ML18141A474

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Safety Evaluation Re Util 820921 Requests for Relief from Inservice Insp Requirements
ML18141A474
Person / Time
Site: Surry Dominion icon.png
Issue date: 01/24/1984
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML18141A472 List:
References
NUDOCS 8402090431
Download: ML18141A474 (43)
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Text

l __

  • e UNITED STATES e

NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

/ '* '1 SAFETY EVALUATION OF REQUESTS.FOR RELIEF FROM INSERVICE INSPECTION REQUIREMENTS - VIR~INIA ELECTRIC POWER COMPANY SURRY POWER STATION UNIT 1 DOCKET NO. 50-280 INTRODUCTION Technical.Specification 4.2-1 for the Surry Power Station Unit 1 states that inservice examination of ASME Code Class 1, 2, and 3 components

  • shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), ~xcept where.specific written relief has been.

granted by the-Commission.

Certain requirements of later editions and ~ddenda of Section XI are impractical to perform on older plants because of *the plants' design, component geometry, and materials construction.

Thus, 10 CFR 50.55a(g)(G)(i) qUthorizes the Commission to grant relief from those requirements upon making the necessary findings.

By letter dated September 21, 1982, Virginia Electric Power Company submitted its inservice inspection program revisions, or additional information related to request for relief from certain Code requirements determined to be impractical to perfor~ on the Surry Station Unit l during the inspection interval.

The program is based on the 1980 Edition through Winter of 1980 Addenda of Section XI of the ASME Code, and covers the 120-month inservice inspection period from December l, 1982.

8402090431 840124 PDR ADOCK 05000280 G

e e EVALUATION Requests for relief from the requirements of Section XI which have been determined to be impractical to perform have been reviewed by the Staff's contractor, Battelle, Pacific Northwest Laboratory.

The contractor's evaluations of the licensee's requests for relief and his recommenda-tions are presentei in the attached Technical Evaluation Report (TER).

The Staff has reviewed the TER and agrees with the evaluations*and recommendations.

A summary of the determinations made by the staff is presented in the following tables:

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(/71 C ;a

a

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-a n,

n -I 0 z IWB-2600 IWB-2500 System or Item No.

Exam. Cat.

Component 82.10 B-B Pressurizer 89.30 B-J Piping 812.40 B-M-2 Valves

-.--- --- ------~~~

TABLE 1 CLASS l*COMPOHENTS Licensee Proposed Relief Area to be Required Alternative Request Examined Method Exam Status Shel l-to-*head Volumetric Visual during Granted weld hydro for leakage Reactor cool-Volumetric Volumetric Granted ant branch exam to nozzle con-extent prac-nection ti cal Examination Visual Visual during Granted of internal maintenance surfaces

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a n

rr, z

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-0 rr, n -l 0 z IWB-2600 Item No.

Cl..10 C2.21 IWB-2500 Exam. Cat.

C-A C-B System or Component Reactor coolant filter Residual heat exchanger TABLE 2 CLASS 2 COMPONENTS Area to be Examined Circumferential shell welds Nozzle-to-shell weld Required Method Volumetric Surface &

Volumetric Licensee Proposed Alternative Exam Surface Visual during hydrostatic test Relief Request Status Granted Granted provided licensee also does surface exam on reinforcement pad fillet weld I

e TABLE 3 CLASS 3 COMPONENTS No Relief Requests 3

e SURRY INSERVICE INSPECTION

e e

TABLE 4 PRESSURE TEST IWA-5000, IWB-5000 Licensee IWC-5000 and Proposed Relief System or.

IW0-5000 Test Alternative Request Component Pressure Requirement Test Pressure Status Class 1 & 2 S~stem H~drostatic Test Test@ 2335 psig when Granted piping between IWB-5222 - test pressur~

reactor is shut down two check should be 1.10 x pressure valves

@ 100% power.

IWC-5222 -

test pressure shall be 1.10 X p SV Class 1 piping S~stem Leakage Test Visual test during Granted between two IBW-5221 full fl ow test check valves Reactor cool-S~stem H~drostatic Test Leakage test at nom-Granted ant seal water IWB-5222 inal operating pres-system sure

  • Piping & valves S~stem H~drostatic Test Test pressure to be Granted associated with IWB-5222 1.25 x pressurizer pressurizer

- safety valve set point Class 1 piping S~stem Leaking and H~dro-Test piping to lower Granted between normally static tests pressure Class II closed motor IWB-5221 and IWB-5222 requirements operated valves Piping associ-IWA-5213(d) - 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Test according to manu-Granted ated with steam pressure test hold time facturers specifica-generators tions Class 2 open S~stem H~drostatic Test Test to requirements Granted ended fi 11 pip-IWC-5222 of IWC-5222(c),(b) ing attached to RWST Class 3 piping System Hydrostatic Test Test to normal aper-Granted associated with

. IW0-5223 ating pressure reci rcul ati on spray heat exchangers 4

SURRY INSERVICE INSPECTION

System or Component.

Class 3 open-ended and non-isolable piping.

Circulation and Service Water system.

Steam genera-tor primary-to-secondary leak visual test Fuel oil system e

e TABLE 4 (Cont.)

PRESSURE TEST IWA-5000, IWB-5000 IWC-5000 and IWD-5000 Test Pressure Requirement System Hydrostatic Test IWD-5223 IWA-5240 - visual test for 1 eakage System Hydrostatic Test IWD-5523

)

Licensee Proposed Alternative Test Pressure Test to requirements of open-ended pipe systems Test for leakage to plant tech. specs.

System functional test Relief Request Status Granted Granted Granted 5

SURRY INSERVICE INSPECTION i

System or Component

.e TABLE 5 ULTRASONIC EXAMINATION TECHNIQUE Requirement Licensee Proposed Alternative Method No Relief Requests Relief Request Status 6

SURRY INSERVICE INSPECTION

System or Component TABLE 6 GENERAL RELIEF REQUESTS ALL CLASSES/COMPONENTS Regufrement Licensee Proposed Alternative Method No Relief Requests e

Relief Request Status 7

SURRY INSERVICE INSPECTION

e e

Based on the. review summarized, the staff concludes that relief granted from.

the examination requirements and alternate methods imposed through this document give reasonable assurance of the piping and component pressure boundary and support structure integrity; that granting relief where the Code requirements are impractical is authorized by law and will not endanger life or property, or the common defense and security, and is otherwise in the public interest considering the burden that could result if they were imposed on the facility.

