ML20054J058
| ML20054J058 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/18/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20054J057 | List: |
| References | |
| TAC-48002, NUDOCS 8206280031 | |
| Download: ML20054J058 (5) | |
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SAFETY EVALUATION REPORT INSERVICE INSPECTION RELIEF REQUESTS CLASS 3 COMPONENTS e
TROJAN NUCLEAR PLANT i
INSERVICE INSPECTION SECTION MATERIALS ENGINEERING BRANCH j
By letter dated May 8,1981, the NRC granted relief from certain inservice inspection requirements for Class 1 & 2 component.s in the Trojan Nuclear Plant j
and stated that specific limitations should be identified for a given Class 3 l
component, system or portion of a system in order that the request could be evaluated in accordance with 10 CFR 50.55a(g).
By letter dated February 5,1982, j
Portland General Electric Company submitted specific relief requests for some Class 3 components as directed.
The requests and evaluations are iter,ized below.
1 15.
CLASS 3 COMPONENTS AND SUPPORTS (1) CODE DEVIATION REQUEST:: Relief is requested from the visual examina-i i
tion requirement for the Diesel Oil Storage Tanks, Diesel Oil Transfer Pumps (P-144 A and B) and portions of associated piping as j
shown on isometrics HBD-72-1,
-2, -3 and HBD-72-50 and -51.
i CODE REQUIREMENT:
(a)
Visual examination of 100 percent of Class 3 components and supports shall be performed while the system is in, operation or undergoing system testing each 40-month period and during i
hydrostatic testing each 10-year interval.
(b)
In the case of buried components (e.g., underground piping),
valves shall be provided to permit isolation of the buried i
portions of piping for the purpose of conducting a system pressure test in lieu of, the visual examination.
A loss of system pressure shall' constitute evidence of component leakage.
i (c)
In the case of storage tanks, the nominal hydrostatic pressure l
developed with the tank filled to its design capacity shall be acceptable as the system test pressure.
i (d)
Open-ended portions of a system (e.g., suction line from a storage tank) extending to the first shutoff valve may be exempted from the test requirements of IWD-5200 System Test l
l Requirements.
j REASON FOR REQUEST i
l The Diesel Oil Storage Tanks (T-119A and B) and portions of the l
associated piping are either buried underground _or in concrete.
The (iesel Oil Transfer Pumps (P-144A and B) are submerged in. the Diesel Oil Storage Tanks (T-119A and B).
These areas cannot be j
seen by the examiner while the system is in operation or undergoing
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system testing.
i 8206280031 820618 i
i PDR ADOCK 05000344 G
PDR t
, ALTERNATIVE EXAMINATION The examination to locate evidence of leakage in diesel fuel oil components will be performed by verifying that the flow of diesel fuel oil during operations is not impaired.
Verifying that the flow of diesel fuel oil is not impaired is performed on a routine basis during plant tests of the diesel fuel oil systems.
STAFF EVALUATION The Diesel Oil Storage Tanks Transfer Pumps, and portions of the associated piping are either buried or' encased in concrete and thus are impractical to examine visually.
The impracticality of the visual examination requirement for buried components and piping was recognized by the Code and alternative methods for determining component or piping leakage were incorporated.
Visual examination is not required for the components for which relief has been requested. A loss of significant oil level in the Diesel Oil Storage
. Tanks will serve as evidence of tank or piping leakage.
Scheduled or unscheduled maintenance of the Transfer Pumps in addition to the licensee's Alternative Examination given above is adequate to deter-mine the condition of the pumps.
'(2)
CODE DEVIATION REQUEST: Relief is requested from the visual examina-tion requirement for the following components:
(a) Cation Bed Demineralizer Tank (T-211) and portions of associated piping as shown on isometrics CS-151R-9-51, CS-151R-9-55, and i
CS-151 R-30-1. -
(b) Mixed Bed Demineralizer Tanks (T-210A and B) and portions of associated piping as shown on isometrics CS-151R-9-52, CS-151 R-9-53, CS-151R-9-55, and CS-151 R-30-1.
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s (c) Evaporatof Feed Ion Exchangers (T-219A, B, and C) and portions of associated piping as shown on isometrics CS-151R-14-1, CS-151 R-14-2, CS-151R-14-54, CS-151 R-14-55, CS-151 R-14-56, and CS-151 R-14-60.
(Note:
Inspections will continue until inspector exposure reaches 0.1 man-rem per inspection.)
CODE REQUIREMENT IWD-2400 requires visual examination of 100 percent of the Quality Group 3 components and supports while the system.is in operation or undergoing system testing each 40-month period and during hydrostatic testing for each 10-year interval.
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, REASONS FOR REQUEST The Cation Bed Denineralizer Tank (T-211) and portiors of the associated piping located in an area where accessibiiity is limited due to ALARA considerations.
This area should be avoided because personnel radiation exposures a're estimated to be about 0.5 man-rem j
per inspection.
