ML19031B398

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Transmit Information Re Conformance to ANSI B31.7, Which Contains Many Requirements That Were Impractical to Follow, Especially in Area of Radiography
ML19031B398
Person / Time
Site: Salem  PSEG icon.png
Issue date: 01/08/1976
From: Mittl R
Public Service Electric & Gas Co
To: Vassallo D
Office of Nuclear Reactor Regulation
References
Download: ML19031B398 (2)


Text

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Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 Pho.ne 201 /622-7000 Director of Nuclear Reactor u.s. Nuclear Regulatory Washington, DoCo 20555 Attention:

Mro D.B. Vassallo, Chief Light Water Reactor Projects Branch 1-1 Gentlemen:

APPLiCATION OF ANSI B3lo7 NO~ 1 AND 2 UNITS SALEM NUCLEAR GENERATING S,TION DOCKET.NOSo 50-272 AND <Q.731i:)

In response to your telephone request, Public Service Electric and Gas Company hereby transmits the following information regarding conformance to ANSI B31.7, code for Nuclear Power Piping, for fabrication and inspection of piping "wherever possible," as indicated in Amendment 33 to the Salem FSARo ANSI B3lo7 was an interim iocument which did not have a history of field applicationo It contained many requirements that were, at best, impractical to follow, especially in the area of radiographyo In order to overcome these areas, code cases to ANSI B3lo7 were_ prepared and accepted, and an addendum was issued.

Subsequently, ANSI B3lo7 was made a part of Section III of the 1971 edition of the ASME Boiler and Pressure Vessel Code.

Therefore, using ANSI B3lo7 in its original form would also require using the later documents, especially ASME III - 1971, for guidance in dealing with problems created by the original document 0 Specific examples of field problems created as a result of using ANSI B3lo7 in its original form are indicated below.

lo Radiographic requirements were related to pressure vessel fabrication, and were not suitable for application to piping; e.,g.,

a 0 )

Inability to obtain reliable results* and proper sensitivity when radiographing small (under 4-in) diameter piping, in accordance with Table B-1-110, using isotopes. This was recognized and partially corrected by ANSI B31 0 7 Code Case 720 315 95-2001. (40aM) 5-73

2 1-8-76 b.) In the examination of 4-ino to 10-ino diameter piping, it is not feasible to adhere to Table B~l~l20, with regard to the placem~nt of film and penetrameters. This situation was correc.ted by ASME III... 1971, which contains Table IX-3325-2 and.requirements directly appli-cable to radiography of pipe and tubing.*

  • Therefor.e, radiographic procedures utilized at Salem meet the requirements of ASME III - 1971 and, in some areas, are more stringent.
2.

ANSI B3lo7 permitted no undercutting in pipe welds.

This requirement is unreasonable and other widely used codes recognize that a limited amount of undercutting in a welded structure is tolerable. ANSI B31~7 Code Case 83 was prepared tq permit undercutting up to 1/32-in, as does ASME III - 1971 0

3.

The NDE requirements of ANSI B3lo 7 required random radiography of Class III pipe joints over 4-in0 in diameter 0 This presents a problem with certain types of piping, particularly piping which is internally-lined.

The 1970 addendum to ANSI B31 0 7 per-mitted an alternate means of examining Class III pipe welds, as does AS:M:E III -

1971~

PSE&G has conformed with the intent of Amendment 33 to the Salem FSAR by adhering to ANSI B31.;i 7 "wherever possibleo" In those areas where adherence has not been possible, we have been guided by the requirements of the later code, which represents a more enlightened approach to nuclear construction.

In view of the above, the Salem FSAR will be amended to read: "where not possible to comply with ANSI B3la7, the requirements of ASME III - 1971, which incorporated ANSI B3lo7, were adhered to."

Very truly yours, RoLo Mittl General Manager - Projects Engineering and Construction Department

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