Date:

January 24, 1984 8

SURRY INSERVICE INSPECTION

'\\,.

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TECHNICAL EVALUATION REPORT SURRY POWER*STATION UNIT 1 INSERVICE INSPECTION PROGRAM Submitted to:

U.S. Nuclear Regulatory Commission Fin. B2157 Battelle, Pacific Northwest Laboratory Richland, Washington February 28, 1983

TECHNI,CAL EVALUATION REPORT SURRY POWER STATION UNIT l INSERVICE INSPECTION PROGRAM The revision to 10 CFR 50. 95a, published in February 1976, required that Inservice Inspection (ISI) Programs be updated to meet the requirements ( to the extent practical) of the Edition and Addenda of Section XI of the American Society of Mechanical-Engineers Boiler and Pressure Vessel Code (hereinafter referred to asSection XI or Code) incorporated in the Regulation by reference in paragraph (b).

This updating of the programs was required to be done every 40 months to reflect the new requirements of the later editions of.Section XI.

As specified in the February 1976 revision, for plants with Oper~ting Licenses issued prior to March 1, 1976, the regulations became effective after September 1, 1976*, at the start of the next regular 40-month inspection period.

The initial inservice examina-tions conducted during the first 40-month period were to comply with the requirements in editions of Section XI and addenda in effect no more than six months prior to the date of start of.facility commercial operation.

The Regulation recognized that the requirements of _the later editions and addenda of the Section XI might not be practical to implement at facilities because of limitations of design, geometry, and materials-of construction of components and systems.- It therefore permitted determinations of impractical examination or testing re-quirements to be evaluated. Relief from these requirements could be granted provided heal th and safety of the public were not endangered, giving due consideration to the burden placed on the licensee if the requirements were imposed. The* 1 icensee, Virginia Electric and Power Company, of Surry Power Station Unit 1, has recently submitted relief requests dealing with inserv:ice examinations of components or with system pressure tests that were formally submitted to the Nuclear Regulatory Commission (NRC)

  • Inservice tests of pumps and valves ( IST programs) are being evaluated separately.

The revision to 10 CFR 50. 55a, effective November 1, 1979, modified tbe time interval for updating ISI programs and incorporated by reference a later edition and addenda of Section XI. The updating intervals were extended from 40 months to 120 months to be consistent with intervals as defined in Section XI.

For plants with Operating Licenses issued prior to March 1, 1976, the provisions of the November 1, 1979, revision are effective after September 1, 1976, at the start of the next one-third of the 120-month interval.

During the one-third of an interval and throughout the 1

e e

remainder of the interval, inservice examinations shall comply with the latest edition and addenda of Section XI, incorporated by refer-ence in the Regulation, on the date 12 months prior to the start of that one-third of an interval.

For Surry Power Station Unit 1, the ISI program and relief requests submitted in conjunction with it cover the second ten year interval, from December 22, 1982 to December 22, 1991.

This program was based upon the 1980 Edition of Section XI of the ASME Boile*r and Pressure Vessel Code with Addenda through the Winter of 1980.

The November 1979 revision of the Regulation also provides that ISI programs may meet the requirements of subsequent Code editions and addenda, incorporated by reference in paragraph (b) and subject to NRC approval. Portions of such editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.

Finally,Section XI of the Code provides for certain components and systems to be exempted from its requirements. In some instances, these exemptions are not acceptable to NRC or are only acceptable with restrictions.

2

e I.

CLASS 1 COMPONENTS A.

Reactor Vessel No Requests for Relief.

B.

  • Pressurizer
1.

Relief Request SR-5, Pressurizer Shell to Top Head Weld Code Requirement Volumetric examination of the pressurizer head to shell weld (Category B-B).

Code Relief Request Relief is requested from the Code volumetric examination requirements.

Proposed Alternative Examination A visual examination for evidence of leakage will be performed during system*pressuie tests.

Licensee Basis for Relief The shell to top head circumferential weld is not accessible for volumetric or surface examination due.

to interference from the insulation aupport ring.

Evaluation There were no drawings or sketches submitted with this relief request.

Without additional information from drawings, etc. to support the licensee basis for relief, a complete evaluation cannot be made.

Conclusions and Recommendations Without additional information, relief from Code requirements should not be granted.

The licensee should submit dimensional drawings to support the basis for relief.

3

e C *. Piping

1.

Relief Request SR-3, Reactor Coolant Branch Nozzle Connection Welds D.

Pumps Code Requirement A volumetric and surface examination of branch pipe connection welds on piping having a nominal pipe size of four inches or greater.

Code Relief Request Relief is requested from the Code volumetric examination of the weld root from the weld crown.

Paragraph III-4430 Proposed Alternative Examination The volumetric examinations on-these welds will be performed. to the extent practical.

Licensee Basis for Relief Due to the configuration of the weld crown, transducer contact cannot be maintained on the weld.

The *slope of the weld crown precludes examination of the weld root when scanning from the weld crown.

Evaluation A sketch of the subject pipe is shown in Figure

1.

The weld can be examined from the nozzle forging side only.

Reliable examinations from the reactor coolant pipe and the weld crown side are not possible due to component geometry.

A complete surface exam-inatioi and single-sided volumetric examination are judged to be adequate to ensure the structural inte-grity of the component.

Conclusions and Recommendations Based on the above evaluation,. Code. requirements are impractical.

It is recommended that relief be granted.

No Relief Requests 4

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2

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  • a *
    • _-_*---0-,

eeSTINGHOUSB ELECTRIC COR.ATION BRANCH NOZZLE CONNECTIOH WELD CEHTERLINE-HOZZLE 5

0 Figure 1 REACTOR COOLANT PIPE

-- -.* *~-***-- ***-**-

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E.

