ML20058N831

Safety Evaluation Granting Relief Until Next Scheduled Outage Exceeding 30 Days & No Later than Next Scheduled Refueling Outage

ML20058N831
Person / Time
Site:	Hope Creek
Issue date:	08/13/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20058N830	List: ML20058N826 ML20058N831
References
NUDOCS 9008150152
Download: ML20058N831 (2)

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% . . . . .)j ENCLOSUE 1 SAFETY EVALUATION BY THE OFFICE OF-NUCLEAR REACTOR REGULATION REQUEST FOR REllEF FROM ASME CODE REPAIR REQUIREMENTS l FOR ASME' CODE CLASS 3 PIPING j PUBLIC SERY1CE ELECTRIC-AND CAS COMPANY HOPE CREEK I DOCKET NO. 50-354- .

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1. BACKGROUND I Temporary Non-Code Repairs 10 CFR 50.55a(g) requires nuclear power facility piping and components to meet I the applicable requirements of Seciton XI of the ASME Boiler and Pressure VesselCode(hereaftercalledthecode).Section XI of the code specifies 4

code-acceptable repair methods for-flaws that exceed code acceptance limits in piping that is in service. A code repair is required to restore the structural integrity of flawed code piping, independent of the operational j mode of the plant when the flaw is detected. Those repairs not in compliance with Section XI of the code are non-code repairs. However, the required code repair may be impractical for a flaw detected during plant operation unless.

the facility is shut down. Pursuant to 10 CFR'50.55a(g)(6)(i); the Comission will evaluate determinations of impracticality, and may grant relief and may impose alternative requirements. Generic Letter 90-05, entitleo " Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping," -!

dated June 15, 1990, provides guidance for the staff in evaluating relief requests submitted by licensees for temporary non-code repairs of code Class 3 piping. The Comission may grant relief based on a staff evaluation considering the guidance in Generic Letter 90-05.

Licensc Ps Relief Request By letter dateo June 21, 1990, Public Service Electric and Gas Company (the-licensee) requested relief from code repair requirements of certain code Class 3 piping at Hope Creek.1 A pinhole leak was detected in-code Class 3 moderate energy service water system piping during plant operation and the licensee has determined that conformance with code repair requirements is impractical <

because the flaw was detected during plant operation and is in a section of Class 3 piping that can only be isolated for completing a code repair by- '

isolating the service water supply to the reactor auxiliaries cooling system heat exchanger. This action would force a plant shutdown despite the fact j that no safety related-heat loads are affected and no Technical Specification Limiting Condition for Operation applies. Pursuantto10CFR50.55a(g)(5)(iii),

the licensee submitted a relief request to the Comission. The subject piping is 30' inches in diameter, fabricated from ferritic steel and coated with epoxy.

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l By letters dated June 26,1990, July 2,1990, and July 3,1990, the licensee submitted additional information relating to the relief request. The licensee proposed a temporary non-code repair based on a non-welded repair as described in the July 2,1990 and July 3,1990 letters.

1 II. EVALUATION OF RELIEF RE00EST Code Requirement Article IWA-4000 of Section XI of the code specifies the code repair procedures.

Code Relief Request-Relief is requested from performing a code repair for the flaw detected during ,

plant _ operation in code Class'3 piping.

Basis for Relief Code repair requirements are impractical unless the. facility is shut down.

Proposed Alternative ,

L The licenset proposed to utilize the guidance in Generic Letter 90-05 to perform a temporary non-code repair, r

Staff Evaluation and Conclusions l

The staff has determined that code repair requirements'in this case are impractical, as defined in Generic Letter 90-05 since isolation of-the service water suppb to the reactor auxiliaries cooling system heat exchanger would force a-plant shutdown'despite the fact that no safety related heat loads are-t affected and no Technical Specification Limiting Condition for Operation l applies. Furthermore, the licensee has connitted to' the guidance provided in Generic Letter 90-05 which will- reasonably assure' structural integrity and f

protect public health and safety. Accordingly, the staff concludes that granting relief where code requirements are impractical and-imposing -

i alternative requirements are authorized by law and will not endanger life or '

property or the common defense and security and are otherwise in the public  :

L interest, given due consideration to the burden upon the licensee and facility  !

! that could result-if the code re l

Pursuant _to 10 CFR 50.55a(g)(6)(quirements were i) and consistent

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imposed with on-the in-the guidance facility. '

Generic Letter 90-05, relief is granted until the.next scheduled outage exceeding 30 days, but no later than the next scheduled refueling outage. ,

The temporary non-code repair must then be replaced with a code repair. i Dated: August 13, 1990 i

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