ML20058N831
| ML20058N831 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/13/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058N830 | List: |
| References | |
| NUDOCS 9008150152 | |
| Download: ML20058N831 (2) | |
Text
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%.....)j W A %W NG TON. D. C. 20555 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-i 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 mode of the plant when the flaw is detected. Those repairs not in compliance j
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 that no safety related-heat loads are affected and no Technical Specification j
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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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.
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-affected and no Technical Specification Limiting Condition for Operation t
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 Pursuant _to 10 CFR 50.55a(g)(6)(quirements were imposed on-the facility.
l i) and consistent with the guidance in-
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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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