ML20070S786
| ML20070S786 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/28/1983 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20070S788 | List: |
| References | |
| TAC-51033, TAC-51062, NUDOCS 8302080012 | |
| Download: ML20070S786 (30) | |
Text
l' Malling Address .-.
Alf b:ma Power Company 600 North 18th Street Post Offica Box 2641 Birmingham, Alabama 35291
, Telephone 205 783-6081 F. L Clayton, Jr.
$"%$'70lT4*"' AlabamaPower the southem electrc system J anua ry 28, 1983 Docket No. 50-364 I l
l Director, Nuclear Reactor Regulation ,
U. S. Nuclear Regulatory Commission '
Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 2 Inservice Inspection Program for ASME l Code Class 1, 2 and 3 Components Gentlemen:
On July 25, 1980, Alabama Power Company submitted Revision 0 of the subject program which included requests for relief from certain ASME Code requirements. Since implementation of this program, Alabama Power Company has determined that certain other ASME Code requirements are impractical. Therefore, it is necessary to request additional relief from other ASME Codes requirements.
In accordance with 10 CFR 50.55 a(g)(6)(i), Alabama Power Company hereby requests that relief be granted from certain requirements of the 1974 Edition through the Summer 1975 Addenda of the ASME Code,Section XI, Articles IWA-5000, IWB-5000, IWC-5000, IWD-5000, IWC-2000 and IWD-2000. A summary of the proposed relief request changes and additions is provided in Attachment 1. A complete description of the affected components, existing examination requirements, bases of request for relief and proposed alternative examinations are provided in Attachment 2.
Alabama Power Company's Plant Operations Review Committee has reviewed the proposed relief request changes and additions. It is respectfully requested that these relief requests be granted by September 1,1983 since the Inservice Inspection (ISI) activities currently include some of these impractical inspections that are required to be performed during the next Unit 2 refueling outage scheduled for October 1983.
B302080012 830128 i PDR ADOCK 05000364 PDR '
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- Mr. S. A. Varga January 28, 1983 Director, Nuclear Reactor Regulation Page 2 This request for relief is designated as Class III in accordance with 10 CFR 170.22 requirements. Enclosed is a check for $4000.00 to cover the total amount of fees required.
Yours very truly ,
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F. L. Cl ayton , J r.
F LCJ r/ STB :1 s h-D13 /
Att ac hment s cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford
ATTACHMENT 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS Alabama Power Company proposes that the following revisions and additions and the existing relief requests contained in the Unit 2 Inservice Inspection Program for ASME Code Class 1, 2 and 3 Components, Revision 0 be granted. Upon NRC approval, these additional reliefs will be incorporated into the existing program as Revision 1,
1.0 INTRODUCTION
1.1 1.8.1 Ultrasonic Revise paragraph 1.8.1 to delete references to unapproved editions and addenda of the ASME Code. Later NRC approved editions and addenda are referenced as a guide in performing ultrasonic examinations of piping systems less than 2-1/2 inches in wall thickness and for the design of calibration blocks.
2.0 ASME CODE CLASS 1 2.1 2.2 System Leakage and Hydrostatic Pressure Test Revise paragraph 2.2 to state that hydrostatic testing shall be performed in accordance with IWB-5000 of the 1974 Edition through the Summer 1975 Addenda of the ASME Code,Section XI except as identified in Relief Requests 2.3.12 and 2.3.15.
The following items were added to the existing paragraph 2.2:
2.2.5 Add the CVCS auxiliary spray to pressurizer piping between check valve Q2E21V109 and valve Q2E21V245 to the existing relief request. This line will not be examined as part of the RCS pressure test.
2.2.6 Add the RCS normal charging piping between check valve Q2E21V110 and valve Q2E21V112 to the existing relief request. This line will not be examined as a part of the RCS pressure test.
2.2.7 Add the RCS alternate charging piping between check valves Q2E21V111 and Q2E21V113 to the existing relief request. This line will not be examined as part of the RCS pressure test.
2.2.0 Add the excess letdown line between valves Q2E21V246 and Q2E21V247 to the existing relief
( request. This line will not be examined as a part of the RCS pressure test.
