ML20012B656
| ML20012B656 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/09/1990 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003160049 | |
| Download: ML20012B656 (10) | |
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David W. Cockfield Vice President, Nuclear i
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March 9, 1990 Trojan Nuclear plant i
Docket 50-344 License NPF-1 l
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U.S. Nuclear R*Eulatory Commission l
Attnt Document Control Desk Washington DC 20555 Dear Elts; Trojan Nuclear plant Inssevice 7nspection
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Program Decond Ten-Year interval k81u,eJ,1.,,($1;JJ.1kraaQ,o,n,L l
Py lutter dsted kept.empw 19. 19b9, Fortland General Electric Company (PCd) m, cuisitted Revision-1 of Torh ei Soport PCE-1049, Trojan No7.lces rlant.
l 1* sr.rvice Inspection proctam cocond Ten Yaw 'Intwer!", to the Nac14sr g'
Repistcry Cocalssion iLPO) fcr re'tiov. M or.g W,h the submittal, PGW D
requested approval of an upgrade to thel.9a4 laition of American society of h
Mechanical Engireers (ASNE)Section XI for the exemption. Selectiun, and i
exas.ination criteria for Class 2 piping welds and appr& val of the relief requests contained in the revision of our inservice inspection (ISI) l program.' By letter dated January 17, 1990, PCE submitted supplemental l.
information to assist in the review process at the request of i
l Wr. Roby Bevan.
By letter dated January 30, 1990, the NRC requested additional information I
-needed to complete the review. Responses to your requests are attached.
We request that priority be given to approval of the upgrade to the 1986 ls i
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1 121 S.W. Salmon Street, Portland, Oregon 97204,503/404-8697
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Ptwtiand Genend BecticCormany Document Control nosk March 9, 1990 g
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Code and of Relief Requests RR-B2, " Flued Head Containment Penetrations With Welds Within the Guard Pipe", and RR-B5, " Class 2 and Class 3 i
Hydrostatic Test Scheduling", since these are required to support our 1990 l
I Refueling Outage.
Sincerely, Attachments et Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear ReSulatory Commicsion Mr. David Stewart-Smith Stato of Oregon Department of Energy i
Mr. R. C. Barr NRC Resident. Inspector Trojan Nuclear Plant f
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Docket 50-344 March 9, 1990 License NPF-1 Attachment A Page 1 of 3 RESPONSES TO REQUESTS FOR INFORMATION CONCERNING REVISION 1 0F THE TROJAN NUCLEAR PLANT INSERVICE INSPECTION (ISI) PROGRAM SECOND TEN-YEAR INTERVAL f
By letter dated September 29, 1989 Portland General Electric Company (PGE) submitted Revision 1 of Topical Report PGE-1049, " Trojan Nuclear qi-Plant Inservice Inspection Program Second Ten-Year Interval", to the Nuclear Regulatory Commission (NRC) for review. By letter dated January 30, 1990 the NRC requested additional information needed to cemplete the review. The following responses are provided to satisfy your request.
L Request As l
l' Section 6.3, " Class'3 Exempt Components", on page 6-6 of the ISI Program, L
' Revision 1, states that piping and components in the Class 3 systems l
Ifsted are exempt from examination by IWD-1220. Paragraph IWD-1220 of Sestion XI of the Code does exampt certain Class 3 integral attachments from examination but does not exempt Class 3 piping from examination.
' Table IWD-2500-1 of Section XI of the Code requires visual (VT-2) examination of Class 3 pressure retaining components during system-L hydrostatic and system pressure tests. Note 4 of Table IWD-2500-1 states p
that there are no exemptions or exclusions from these. requirements except
[l as specified in IWA-5214(c). Provide clarification of the exemptions i
taken for. Class 3 systems.-
s PGE Response:
In accordance with Paragraph 'IWD-1200, " Components Subject to
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Examination" PGE identified all Class 3 pressure retaining components
.and their integral attachments, and categorized them in accordance with l
Table IWD-2500-l'.
The exemption criteria were then applied to identify those Class 3 components exempted from visual (VT-3) examination. The intent of Section 6.3 was not to exempt Class 3 piping from all t
examination requirements.
'A'new version of page 6-6 of the ISI Program is provided as Attachment B.
It clarifies the applicability of the exemption criteria, which are for visual (VT-3) examination only, and will be included in n revision of PGE-1049 by April 13, 1990.
Reauest B:
- Paragraph (4)(d) of.Section 11.1, " General Criteria", on page 11-2 of the ISI Program, Revision 1, states that component connections, piping, and associated valves that are 1-inch nominal pipe size and smaller are exempt from hydrostatic testing. This statement only applies in cases 3
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y Trofan' Nuclear Plant Document Control Desk Docket 50-344 March 9, 1990 License NPF-1 Attachment A Page 2 of 3 I
where there have been welding repairs made on the pressure retaining boundary as stated in Paragraph IWA-4400(b)(5).
Confirm that this piping i
has not been exempted from the hydrostatic testing required by IWA-5000.
PCE Response PGE concurs that the exemption of component connections, piping and associated valves that are 1-inch nominal pipe size and smaller is only applicable for welding repairs as stated in Paragraph IWA-4400(b)(5).
l PGE will delete Paragraph (4)(d) of Section 11.1 in a revision of PGE-1049 by April 13, 1990.