The estimate assumes the spent resins are previously sluiced from the demineralizer vault (to minimize exposur.es) and current failed fuel rates.
Since radiation levels are expected to increase with time due to buildup of contamination in pipes and vessels and possibly higher failed fuel rates, this value may increase in the future.
The Mixed Bed Demineralizer Tanks (T-210A and B) and portions of the associated piping are located in an area where accessibility is limited due to ALARA considerations.
These areas should be avoided because personnel radiation exposure's are estimated to be about 0.8 man-rem for the examination of each' tank.
The values for personnel exposure are based on the same considerations presented above.
The evaporator Feed Ion Exchangers (T-219A, B, and C) and portions of the associated piping are located in an area where accessibility may be limited due to ALARA considerations.
These areas should be avoided when estimated personnel radiation exposures exceed 0.1 man-rem for the examination of each tank.
Although current conditions
'will allow inspection of these demineralizers, plant conditions in the future may result in exposures greater than 0.1 man-rem.
ALTERNATIVE EXAMINATION Leakage from the Cation Bed Demineraliz'er Tank (T-211), Mixed Bed Demineralizer Tanks (T-210A and B), Evaporator Feed Ion Exchangers (T-219A, B, and C) and portions of the associated piping will result in increased airborne radioactivity levels caused by the noble gases present in the leakage and/or increased levels in the Dirty Waste Drain Tank, (T-311).
Radiation levels and tank levels are routinely l
j monitored at the plant.
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STAFF EVALUATION The visual examination requirement for the Demineralizer Tanks, Evaporator Feed Ion Exchang'ers, and associated piping is not an impractical requirement to perform at this time.
However, the frequency of the examination could be an impractical requirement when personnel radiation exposure, component failure history, and the safety gained by performing the visual examination are considered.
Radiation and tank level monitoring are performed monthly and will provide adequate assurance of the component and piping integrity.
It is the staff's conclusion that visual examination of the components and piping should be performed at a time coincident with any scheduled or unscheduled maintenance or repair, but not to exceed the frequency 4
requirement of the Code.
Relief from the frequency of visual examination may be granted.
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. (3) CODE DEVIATION REOUEST:
Relief is requested from the visual examina-tion requirement 17r the Service Water Pumps (P-108A, B, and C) and portions of associa+.ed piping.
CODE REQUIREMENT:
(a) Visual examination of 100 percent of Class 3 components and supports shall be performed while the system is in operation or undergoing system testing each 40-month period and during hydrostatic testing each 10-year interval.
(b)
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 shall constitute evidence of component leakage.
REASON-FOR REQUEST
'The Service Water Pumps (P-108A, B, and C) and portions of the associated piping are bdried underground, buried in concrete, or are submerged in water.
The piping from the discharge of the Service Wa.ter Pumps (P-108A, B, and C) as shown on isometric HFD-1-4 is submerged in water at the intake structure.
This area cannot be seen by the examiner while the system is in operation or undergoing system testing.
ALTERNATIVE EXAMINATION The examination to locate evidence of leakage in the service water system is performed by verifying that the flow of service water during operation is not impaired.
Verifying that the flow of service water is not impaired is performed on a monthly basis during plant tests of the service water system.
STAFF EVALUATIOk Visual examination of buried ~ components and piping is not required by the Code.
Leakage is determined by a pressure test of the system.
The plant tests of'the Service Water System is adequate in providing assurance of the system's structural integrity.
(4)
CODE DEVIATION REQUEST:
Relief is requested from visual examination of the Containment S Storage Tank (T-206) pray Pump suction line from the Refueling Water CODE REQUIREMENT:
(a) Visual examination of 100 percent of Class 3 components and supports shall be performed while the system is in operation or undergoing system testing each 40-month period and during
. s hydrostatic testing each 10-year interval.
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' (b)
In 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 shall constitute evidence of component leakage.
(c)
Open-ended portions of a system (e.g., suction line from a storage tank) extending to the first shutoff valve may be exempted from the System Test Requirements, IWD-5200.
REASON FOR REQUEST The Containment Spray Pumps (P-204A and B) suction line from the Refueling Water Storage Tank (T-206) as shown on isometric SI-151R-10-1 is buried underground.
This area cannot be seen by the examiner while the system is operating or undergoing system testing.
STAFF EVALUATION The suction line from the Refueling Water Storage Tank is exempted from visual examination and pressure testing by the Code.
An 4
unaccounte.d for loss of tank level constitutes evidence of either tank or piping loss of structural integrity. ' Relief from visual examination is not required.
CONCLUSION:
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Based on the foregoing, we conclude, pursuant to 10 CFR ISO,55a(g)(6)(1),
that granting of this relief is authorized by law and will not endanger i
life or property, or the conson defense and security, and is otherwise in the public interest.
In making this determination, we have given due consideration to the burden that would result if the Code require-ments.were' imposed on the facility, and conclude that relief should be granted.
Date: JUN 181982 Principal Contributor:
George Johnson l
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