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!~"- ATTACHMENT 1 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS
] PAGE 2 2.2 Relief Requests 2.2.1 2.3.12 Relief Request Add the 2.3.12 Relief Request to request relief .from performing a Class 1 hydrostatic test of the RCP seal injection piping from the RCP flanges to valve Q2E21V100A, B & C and the RCPLNo. I seal bypass piping from the RCP flanges to flow orifices Q2E21F06001A, B
& C and valves Q2E21V106A, B & C. This Class 1 piping cannot be isolated from the adjoining Class 2 piping due to flow orifices at the Code Class change points.
These-lines will be tested in accordance with Class 2 requirements.
i 2.2.2 2.3.14 Relief Request
! Add the 2.3.14 Relief Request to request relief-from performing a surface examination of socket weld no. 9 i located in the safety injection system between valves Q2E21V077C and Q2E21V079C. This weld. is inaccessible for a surface examination due to a seismic support at this location. This portion of the safety injection i system, including weld no. 9, will be subjected to the j hydrostatic testing requirements as discussed in j paragraph 2.2 of the ISI Program.
2.2.3 2.3.15 Relief Request Add the 2.3.15 Relief Request to request relief from i
t the four hour holding time required prior to performance of visual examinations for hydrostatic tests of noninsulated piping. Later NRC approved editions and addenda of the ASME Code,Section XI require only a ten minute holding time. Test pressures and temperatures will be maintained for a minimum of ten minutes prior to initiating the visual examination and will be maintained until completion of j the examination.
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ATTACHMENT 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS PAGE 3 3.0 ASME CODE CLASS 2 1
3.1 3.3.1 Hydrostatic Testing Revise paragraph 3.3.1 by deleting in its entirety the existing paragraph 3.3.1 and replacing it with the revised paragraph 3.3.1. The revised paragraph eliminates specific relief requests which were
- reformatted and referenced as relief requests 3.4.12, 3.4.13, 3.4.14, 3.4.15, 3.4.16, 3.4.17, 3.4.18 and 3.4.14, 3.3.2.2 Hydrostatic Testing Revise paragraph 3.3.2.2 by adding the boron meter discharge line to Volume Control Tank from valve
! Q2E21V243 to the connection with line no. HCB-92.
1 3.2 Relief Requests i
3.2.1 3.4.12 Relief Request Add the 3.4.12 Relief Request to request relief from the performance of a hydrostatic test on the reactor vessel flange seal leakoff line from the reactor vessel to valves Q2B13V019 and Q2B13V018. Pressurization _of the flange seal leakoff line could potentially result i n damage to the reactor vessel flange seals; therefore, these lines will not be subjected to an alternative
- examination.
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ATTACHMENT 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS PAGE 4 3.2.2 3.4.13 Relief Request Add the 3.4.12 Relief Request to request relief from the performance of a hydrostatic test on the vents, drains, instrumentation lines and branch connections off of Class I lines; pressurizer spray valves bypass lines; sample lines of RCS loops and pressurizer; boron injection tank discharge to RCS (cold legs) between valves Q2E21V004A & B, Q2E21V029 and Q2E21V062A, B & C; high head safety injection pumps discharge lines to RCS (cold legs) between valves Q2E21V063 and Q2E21V066A, B &
C; high head safety injection pump discharge lines to RCS (hot legs) between valves Q2E21V068 and Q2E21V078A, B & C, Q2E21V072 and Q2E21V079A, B & C; branch lines connecting the accumulator discharge lines to the accumulator test line; residual heat removal pump discharge to RCS (hot legs) between valves Q2E21V044 and Q2E21V076A & B, residual heat removal to RCS (cold legs) between valves Q2E21V023A & B and Q2E21V021A, B & C; alternate charging line between valves Q2E21V243 and Q2E21V113; normal charging line between valves Q2E21V244 and Q2E21V112; normal charging line control valve bypass line between valves Q2E21V143 and Q2E21V112; RPV head vent line between the Class I line and valves HV-1 and HV-3; and RCP seal no. I leakoff lines from RCP's to check valves Q2E21V623A, B & C. The fourteen portions of systems listed above cannot be isolated from or can only be pressurized through the Class 1 systems. Visual examination for evidence of leakage will be conducted on these portions of systems in conjunctinn with the hydrot catic test performed on the adjoining Class 1 system.