Valves

1.

Relief Request SR-1, Visual Examination of Valve In-ternals, Category B-M-2, Item*B12.40 Code Requirement A visual examination of the internal pressure boundary surfaces of one valve in each group of valves of the same constructural design and manufacturing method that perform similar functions in the system.

These examinations are required to be completed each inspection interval (Code Category B-M-2, Item B12. 40).

Code Relief Request Relief is requested *from Code requirements.

Proposed Alternative Examination An examination of the internal pressure boundary surfaces will be performed, to the extent practical, each time a valve is disass-embled for maintenance purposes.

Licensee Basis for Relief The requirement to disassemble p~imary system valves for the sole purpose of per forming a visual.

examination of the interna~ pressure boundary sur-faces has only a very small potential of increasing plant safety margins and a very disproportionate im-pact on expenditures of plant manpower and radiation_

exposure.

Performing these visual examinations, under such adverse conditions as high dose rates and poor as-cast surface c'ondi tion, realistically, provides li_ttle ad-ditional information as to the valve casing integrity.

The performance of both carbon and stainless cast valve bodies has. been excellent in PWR applications.

Based on this experience and both industry and regula-tory acceptance of these alloys, continued excellent service performance is.anticipated.

A more practical approach that would essentially provide an equivalent sampling program and signifi-cantly reduced radiation exposure to plant personnel 6

e e

is to inspect the internal pressure boundary of only those valves that require disassembly for maintenance purposes.

This would* still provide a reasonable sampling of primary system valves and give adequate assurance that the integrity of these components is being maintained.

Evaluation Disassembly of these valves for the sole purpose of a visual examination, ~n absence of other required maintenance, represents an unnecessary exposure to radiation and contamiriation.

Contamination levels in the valves are particu-larly high for valves located at the bottom of the system.

Class 1 valves are subject to system hydro.static examination and containment isolation valves are leak-tested periodically. The licensee has agreed to visually examin~ any valves that are disassembled for routine maintenance.

Conclusions and Recommendations Based on the evaluation and licensee discussion above, Code requirements ar~ impractical.

However,

.valve wall thickness measurements could.be performed on any valves that are not examined for maintenance.

Therefore, it is recommended that relief be granted from the visual examination requirements of B-M-2 provided that the licensee conducts a valve wall thickness examination on any valves that are not visually examined for routine maintenance.

I I

  • CLASS 2 COMPONENTS A.

Vessels

1.

Relief Request SR-2, Residual Heat Removal Heat Ex-changer Nozzle-to-Vessel Welds Code Requirement A volumetric and s~rface examination of the noz-zle inside radius section (Category C-B).

7

2.

e Code Relief Request r

Relief is requested from Code requr~ements.

Proposed Alternative Examination A visual examination for evidence of leakage will be performed in accordance with Subsection IWC-5000 requirements.

Licensee Basis for Relief The fabrication of these welds pr eel udes any type of surface or volumetric examination.

Additional assurance.of the continued integrity of these welds is afforded by the fact that the reinforcement pads strengthen the welds and reduce stresses on the in-ternal welds.

Evaluation The nozzle-to-vessel weld of the redisual heat exchanger is de.signed with a reinforcement pad as shown in Figure 2.

The reinforcement pad completely covers the weld subject to inspection; therefore, volumetric and surface examination of the required weld is physically not possible. However, the fillet weld on the reinforcement pad could ~e examined using surface methods.

Conclusions and Recommendations Based on the above evaluation, Code requirements for the subject welds are impractical.

However, the licensee could perform surface examination on the fillet. weld of the reinforcement pad.

It is recom-mended that relief be granted from performing Code required examinations, proyided the licensee conducts a surface examination of the reinforcement pad fillet weld.

Relief Request SR-4, Reactor Coolant Filter Circum-ferential Welds Code Requirement A volumetric examination shell welds (Category C-A).

8 of circumferential

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2 C a

  • _J)

ESTINOHOUSE ELECTRIC CO RA'fH~~

Figure 2 RESIDUAL HEAT REMOVAi HEAT EXCHANGER

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CHANNEL HEAD FLANGE NOmE TO VESSEL WELD 9

1* THICK.REINFORCEMENT PAD

-~

NtlmE 10" SCH 4QS tTYP ICAL OF TWO)

.875" THICK SHELL AND HEAD

Code Relief Request

  • Request relief from Code required volumetric examination.

Proposed Alternative Examination A surface examination will be performed in lieu of the volumetric examination.

Licensee Basis for Relief The stainless steel material and th"ickness (0.1~8") preclude any type of meaningful examination by ultrasonic examination.

Evaluation The manual ultrasonic volumetric examination of thin-walled stainless steel components does not pro-duce reliable results.

Conclusions and.Recommendations Based on the above evaluation, Code requirements for the subject weld are impractical.

We recommend that ~elief be granted.

B.

Piping

~o Relief Requests

c.

Pumps No Relief Requests D.

Valves ll No Relief Requests III. CLASS 3 COMPONENTS No Relief Requests 10

.........-------------.,....,,.--------------,---------------~---~---

e e

IV.

PRESSURE TESTING

1.

