ML19256A294
| ML19256A294 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/20/1978 |
| From: | Short T OMAHA PUBLIC POWER DISTRICT |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7811280257 | |
| Download: ML19256A294 (3) | |
Text
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Omaha Public Power District 1823 HANNEY a
OMAHA. NEDRA8MA 68102 m TELEPHONE 536-4000 AREA CODE 402 November 20, 1978 Director of Huclear Reactor Regulation ATT'l:
Mr. Robert W. Reid, Chief Operating Reactors Branch No. 14 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 50-285(N)
Re ference :
Docket No.
Gentlemen:
During the course of inservice inspectica and testing conducted at the Omaha Public Power District's Fort Calhoun Station during the current refueling outage, it has been discovered that a certain hydro-test requirement for Class 2 piping in ASME XI, Summer of 1975 Addenda, is " impractical" within the meaning of 10 CFR S 50.55(a). Accoruingly, a revision (Pages 8 and 9) to the document entitled " Fort Calhoun Station Unit No. 3 Inservice Inspection Program Plan for the 1976-1980 Period",
dated September, 1978, is attached and contains an appropriate relief request. The program plan was submitted to the Commission for review in September of 1978.
It is the District's understanding, subsequent to discussions with members of your staff, that testing of Class 2 piping will be conducted in accordance with the program plan as revised to date.
Final resolu-tion of testing requirements will be achieved after t'le Commission's approval of this plan.
Sincerely, I
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- <, fg T.' E. 'Short Assistant General Manager TES/KJM/BJH:Jmm
- Attach, cc:
LeBoeuf, Lamb, Leiby & MacRae 1757 "N" Street, N. W.
Washington, D. C.
20036 09%
78'.1280257
s with Article IWA-5000 and Article IWB-5000 of Reference (1) and in accordance with Figures 2-1 and 2-2 of the Technical Specifications.
1.7.2.2 At or near the end of each inspection interval, a hydrostatic pressure test shall be performed on the reactor coolant system components.
This test shall be conducted in accordance with the require-ments of Article IWA-5000 and Article IWG-5000 of Reference (1).
Test tempera-ture shall be in accordance with Figures 2-1 and 2-2 of the Technical Specifications.
1.7.3 Class 2 Components 1.7.3.1 Pressure tests and visual examination of Class 2 Components will be performed in accordance with the guidelines of Paragraph IWC-2412 of Reference (1).
The test pressures will be in accordance with the regnirements of Article IWC-5000,
. Winter 1977 Addenda, in exception to the requirements of Reference (1).
The Tech-nical Specification 2.1.1 limiting the number of cycles at 125% of the design pressure to 10 for the secondary system (Steam /Feedwater) will be taken into con-sideration.
8
Basis for Exception:
The majority of the Class 2 piping systems, subject to the Section XI pressure testing, can be tested only when the plant is in a cold shutdown condition.
While in this mode, there does not exist a means of heating the piping systems above ambient temperatures.
Providing a means of heating long piping systems to 1000F is considered impractical, within the meaning of 10 CFR 50.55a.
The minimum temperature requirement for performing a system hydroslatic pressure test was established to meet the requirements specified by fracture prevention criteria.
Since the Fort Calhoun ferritic components' ambient room temperatures are sufficiently above brittle fracture temperatures (NDT typically < -200F), heating the systems to 1000F is unnecessary.
For the austenitic steel com-ponents, the NDT temperature is typically -3250F; far helow any possible testing temperature.
Again, heating tl'e austenitic materials to 1000F is unnecessary.
Preservice hydrostatic tests were performed at ambient temperatures and it is the judgment of OPPD that hydro-testing at ambient temperatures is still acceptable.
1.7.4 Class 3 Components 1.7.4.1 Class 3 Components shall be pressure tested in accordance with Article IND-5000 of Reference (1).
1.8 Records and Reports 1.8.1 Records and Reports for the inspections made in accordance with this program shall be developed
~
and maintained in accordance with Article IWA-6000 of Reference (1).