3.2.3 3.4.14 Relief Request Add the 3.4.14 Relief Request to request relief from the performance of hydrostatic tests on the charging pump suction piping from the boric acid filter between valves Q2E21V212 and Q2E21V264 and check valves Q2E21V211 and Q2E21V210, respectively, the charging pump suction piping f rom the chemical mixing tank between valve Q2E21V186 and check valve Q2E21V187, and the hydrogen and nitrogen supply piping to the volume control tank from check valve Q2E21V201 to isolation valves Q2E21V202 and Q2E21V203. Pressurization of these portions of system piping cannot be assured due to check valves
ATTACHMENT 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS PAGE 5 which prevent flow from the test fill point to the specified boundary valves. These portions of piping will not be subjected to an alternative examination.
3.2.4 3.4.15 Relief Request Add the 3.4.15 Relief Request to request relief from the performance of a hydrostatic test on the waste gas drain filter line to the volume control tank between isolation valve Q2G22V249 and check valve Q2G22V248.
Performance of a hydrostatic test on this line could potentially result in overpressurization and subsequent damage of the waste gas filter; therefore, no alternative examination will be performed.
3.2.5 3.4.16 Relief Request Add the 3.4.16 Relief Request to request relief from the 100*F minimum temperature requirements for the hydrostatic pressure test of Class 2 components. It is impractical and very difficult to heat the extensive water filled systems, especially during cold weather months. Later NRC approved editions and addenda of the ASME Code,Section XI remove the limit for austenitic stainless steel components and allow the use of fracture prevention criteria specified or owner specified temperatures for ferritic steel components. The Class 2 test will be conducted in accordance with the requirements of the later NRC approved code.
3.2.6 3.4.17 Relief Request Add the 3.4.17 Relief Request to requast relief from the required hydrostatic test pressure of 1.25 P -d This requirement places undue stress on components of the Class 2 systems. Adequate levels of plant safety are assured by performing hydrostatic tests at the pressures specified in later NRC approved editions and addenda of the ASME Code. The Class 2 hydrostatic tests will be conducted at, as a minimun, 1.10 Psv where design temperature is 200 F or less and 1.25 Psv i
where design' temperature is greater than 200 F, as specified in the later NRC approved ASME Code.
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ATTACHMENT 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS PAGE 6 3.2.7 3.4.18 Relief Request Add the 3.4.18 Relief Request to request relief from the four hour holding time required prior to performance of visual examinations for hydrostatic tests of noninsulated piping. Later NRC approved editions and addenda of the ASME Code,Section XI, require only a ten minute holding time. Test pressuras and temperatures will be maintained for a minimum of ten minutes prior to initiating the visual examination and will be maintained until completion of the examination.
3.2.8 3.4.19 Relief Request Add the 3.4.19 Relief Request to request relief frcm the performance of a Class 2 hydrostatic test on the boron injection recirculation pump discharge piping between valves Q2E21V005A, B & C and check valves Q2E21V006A & B and the adjoining drain piping.
Performance of a hydrostatic test on the portion of the system described above requires the use of check valves as a hydrostatic test boundary. Leakage past these valves could potentially pressurize and overstress the adjoining Class 3 piping. These lines will be visually examined during operation as a part of the adjoining Class 3 system examination.
4.0 ASME CODE CLASS 3 4.1 4.1 System Pressure Test Add paragraph 4.1 which states that the system pressure tests shall be performed in accordance with IWD-5000 of the 1974 Edition through Summer 1975 Addenda of the ASME Code,Section XI except as identified in Relief Requests 4.2.12 and 4.2.13. Exception is taken to the performance of system pressure testing on those portions of Class 3 systems identified in Relief Requests 4.2.1 through 4.2.11 and 4.2.14.