Relief Requests RR-1, RR-5 and RR-11, Class 1 and Class 2 P'ip'ing between the fo-1-lowing* double chec'k valve combinations Class 1 Piping Safety Injection Sy*tem 11448-FM-89B 11448-FM-88C l-SI-79 and l-SI-235, l-SI-241 l-SI-82 and l-SI-236, l-SI-242 l-SI-85 and l-SI-237, l-SI-243 l-SI-88 and l-SI-238 l-SI-91 and l-SI-239 l-SI-94 and l-SI-240.

i~cH-430 a~d l-CH-312 HCV-1311 to l-CH-313 Class 2 Piping Safety Injection System Component MOV-1890C MOV-1890A MOV-1890B

)

1-SI-174 and

.MOV-1869A MOV-1869B Connected Piping 10"-SI-152-1502 to 6"-SI-153-1502 to 6"-SI-145-1502 to 6"-SI-144-1502 6"-SI-49-1502 6"-SI-48-1502 to 6"-SI-143-1502 to 6"-SI-48-1502 to 6"-SI-50-1502 3"-SI-72-1503 to 2"-SI-72-1503/

2"-SI-79-1502 2"-SI-77-1503/

2"-SI-80-1502 3"-SI-147-1503 to *2 11-SI-73-1503 to 2"-SI-81-1502 11 Component 1-SI-243

. 1-SI-241 l-SI-242 1-SI-229 2"-SI-81-1502 6"-SI-49-1502 2"-SI-79-1502 1-SI-240 l-SI-257 l-SI-239 l-SI-255 l-SI-238 l-SI-253

l-SI-150 MOV-1867D MOV-1867C MOV-1842 MOV1865A l-SI-105 MOV-1865B l-SI-126 MOV-1865C l-SI-143 e

3"-SI-70-1503 to 2"-SI-70-1503 2"-SI-75-1502 2"-SI-76-1503/

2"-SI-85-1502 3"-SI-146-1503 to 2"-SI-71-1503/

2 "-SI-74-1502.

12"-SI-45-1502 3/4"-SI-33-1502 12"-SI-46"."'1502 3/4"-SI-34-1502.

12"-SI-47-1502 3/4"--SI-35-1502 Chemical and Volume Control System Component l-CH-311 HCV-1310A Code Requirement Connected Piping 3/4 11"".'CH-240-1502 3"-CH-1-1502 l-SI-237 l-SI-250 l-SI-236 l-SI-248 l-SI-235 l-SI-245 l-SI-107 l-SI-107 l-SI-128 l-SI-128 l-SI-145 l-SI-145 Component l-CH-312 l-CH-312 Class 1:

Class I System Hydrostat_ic Test, IWB-5222 (a)

The system hydrostatic test pressure shall be 1.10 times the system nominal operating pressure P0 that corresponds with 100% rated power.

Class 2:

Class II System Hydrostatic Test, IWC-5222 (a)

The system hydrostatic test pressure shall be at least 1.10 times the system pressure Psv for systems with Design Temperature of 2QQOp (93oC), or less, and at least 1.25 times the system pressure P~v for systems with Design Temperature above 20*0 F (93°C).

The system pressur-e Psv shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within 1;he bounda*ry of the sys*tem to be tested.

12

e e

Code Relief Request Relief is requested from the Code required test pressures.

Proposed Alternative Examination Class 1:

The alternative test proposed is to pressurize the primary system to 2335 psig while the reactor is in a shutdown condition.

The reactor will be borated to equal to or greater than cold shutdown Boron Con-centration.

  • The pressurized primary will act as a boundary for the test forcing closed the first check valve in the pressure boundary.

A charging test pump will provide test pressure and a VT-2 examination will be conducted on the area.

Class 2:

As an alternative these systems will be tested in conjunction with the Class I Hydrostatic test at a pressure of 2335 psig.

A VT-2 examination will be performed on the components and piping listed above~

Licensee Basis for*Relief Class 1:

The double. check valve combination prevents pressurization of the area in between the check valves when conducting IWB-5222 on the primary system.

Class 2:

Check valve boundaries between Class II and Class I systems make it impractical to establish hydrostatic test boundaries so that the primary system is not included. Design pressure for this piping is 2800 psig (Pd), therefore normal test pressure would be 3080 psig (T 200°F).

This pressure would overpressurize the primary since i~ cannot be isolated.

The valves listed below will be tested as fol-lows:

Component MOV-1865A l-SI-105 Connected Piping 12"-SI-45-1502 3/4"-SI-33-1502 13 Component l-SI-107 l-SI-107

e MOV-1865B l-SI-126 MOV-1865C l-SI-143 12"-SI-46-1502 3/4"-SI-34-1502 12"-SI-47-1502 3/4"-SI-35-1502 l-SI-128 l-SI-128 l-SI-145 l-SI-145 The check valve boundary prevents isolation of the adjoining Class-1 system from the Class 2 system mentioned. The lack of *overpressure protection within the boundary requires a valve Pd (Design Pressure) equal to 2485 psig times 1.1 (T 2QQOF) for a test pressure of 2733.5 psig. The nominal operating pres-sure Po for the adjoining Class 1 system is 660 psig.

which at l00°F requires a test pressure of 726 psig.

  • As is evident since isolation is not practical, the normal Class 2 test pressure will be far in excess of the test pressure for the Class 1 system.
  • Evaluation For the Class 1 portion of the subject piping, system design causes pressure to be retained by the first valve in a series of two check valves.

There-fore, pressurization of the piping between *valves is not possibl:e. The alternate test pressure p_roposed.by the licensee is judged to be adequate to detect struc:-

tural degradation.

For the Class 2 piping,

  • isolation of Class 1 and
  • Class 2 systems at the boundary cannot be accom-plished.

To prevent overpressurization of the Class 1 portions of these sy~tems, these portions of the piping systems are exam~ned volumetrically under Category B-J. It is judged that these examinations and alternate testing will be acceptable in providing assuring of the systems' integrity for safe operation of the facility during this inspection period.

Conclusions and Recommendations Based on the above evaluation, Code requirements are impractical.

It is recommended that relief be granted.

14

2.

e Relief Request RR-2, System Leakage Test between the following Class 2 Double Check Valves:

l-SI-79 and l-SI-235, l-SI-241 l-SI-82 and l-SI-236, l-SI-242 l-SI-85 and l-SI-237, l-SI-243 l-SI-88 and l-SI-238 l-SI-91 and l-SI-239 l-SI-94 and l-SI-240 Code Requirement IWB-5221 System Leakage Test (a)

The system leakage test shall be conducted at a test pressure not less than the nominal operating pressure associated with 100% rated reactor power.