Request C:
The Code requires both surface and volumetric examinations of certain Class 1 and Class 2 piping welds, whereas the ISI Program states that only volumetric examination is required. Corrections should be made to the following items in Table A, " class 1 Section XI Summary", and Table B, " Class 2 Section XI Summary", of the ISI Program to include the Code-required surface examination:
Table A, " Class 1 Section II Summary", Pages 16 and 17, Items B9.11 and B9.31, respectively.
Table B, " Class 2 Section XI Summary",-Page 37. Items C5.11 and C5.12, and Page 39, Items C5.51 and C5.52.
Note that these only examples -- the Licensee should verify the correctness of all information in these two tables and make necessary corrections.
PCE Response:
PGE reviewed the Class 1 and 2 Section XI Summary Tables and concurs that the " Exam Method" column does not consistently denote all examination requirements for each item. This is a result of a computer software deficiency in generating the sen.tary tables. Please note that the ISI Computerized (ISIC) data base which was provided as an enclosure in our letter of September 29, 1989 does reflect the appropriate examinations, PCE'is pursuing correction of the software deficiency and will include i
corrected summary tables in a revision of PCE-1049 by November 23, 1990.
Request D:
Request for Relief RR-B2: It is stated in the ISI Program that the extent of examination for Class 2 piping welds has been determined by the 1986 Edition of the American Society of Mechanical Engineers (ASME)
Code Section XI.
However, in Relief Request RR-B2, relief is requested i
"a Trojan Nuclear Plant-Document Control Desk Docket 50-344 March 9, 1990 License WPF-3 Attachment A Page 3 of 3 from the 1983 Edition, Summer 1983 Addenda Code requirements for Class 2 piping welds. This relief request should be revised to include the requirements of the 1986 Edition of the ASME Code Section II for Class 2 piping welds.
PGE Responset A corrected version of Relief Request RR-B2 is provided as Attachment C.
It accurately reflects the use of the 1986 Edition of Section XI and will replace the existin5 relief request in a revision of PGE-1049 by April 13, 1990.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9, 1990 License NPF-1 Attachment B Page 1 of 2 6.3 CLASS 3 EXEMPTION CRITERIA IWD-1220-1 Integral attachments of supports and restraints to components that are 4-inch nominal pipe size and smaller within the system boundaries of Examination Categories D-A, D-B, and D-C of Table IWD-2500-1 shall be exempt from the visual examination VT-3, except for Auxiliary Feedwater Systems.
IWD-1220-2 Integral' attachments of supports and restraints to components exceeding 4-inch nominal pipe size may be exempted from the visual examination VT-3 of Table IWD-2500-1 provided:
a) The components are located in systems (or portions of systems) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling.
b) The components operate at a pressure of 275 psis or less and a temperature of 200*F or less.
Piping and component integral attachments in the following systems, which have been designated Class 3, are exempt as applicable from visual examination VT-3 requirements of Table IWD-2500-1:
L FSAR l
System Figure No.
P&ID No.
Safety Injection System 6.3-Ib M-206, Sht. 2 Spent Fuel Pool Cooling 9.1-4 M-227 l
and Dcmineralizer System Service Water System 9.2-la M-218, Sht. 1 9.2-1b M-218, Sht. 2 Component Cooling Water System 9.2-4a M-215, Sht. 1 9.2-4b M-215, Sht. 2 9.2-4c M-215, Sht. 3 Process Sampling System 9.3-2 H-231, Sht. I 9.3-4 M-231, Sht. 3 Chemical and Volume Control 9.2-14a M-202, Sht. 1 System 9.3-14b M-202, Sht. 2 9.3-15 M-203 9.3-16 M-204
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9, 1990 License NPF-1 Attachment-B i
PaSe 2 of 2 FSAR System Figure No.
P&ID No.
Process Sampling System 9.3-21 M-231 Sbt. 5
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Diesel Fuel Oil System 9.5-3 M-226 Main Steam System 10.2-3c M-208, Sht. 3 l
Circulating Water and Turbine 10.4-la M-216, Sht. 1 Building Coolin5 Water System Condensate and Feedwater 10.4-2b H-213 Sht. 1 System 10.4-2c M-213, Sht. 2 Auxiliary Steam System 10.4-3a M-214, Sht. 1 l'
Dirty Radioactive Waste 11.2-14 M-221 Treatment System
-Radioactive Gaseous Waste 11.3-4 M-222 System LGD/bsh 4419W.0390 t
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1 Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9, 1990 License NPF-1 Attachment C Page 1 of 2 RELIEF REQUEST RR-B2 Component
Description:
Containment penetration - Flued head welds penetration nunibers as follows:
Catemory C-F-1 Catemory C-F-2 P-11 P-47 P-28 P-32 P-44 P-63 P-29 P-33 P-45 P-70 P-30 P-34 P-46 P-31 P-35 ASME Code Class:
ASME KI Class 2 - penetrations.
ASME XI Examination Requirements:
Subsection IWC, Table IWC-2500-1 Examination Categories C-F-1 and.C-F-2 require surface, or surface and volumetric examination of'circumferential piping welds each inspection interval.
Basis for Relief:
Due to the design of the Containment penetration assemblies, the pressure retaining pipe weld (see attached drawing) installed in the penetration guard piping fis inaccessible for examination.
Alternative Examination:
No alternative examination proposed.
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