. - ATTACHMENT 1
SUMMARY
OF PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS PAGE 7 4.2 Relief Requests 4.2.1 4.2.12 Relief Request Add the 4.2.12 Relief Request to request relief from the required hydrostatic test pressure of 1.10 P d-This requirement places undue stress on components of the Class 3 system. Adequate levels of plant safety are assured by performing hydrostatic tests at the pressures specified in later NRC approved editions and addenda of the ASME Code. The Class 3 hydrostatic tests will be conducted at, as a minimum,1.10 Psv where design temperature is 200 F or less and 1.25 Psy where design temperature is greater than 200 F, as specified in the later NRC approved ASME Code.
S.2.2 4.2.13 Relief Request Add the 4.2.13 Relief Request to request relief from the four hour holding time required prior to performance of visual examinations for hydrostatic tests of noninsulated piping. Later NRC approved editions and addenda of the ASME Code,Section XI require only a ten-minute holding time. Test pressures and temperatures will be maintained for a minimum of ten minutes prior to initiating the visual examination and will be maintained until completion of the examination.
4.2.3 4.2.14 Relief Request Add the 4.2.14 Relief Request to request relief from the performance of a hydrostatic test on the auxiliary feedwater pump minimum flow piping between flow orifices Q2N23F03214A & B and Q2N23F03219 and valves Q2N23FV010 and Q2N23V019A & B. The Class 3 portions of these lines cannot be isolated from adjoining non-code piping; therefore, performance of a hydrostatic test on these lines would overpressurize the lower pressure, non-code piping downstream of the i flow orifices. These lines will receive a visual
! examination during normal operation at system operating temperature and pressure.
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ATTACHMENT 2 PROPOSED RELIEF REQUEST CHANGES AND ADDITIONS
1.0 INTRODUCTION
Revise Paragraph 1.8.1 as shown:
1.1 1.8.1 Ultrasonic Ultrasonic examinations will be conducted in accordance with the provisions of Appendix I of Section XI and Article 5 of Section V as required by IWA-2232.
In lieu of using Article 5 of Section V, Appendix III of the 1977 Edition through the Summer 1978 Addenda of the ASME Code,Section XI will be used as a guide for ultrasonic examination of piping systems less than 21/2 inches in wall thickness. The alternative ' calibration block design described in Appendix III requires ultrasonic reflectors to be machined notches instead of side-drilled holes.
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2.0 ASME CODE CLASS 1 Revise Paragraph 2.2 as shown:
2.1 2.2 System Leakage and Hydrostatic Pressure Test Hydrostatic testing shall be performed in accordance with IWB-5000 of the 1974 Edition through the Summer 1975 Addenda of the ASME Code,Section XI except as identified in Relief Requests 2.3.12 and 2.3.15.
Requirements for the visual examination of Class 1 systems and components for evidence of leakage during the performance of the system leakage test following each reactor refueling are identified in IWB-5200. Exception is taken to the implementation of these requirements on those portion of Class 1 systems which are contained between two check valves or two normally closed valves where pressure applied to the reactor coolant system will be retained at the first valve in the line. The portions of systems affected by this limitation are as follows:
2.2.1 Accumulator discharge lines between check valves Q2E21V032A, B & C and Q2E21V037A, B & C.
2.2.2 Low head cold leg injection between check valves Q2E11V051A, B & C and Q2E11V021A, B & C, high head injection lines to check valves Q2E21V066A, B & C and boron injection lines to check valves Q2E21V062A, B & C.
2.2.3 High head safety injection to hot legs between check valves Q2E21V077A, B & C, Q2221V078A, B & C and Q2E21V079A, B & C and low head SIS to check valves' Q2E21V076A & B.