( b)

The system test pressure and temperature shall be attained at a rate in accordance with the heat-up limitations specified for the system.

Code Relief Request Relief*is requested from Code pressure require-ments.

Proposed Alternative Examination As an alternative test the system wfll be flushed to prove flow capability to the primary system. Du{ing this test a VT-2 examination will be conducted.:

This test will be conducted each refueling out-age.

Licensee Basis for Relief The pressure during normal operation (100%

power) would be the static head left when the system was isolated or at most a few pounds over atmosphere.

This test would be inconsequential and would* not indicate existing leakage problems effectively.

Evaluation Due to the double check valve design, pressure is held by the first check valve in series.

Therefore, pressurization in piping between check valves is not possible.

The alternative testing proposed by the 15

3.

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licensee will provide a better method for testing system leak tightness.

Conclusions and Recommendations Based on the above evaluation, Code requirements are impractical.

It is recommended that relief be granted.

Request Request RR-7, Piping Leading to the Seal of Reactor Coolant Pumps Code Requirement

~WB-5222 System Hydrostatic Test (a)

The system hydrostatic test shall be con-,

ducted at a test pressure of 1.10 times the system nominal operating pressure P0 that corresponds with 100% rated reactor power except when the test is conducted at temperatures above lOOOF (JSOC) to meet the requirement~ of IWB-5230.

(b)

The system hydrostatic test may be con-ducted at the reduced test pressure of Table IWB-5220-1 to meet the requirements of IWB-5230.

(c)

The pressure measuring instrument used for

.. _ measuring system hydrostatic *or pneumatj.c test pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Relief is requested from Code test pressure re-quirements.

Proposed Alternative Examination The normal system leakage tests and VT~2 exam-ination of the piping from the flanges to the pumps will be adequate, and an alternative test is. not necessary.

Licensee Basis for Relief The number one sea~ return is the pressure bound-ary for the reactor coolant pumps.

The nature of the design of this system precludes the use of an external pressure source for this test; as excessive pressure could damage the seal.

16

4.

Evaluation The design of the reactor coolant pump seal supply system does not allow isolation of the reactor pumps' seals.

Testing the subject piping at Code required pressure could damage the pump seals.

The alternative test pressure (i.e., normal operating pressure) is judged adequate to ensure structural integrity.

Conclusions and Recommendations Based on the above evaluation, Code requirements are impractical.

It is recommended that relief be granted.

Relief Request RR-4, Pipin*g and Valves Associated with the Pressurizer as listed below:

l-CH-323 to the flange prior to 1-RC-P-lA l-CH-33-3 to the tlange prior to 1:-RC-P-lB l-CH-349 to.the flange prior to 1-RC-P-lC Code Requirement IWB-5222 System Hydrostatic Test (a)

The system hydrostatic test shall be con-ducted at a test press~re of 1.10 times the system

-- nominal operating pressure P0 that cortesponds with 100%. rated reactor power except when the test is conducted at temperatures above l00°F (380C) to meet the requirements of IWB-5230.

(b)

The system hydrostatic test may be con-ducted at the reduced test pressure of Table IWB-5220-1 to meet the requirements of IWB-5230.

(c)

The pressure measuring instrument used for measuring system hydrostatic or pneumatic test pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Relief is requested to test subject piping and components to 1. 25 times pressurizer safety set point.

Proposed Alternative Examination Test piping and components to 1.25 times pres-surizer safety set point.*

17

5.

e Licensee Basis for Relief It is requested that the piping and valves de-scribed be examined during the Class II hydrostatic test which will be conducted on the attached piping.

This hydrostatic test will be conducted at 1. 25 times the pressurizer safety set point ( 2485 psig)

  • The hold time for this hydro is the same as a Class I hydro. It is felt that a Class II hydrostatic test will be the more restrictive test.

Evaluation The licensee has provided no justification for the subject relief request.

An evaluation of the requested relief cannot be completed until the licen-see provides justification for requesting relief.

Conclusions and Recommendations The licensee has not provided any technical jus-tification for requesting relief; therefore, it* -is recommended that relief be denied until justification is presented for review.

Relief Requests RR~6, RR-7, and RR-12, Testing Between Two Normally Closed Motor Operated Valves Residual Heat Removal Component MOV-1701 Code Requirement Connected Piping 14"-RH-18-602 1,;

IWB-5221 System Leakage Test Component MOV-1700 (a)

The system leakage test shall be conducted at a tes*t pressure not less than the nominal operating pressure associated with 100% rated reactor power.

(b)

The system test pressure and temperature shall be attained a,t a rate in accordance with the heat-up limitations specified for the system.

IWB-5222 System Hydrostatic Test (a)

The system hydrostatic test shall be con-ducted at a test pressure of 1.10 times the system 18

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nominal operating pressure P0 except when the test is conducted at temperatures above 1000F (380C) to meet the requirements of IWB-5230.

(b)

The system hydrostatic test may be con-ducted at the reduced test pressure of Table IWB-5220-1 to meet the requirements of IWB-5230.

(c)*

The pressure measuring instrument used for measuring system hydrostatic or pneumatic test pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Relief is requested from meeting the pressure requirements in testing the subject piping.

Proposed Alternative Examination Alternative to System Hydrostatic Test:

MOV-1701 and the piping between MOV-1701 and MOV-1700 will be tested in accordance with the Class II hydrostatic test to be administered to 14"-RH-18-602 on the suction side of the r_esidual heat removal pumps.

This piping is protected from overpressure by RV-1721 which is set at 600 psig. Class I I test pressure will be 750 psig. It is felt that a VT-2 examination at this

... test pres.sure will identify any leakage qnd eliminate the overpressurization risk the Class I hydrostatic test presented.

Alternative to System Leakage Test:

During the conduct of the Class II functional test on 14"-FH-1,8-602, MOV-1701 will be open as well as MOV-1700.

This piping will be examined to the normal VT-2 requirements at the functional test con-ditions.

Licensee Basis for Relief During a normal hydrostatic test of the primary, MOV-1700 is clos*ed in addition to MOV-1701.

