice pressur~ tests proposed in the alternate examinations below:
- 1.
Approximately 4 feet of Stainless Steel RHR system piping between valves 1RH45 and 1RH33. These lines (shown in the sketch on Page 5 of Attachment 2 of PSE&G's letter dated July 17, 1987) cannot be pressurized to the required hydrostatic pressure due to:
- 2.
(a) Lines from the Demineralized Water System are welded to one side of the test boundary.
{b) A check valve with a welded bonnet fonns the other side of the test boundary.
{c) There is no test connection within the test boundary.
PSE&G requests that this portion of RHR piping be pressurized to the nominal operating pressure of the Demineralized Water System (80-90 PSI) in place of 565 PSI required by the Code.
Approximately 4 feet of Stainless Steel RHR system piping between valves 1RH46 and 1RH24. These lines (shown in the sketch on Page 6 of Attachment 2 of PSE&G's letter dated July 17, 1987) cannot be pressurized to the required hydrostatic pressure due to:
(a)
(b)
(c) lines from the Demineralized Water System are welded to one side of the test boundary.
A check valve w1th a welded bonnet forms the other side of the test boundary.
There is no test connection within the test boundary.
- 3.
Approximately 14 feet of Stainless Steel SJ system piping between valves 11SJ96 and 11SJ98. These lines (shown in the sketch on Page 7 of Attachment 2 of PSE&G's letter dated July 17, 1987) cannot be pressurized to the required hydrostatic pressure due to:
(a) Lines from the Demineralized Water System are welded to one side of the test boundary.
(b) A check valve with a welded bonnet forms the other side of the test boundary.
{c) There is no test connection within the test boundary.
PSE&G requests that this portion of RHR piping be pressurized to the nominal operating pressure of the Demineralized Water System (80-90 PSI) in place of 565 PSI required by Code.
- 4.
Approximately 14 feet of Stainless Steel SJ system piping between valves 12SJ96 and 12SJ98. These lines (shown in the sketch on page 7 of Attachment 2 of PSE&G's letter dated July 17, 1987) cannot be pressurized to the required hydrostatic pressure due to:
(a) Lines from the Demineralized Water System are welded to one side of the test boundary.
(b) A check valve with a welded bonnet forms the other side of the test boundary.
(c) There is no test connection within the test boundary.
PSE&G requests that this portion of RHR piping be pressurized to the nominal*operating pressure of the Demineralized Water System
{80-90 PSI) in place of 565 PSI required by Code.
ALTERNATIVE EXAMINATION PSE&G proposes to conduct surface examination of the welds and a test at nominal operating pressure for the following lines:
.. Design Pressure Alternate Test Pressure 3/4 inch line between valves 450 PSI 80 to 90 PSI 1RH45 and 1RH33 3/4 inch line between valves 600 PSI 80 to 90 PSI 1RH46 and 1RH24 3/4 inch line between valves 450 PSI 80 to 90 PSI 11SJ96 and 11SJ98 3/4 inch line between valves 450 PSI 80 to 90 PSI 12SJ96 and 12SJ98 PLANT gUALITY & SAFETY The reguired system operational, leakage, hydrostatic and other pressure tests {as applicable), provide an acceptable level of assurance of Residual Heat Removal and Safety Injection System integrity.
R~.DIATION CONSIDERATIONS Radiation exposure is estimated 0.1 man-rem per valve.
STAFF EVALUATION AND CONCLUSIONS The code requirement to hydrostatically test portions of the Residual Heat Removal (RHR) and Safety Injection (SJ) Systems is impractical because of the system design. Pressurization at hydrostatic pressure would require cutting open the pressure boundary, and rewelding when the test was completed.
Furthermore, there are no test connections within the test boundary and modifications would have to be made.
The staff has detennined that the alternative tests proposed by the li"censee will provide adequate assurance of the structural integrity of the portion of the 3/4 inch RHR and SJ piping in which relief was requested. Pursuant to 10 CFR 50.55a(g)(6)(i), we conclude that relief from the ASME Boiler and Pressure Code requirement may be granted as requested by the licensee.
3.0 CONCLUSION
The staff has determined, with respect to the relief requested, that the requirements of the Code are impractical to perform and relief is granted on the conditions stated above pursuant to 10 CFR 50.55a(g)(6)(i). This relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Principal Contributor: T. Mclellan Date: March 11, 1991
~1 I