2.2.4 RHR take-off lines between Q2E11V001A & B and Q2E11V016A & B.
2.2.5 CVCS auxiliary spray to pressurizer piping between check valve Q2E21V109 and valve Q2E21V245.
2.2.6 RLS normal charging piping between check valves Q2E21V110 and Q2E21V112.
2.2.7 RCS alternate charging piping between check valves Q2E21V111 and Q 2E21V113.
2.2.8 Excess letdown line between valves Q2E21V246 and Q2E21V247.
2.2 Relief Requests Delete previous Relief Request 2.3.12.
2.2.1 2.3.12 Relief Request COMPONENT: CODE CLASS: 1
- 2. RCP No. I seal bypass piping from RCP flanges to flow orifices Q2E21F06001A, B & C and Q2E21V106A, B & C (line no. CCA-32A, B & C).
EXAMINATION REQUIREMENT:
Article IWB-5222 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that the test temperature of Class 1 systems not be less than 100 F.
BASIS FOR RELIEF:
It is impractical to isolate the Class 1 portions of the piping listed from the Class 2 portions of these lines due to flow orifices at the Code Class change pcint. This piping is constructed of austenitic stainless steel which demonstrates minimal ductile-brittle transition characteristics; therefore, testing these lines at reduced temperatures will not adversely af fect the fracture toughness of the piping.
ALTERNATIVE EXAMINATION:
These lines will be hydrostatically tested and visually examined as a part of the adjoining Class 2 piping and in accordance with the Class 2 requirements at ambient temperatures, since nil-ductility requirements do not apply. (Reference Note 13 to the Class 2 Table and Article IWC-5230(c) of the ASME Code,1980 Edition through Winter 1980 Addenda.) Since the Class 2 test pressure exceeds the Class 1 test pressure, the Class 1 pressure requirements will be met.
2.2.2 2.3.14 Relief Request COMPONENT:
CODE CLASS: 1 i
i Piping Pressure Boundary EXAMINATION REQUIREMENT:
Tables IWB-2500 Category B-J and IWB-2600 Item B4.8 require surface examination of socket welds.
BASIS FOR RELIEF:
Weld no. 9, which is a two inch socket weld located in the safety injection system between valves Q2E21V077C and Q2E21V079C, is inaccessible for a surface examination due to a seismic support at this location.
ALTERNATIVE EXAMINATION:
I This portion of the safety injection system, including weld no. 9, will be subjected to the hydrostatic testing requirements as described in paragraph 2.2.
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2.2.3 2.3.15 Relief Request COMPONENT: CODE CLASS: 1 ASME Code Class 1 noninsulated systems or components.
EXAMINATION REQUIREMENTS:
IWA-5210, of the ASME Code,Section XI,1974 Edition through the Summer 1975 Addenda requires that the hydrostatic test temperature and pressure be maintained for at least four hours prior to the performance of the required visual examination.
BASIS FOR RELIEF:
This requirement is an unjustified hardship due to a potential extension of outage time for required delays prior to performance of examinations.
These delays potentially increase the radiation exposure of test pe rsonnel . Examination of noninsulated piping can be adequately performed with a high level of assurance, in accordance with the later NRC approved 1977 Edition through Summer 1978 Addenda of the ASME Code,Section XI, Article IWA-5213 which requires:
"The holding time after pressurization to test conditions, before the visual examinations commence, shall be as follows:
...(d) system hydrostatic tests - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after attaining the test pressure and temperature conditions for insulated systems, and 10 minutes for noninsulated systems or components."
ALTERNATIVE EXAMINATION:
The hydrostatic test pressures and temperatures will be maintained as f oll ow s:
Test Temperature Test Pressure 100 F 1.10 P o 200 F 1.08 P o 300 F 1.06 Po 400 F 1.04 Po 500 F 1.02 Po After a minimum holding time of 10 minutes, a visual examination will be performed. The required pressure and temperature will be maintained for the duration of the visual examination for a period of time suf ficient to complete the visual examination of all portions of system components which are being subjected to the hydrostatic test.
3.0 ASME CODE CLASS 2 3.1 Revise Paragraph 3.3.1 as shown:
Code Class: 2 Hydrostatic testing shall be performe; in accordance with IWC-5000 of the 1974 Edition through Summer 1975 Ad:enda of the ASME Code,Section XI except as identified in Relief Requests 3.4.16, 3.4.17, and 3.4.18.