This prevents pressurization of MOV-1701 and the piping between the two MOVs.. Both valves are closed to prevent possible overpressurization of the residual heat removal system.

19

Evaluation The system design prevents pressurization of the piping between the subject valves.

Opening MOV-1700 could be done; however, this would require over-riding

/

an inter lock and violation of technical spec i fica-tions. The alternative testing proposed by the 1 icen-see is judged to be adequate to determine system leak tightness. Ultrasonic examination of the pipe welds in the lines will help provide assurance of structural integrity.

Conclusions and Recommendations Based on the above evaluation, Code requirements are impractical.

It is recommended that relief be granted.

6.

Relief Requests RR-8 and RR-9, 4 Hour Holding Time for Pressure Testing for the following components and piping:

Steam Generator~ and Piping Located on Station Prints; 11448-FM-64A 11448-FM-64B 11448-FM-68A 11448-FM-124A 11448-FM-138A "11448-FM-123A Component 1-RC-E-lA 1-RC-E-lA 1-RC-E-lA Connected Piping 30"-SHP-1-601 to 30"-SHP-22-601 to 4"-SHP-37-601 30"-SHP-1-601 to 2"-GN-23-601 30"-SHP-1-601 to 6"SHP-45-601 20 Component SV-MS-lOlA SV-MS-102A SV-MS-103A SV-MS-104A SV-MS-lOSA RV-MS-lOlA l-GN NRV-MS-lOlA l-MS-80,81, 266,74

e 1-RC-E-lA 30"-SHP-1-601 HCV-MS-104 to 30"-SHP-22-601 to *3"-SDHV-1-601 to 4"-SDHB-4-601 1-RC-E-lA 14"-WFPD-17-601 l-FW-27 l-FW-10 l-WT-174 1-RC-E-lA l-BD-1 l-BD-2 1..-BD-4 1-RT-l 1-RC-E-lA 30"-SHP-1-601 l-MS-379 l-MS-87 1-RC-E-lB 30"-SHP-2-601 SV-MS-lOlB to 30"-SHP-23-601 SV-MS-102B to 4"-SHP-38-601 SV-MS-103B SV-MS-104B SV-MS-105B RV-MS-101B RC-E-lB 30"-SHP-2-601 l-GN-2 to 2"-GN-24~601 1-RC-E-lB 30"-SHP-2-601 NRV-MS-101B to 6"-SHP-46-601 l-MS-112, 268, 113, 106 1-RC-E-lB 30"-SHP-2-601 HCV-MS-104 to 30"-SHP-23-601 to 3"-SDHV-2-601 to 4"-SDHV-4-601 1-RC-E-lB 14"-WFPD-13-601 l-FW-41,58 l-WT-177 1-RC-E-lB l-BD-11 l-BD-12 l-BD-14 l-RT-20 1-RC-E-lC 30"-SHP-3-601 SV-MS-lOlC to -30 "-SHP-24-601 SV-MS-102C to 4"-SHP-39-601 SV-MS-103C SV-MS-104C SV-MS-lOSC

  • RV-MS-lOlC 21

1-RC-E-lC 1-RC-E-lC 1-RC-E-lC 1-RC-E-lC 1-RC-E-lC 1-RC-E-lC

  • e 30"-SHP-3-601 to 2"-GN-25-601 30"-SHP-3-601 to 6"-SHP-47-601 30"-SHP-3-601 to 30"-SHP-24-601 to 3"-SDHV-3~601 to 4"-SDHV-4-601 30"-SHP-3-601 14"-WFPD-9-601 l-GN-3 NRV-MS-lOlC l-MS-152, 149,208, 143 HCV-MS-104 l-MS-158 l-MS-377 l-FW-72 l-FW-89 l-WT-182 l-BD-21 l-BD-22 l-BD-24 l-BD-39 Feedwater and Auxiliary Feedwater Connections Component l-FW-12 1-FW-43 1-FW-74 1-FW-31 l-FW-30 1-FW-62 1-FW-61 1-FW-93 1-FW-92 Code Requirement Connected Piping 14"-WFPD-17-601 14"-WFPD-13-601 14"-WFPD-9-601 3"-WAPD-10-601 to 3"-WAPD..;,9-601 3"-WAPD-9-601 3"-WAPD-12-601 to 3"-WAPD-11-601 3"-WAPD-11-601 3"-WAPD-14-601 to 3"-WAPD-13-601 3"-WAPD-13-601 Component l-FW-10 l-FW-41 l-FW-72 l-FW-27 l-FW-27 l-FW-58 l-FW-58 l-FW-89 l-FW-89 IWA 5213(d) System Hydrostatic Tests 4 hr. holding time*required after attaining test
  • pressure and temperature conditions for insulated systems.

22

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Proposed Alternative Examination The requirements of 3.10.2 of the Westinghouse Technical Manual require the following:

"The second-ary side hydrostatie test shall be cond~cted in ac-cordance with the ASME Code Section XI for Class 2 Components.

The secondary side pressure is to be raised to 1356 psig, held for 30 minutes and then returned to 1085 psig for a time sufficient to permit proper examination of welds, closures and surfaces for leakage or weeping."

Licensee Basis for Relief Westinghouse requires specific testing require-ments in order to maintain integrity and warranty of the steam generators. These requirements are found in the Westinghouse Technical Manual Steam Generator Vepco Surry Power Station Units 1 & 2 Volume 1, March 1979, Section 3.10. 2, "Secondary Side Hydrostatic Test."

Evaluation Testing hold time requ"irements of the Code are in conflict with testing requirements recommended by the manufacturer.

Requiring the licensee to conform to Code requirements would void the warranty of the steam

.generators.

It is judged that the manufacturer's requirements for hydrostatic testing will be adequate to ensure leak tight integrity of the steam generator and associated piping.

)

Conclusions and Recommendations Based on the above evaluation, Code requirements are impractical.

It 'is recommended that relief be granted~

7.

Relief,Request RR-13, Piping Attached to the Refueling Water Storage Tank as follows:

Component l-CS-48 Connected Piping 6"-CS-15-152 23 Component l-CS-47

Code Requirement IWC-5222 System Hydrostatic Test (a)

The system hydrostatic test pressure shall be at least 1.10 times the system pressure Psv for systems with Design Temperature of 2000F (93oC), or less, and at least 1.25 times' the system pressure Pgv for systems with Design *'+'emperature above 200 F (93°C).

~he system pressure Psv shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

(b)

In the case of atmospheric storage tanks, the nominal hydrostatic pressure developed with the tank filled to its design capacity shall be acceptable as the system test pressu~e. For 0-15 psi (0-103 kPa) storage tanks, the test. pressure shall be 1.1 PG, Design Pressure of vapor or gas space above liquid level for which overpressure protection is provided by relief valves.

(c)

For the purpose of the test, open ended portions of a suction or drain line from a storage tank extending to the first shutoff valve shall be con-sidered as an extension of the storage tank. For open ended portions of discharge lines in nonclosed systems (such as containment spray header), any test that demonstra~~s unimpaired flow shall be acceptable in lieu of a system pressure test.

(d)

The pressure measuring instrument used* for measuring system hydrostatic or pneumatic t~st pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Relief is requested from the pressure require-ments of IWC-5222(a).

Proposed Alternative Examination As an alternative, it is requested that the piping and components mentioned in l(a) be tested to the requirements of IWC-5222(b,c) associated with 1-CS-TK-l (RWST)

  • 24

0 e

e Licensee Basis *for Relief Tank l-CS-TK-1 (RWST) and piping up to l-CS-48 will be tested to system hydrostatic test criteria of IWC-5222 (b,c).

The piping and components in 1 (a) attach to the system and are included only to the requirements of Reg. Guide 1. 26 ( Feb. 1976) to include piping up to the first valve that is either normally closed or capable of automatic closure.

~ince the requirements of IWC-5222 (b,c) can only be applied from the RWST to l-CS-48 the piping mentioned in l(a) must be tested in accordance with IWC-5222(a).

This test*

would be excessive since the piping would only see pressure associated with the RWST when performing its safety function.

Evaluation The liqensee has not" provided sufficient justi-fication for the relief requested.

The piping can be tested in accordance with Code requirements and will not.impose undue hardship on the licensee.

Conclusions and Recommendations Based on the above evaluation, it is recommended that relief not be granted.

a.*

Relief Request RR-14, Components and Associated Pip-

. ing on the Circulating and Service Wa~er System as follows:

Circulating and Service Water System Recirculation Spray Heat Exchangers 1-RS-E-lA 1-RS-E-lB 1-RS-E-lC 1-RS-E-lD Code Requirement Associated Piping Between Below Listed Valves Con-necting Heat Exchangers

--:-.:..:. -~

MOV-SW-lOSA, MOV-SW-104A MOV-SW-105B, MOV-SW-104B MOV-SW-lOSC, MOV-SW-104C MOV-SW-lOSC, MOV-SW-104D IWD-5223 System Hydrostatic Test (a)

The system hydrostatic test pressure shall be at least 1.10 times the system pressure P8v for systems with Design Temperature of 2QQOp (93 C) or 25

e less, a~d at least 1.25 times the system pressure Psv for systems with Design Temperature above 2000F (93°C).

The system pressure Psv shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within*

the boundary of the system to be tested.

(b)

In the case of atmospheric storage tanks, the hydrostatic head, developed with the tank fi-lled to its design capacity, shall be acceptable as the test pressure. For 0-15 psi (0-103 kPa) storage tanks, the test pressure shall be 1.1 PG, Design Pressure of vapor or gas space above 1 iquid level for which overpres~ure protection is provided by relief valve.

(c)

For the purpose of the test, open ended portions of suction or drain lines from a storage tank extending to the first shutoff valve shall be con-sidered as an extension of* the storage tank. For open ended portions of nonclosed systems, any test or observation during system operation that demonstrates unimpaired flow shall be acceptable in 1 teu of a system pressure test..

(d)

The pressure measuring instrument used for

  • measuring system hydrostatic or pneumatic test pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Reliet is requested from the letter of the Code requirements for test pressure to be 1.10 times system design pressure.

Proposed Alternative Examination An an alternative, it is requested that the test pressure for IWD-5223 Class III system hydrostatic test be the design pressure 25 psig.

The normal VT-2 exami~ation will be conducted at this pres9ure.

Licensee Basis for Relief The design specification for this component (station #NUS 85)

  • limits the recirculation spray coolers to design pressure (25 psig) and temperature between 42 and 950F.

tinder the conditions specified in IWD-5223(a) a value 1.1 times the design pressure or 27. 5 psig must be used as test pressure. It is felt no substantial gain would be realized at the required 26

e e

test pressure of 27. 5 psig c~nsidering the design limitation of 25 psig.

Evaluation The licensee has not provided adequate justifi-cation for granting relief from Code requirements.

The subject piping apparently can be tested without

  • imposing undue hardship on the licensee.

Conclusions and Recommendations Based on the above evaluation, it is recommended that relief not be granted.

9.

Relief Request RR-15, Open Ended Intake Piping Before the First Shutoff Valve in Non-closed Systems Located on 11448-FM-71B and Non-isolatable Class III Piping as follows:

Circulating and Service Water System Components and ~iping as listed located on station.

pr int 1144*8-FM-72B.

Component Cooling Water Component Connected Piping Component l-CC-241 6"-CC-76-151 l-CC-242 TV-CC-llOA 6"-CC-78-151 RO-CC-100, l-CC-246 l-CC-232 6"-CC-77-151 l-CC-233 TV-CC-llOB 6"-CC-79-151 TV-CC-llOC 6"-CC-80-151 RO-CC-101, l-CC-228 l-CC-223 6"-CC-75-151 l-CC-224 Code Requirement IWD-5223 System Hydrostatic Test (a)

The system hydrostatic test pressure shall be at least 1.10 times the system pressure P§v for systems with Design Temperature of 200°F (93 C) or less, and at least 1.25 times the system pressure Pgv for systems with Design Temperature above 200 F (93°C).

The system pressure Psv shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

27

  • e (b)* In the case of atmospheric storage tanks, the hydrostatic head, developed with the tank filled to its design capacity, shall be acceptable as the test pressure. For 0-15 psi ( 0-103 kPa) storage tanks, the test pressure shall be 1.1 PG, Design Pressure of vapor or gas space above liquid level for which overpressure protection is provided by relief valve.

(c)

For the purpose of the test, open ended portions of suction or drain lines from a storage tank extending to the first shutoff valv~ shall be con-sidered as an extension of the* storage tank.

For open ended portions of nonclosed systems,. any test or observation during system operation that demonstrates unimpaired flow shall be acceptable in lieu of a system pressure test.

(d)

The pressure measuring instrument used for measuring system hydrostatic or pneumatic test pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Relief is requested from the pressure require-ments of IWD-5223(a).

~ Proposed Alternative Examination Non-closed Systems As an alternative, the requirements applied to open ended portions of discharge lines (IWD-5223(d))

will be applied in this case; that is confirmation of adequate flow during system operation shall be ac-ceptable in lieu of system hydrostatic test.

Non-isolatable Piping As an alternative to two separate Class II and Class III hydrostatic tests, it is requested that a Class III hydro be run utilizing the relief valves RV-CC-112A, B, C set at 146 psig as Psv for the test. This test will encompass the components and piping listed in item l(a) and a normal VT-2 examination will take place.

28

-1

e Licensee Basis for Relief Non-closed Systems The Code addresses the problem of* performing hydrostatic test on open ended portions of discharge lines beyond the last shut-off valve in non-closed systems in IWD-5223 (d) of the Code. A similar problem exists for the intake piping at Surry Unit 1 as it is non-isolatable for the increased pressure require-ments of a hydrostatic test.

Non-isolatable Piping The piping and components listed above cannot be isolated from the Class III system encompassing tne reactor containment air recirculation coolers. Since the Class II boundary contains no.safety or relief valve, Po (150.psig) will be used in determining test pressure or 165 psig. This pressure is higher than the test pressure to be used on the Class III side which is based on Psv of 146 psig for a test pressure of 160. 6 psig.

Evaluation Due to system design, the subject piping cannot be isolated from an open ended tank for testing _at Code required pressures. Requiring the licensee to test at

  • *code pressure would impose an undue hard§hip by forc-ing a re-design of the system.

The alternate testing proposed by the licensee is judged adequate to assure

>system leak-tight integrity.

Conclusions and Recommendations Based on the 1 icensee 's discussion, Code re-quirements are impractical and relief should be granted.

10.

Relief Request RR-17,. Steam Generators - Primary to Secondary Leakage Detection Code Requirement IWA-5240 (a)

The visual examination VT-2 shall be con-ducted by examining the accessible exposed surfaces of pressure retaining components.

29

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Code Relief Request Relief is requested from direct visual observa-tion for primary to secondary leakage.

Proposed Alternative Examination The normal primary to sec.ondary leakage surveil-lance requirements of the plant's technical specifi-cations provide the necessary intended Code examina-tion requirements for leakage identification.

Licensee.Basis for Relief Primary to secondary leakage detection using Code described visual detection techniques would be 1 imi ted in usefulness and hazardous to conduct.

Evaluation The Code does not intend direct visual examina-tion of steam generator tubing during hydrostatic testing.

The Code allows for direct visual observa-tion of surrounding areas for evidence of leakage.

Conclusions and Recommendations Based on the licensee's discussion, Code re-quirements are impractical.

It is recommended that relief be granted.

11.

Relief Request*RR-18, Piping Associated with Diesel Fuel Oil System Code Requirement IWD-5223 System Hydrostatic Test

( a)

The system hydrostatic test Psv for systems pressure shall be at least 1.10 times the system pressure Psv for systems with-Design Temperature of 200°F (93°C) or less, and at least 1.25 times the system pressure Psv for systems with Design Tempera-ture above 200°F ( 930c)

  • The system pressure Psv shall be the lowest pressure setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested.

30

  • ( b)

In the case of atmospheric. storage tanks, the hydrostatic head, developed-with the tank* filled to its design capacity, shall be a_cceptable as the test pressure. For 0-15 psi (0-103 kPa) storage tanks, the test pressure shall be 1.1 PG, Design Pressure of vapor or gas space above liquid level for which overpressure protection is provided by relief valve.

( c)

For the purpose of the test, open ended portions of suction or drain lines from a storage tank extending to the first shutoff valve shall be con-sidered as an extension of the storage( tank. For open ended portions of nonclosed systems, any test or observation during system operation that demonstrates unimpaired flow shall be acceptable in 1 ieu of a system pressure test.

(d)

The pressure me$suring instrument used for measuring system hydrostatic or pneumatic test pres-sure shall meet the requirements of IWA-5260.

Code Relief Request Relief is requested from pressure test require-ments of IWD-522~.

Proposed Alternative Examination As an alternative, a modified system inservice

  • test will be conducted requiring only visual examina-tion of exposed piping; and the verification of ade-quate fuel transfer to the base tank to verify func-tional adequacy of underground piping.

1.;

Licensee Basis for Relief This system transports fuel oil to the*emergency generators so that the 550 gallon generator base tank can be refilled to maintain generator capacity. These components although of an important nature are beyond the original concept designed for Section XI testing.

(That testing originally was for water, steam systems

- see attached inquiry BC/77 /666)

  • In a_ny event high pressure testing of fuel oil systems using the fuel oil as the pressurizing medium would be hazardous to conduct.

Evaluation We agree with the licensee's basis for relief.

31 0

e High pressure testing of the fuel supply system is potentially hazardous.

A functional test of the diesel fuel supply is judged adequate to ensure system integrity.

Conclusions and Recommendations Based on the. licensee's discussion, Code re-quirements are

  • impractical and relief should be granted.

32 1

)

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