Exception is taken to the performance of hydrostatic testing on those portions of Class 2 systems identified in Relief Requests 3.4.12, 3.4.13, 3.4.14, 3.4.15 and 3.4.19.
Add the following item to Paragraph 3.3.2.2 as follows:
Boron meter discharge line (line no. GCB-23) to Volume Control Tank from valve Q2E21V243 to the connection with line no. HCB-92.
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3.2 Relief Requests 3.2.1 3.4.12 Relief Request
-1 COMP 0NENT: CODE CLASS: 2 Reactor vessel flange seal leakoff line from the reactor vessel to valves Q2813V019 and Q2813V018 (line no. CCB-36) .
EXAMINATION REQUIREMENT,:
Article IWC-2510 of Section XI of the ASME Code 1974 Edition through the Summer 1975 Addenda requires that hydrostatic tests be performed on all Class 2 components.
BASIS FOR RELIEF:
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Performance of a hydrostatic test for this system is impractical because pressurization of the flange seal leakof f line could potentially result in damage to the reactor vessel flange seals.
ALTERNATIVE EXAMIATION:
No alternative inspection is proposed.
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3.2.2 3.4.13 Relief Request COMP 0NENT: CODE CLASS: 2
- 1. Vents, drains, instrumentation lines, and branch connections of f of Class 1 lines (line nos. CCB-27, 33, 34, 38, 39, 40, 41, 42, 43, 44, 48A, B and C)
- 2. Pressurizer spray valves bypass lines (line no. CCB-57)
- 3. Sample lines off RCS loops and pressurizer (line nos. CCB-37, 54, 55 and 56)
- 4. Boron injection tank discharge to RCS (cold legs) between valves Q2E21V004A & B, Q2E21V029, and Q2E21V062A, B & C (line no. CCB-21)
- 5. High head safety injection pumps discharge lines to RCS (cold legs) between valves Q2F21V063 and Q2E21V066A, B & C (line no. CCB-22)
- 6. High head safety injection pump discharge lines to RCS (hot legs) between valves Q2E21V068 and Q2E21V078A, B & C; Q2E21V072 and Q2E21V079A, B & C (line nos. CCB-30 and 31)
- 7. Branch lines connecting the accumulator discharge lines to the accumulator test line (line nos. CCB-24, 53 and 54)
- 8. Residual heat removal pump discharge lines to RCS (hot legs) between valves Q2E21V044 and Q2E21V076A & B (line no. CCB-29)
- 9. Residual heat removal to RCS (cold legs) between valves Q2E21V023A & B and Q2E21V021A, B & C (line nos. CCB-32 and 22)
- 10. Alternate charging line between valves Q2E21V243 and Q2E21V113 (line no. CCB-9)
- 11. Normal charging line between valves Q2E21V244 and Q2E21V112 (line no.
CCB-10)
- 12. Normal charging line control valve bypass line between valves Q2E21V143 and Q2E21V112 (line no. CCB-45)
- 13. RPV head vent line between Class I line and valves HV-1 and HV-3 (line no. CCB-63)
- 14. No. I leakoff lines from RCP's to check valves Q2E21V623A, B & C (line nos. CCB-48A, B & C)
EXAMINATION REQUIREMENT:
Article IWC-2510 of Section XI of the ASME Code requires that a hydrostatic test be performed on all Class 2 components.
BASIS FOR RELIEF:
The fourteen portions of systems listed above cannot be isolated from or can only be pressurized through the Class 1 systems.
ALTERNATIVE EXAMINATION:
Visual examination for evidence of leakage will be conducted on these portions of systems in conjunction with the hydrostatic test performed on the adjoining Class 1 system.
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3.2.3 3.4.14 Relief Request COMPONENT: CODE CLASS: 2
- 1. Charging pump suction piping from the boric acid filter between valles Q2E21V212 and Q2E21V264, and check valves Q2E21V211 and Q2E21V210, respectively (line no. HCB-16).
- 2. Charging pump suction piping from the chemical mixing tank between valve Q2E21V186 and check valve Q2E21V187 (line no. HCB-11).
- 3. Hydrogen and nitrogen supply piping to the volume control tank from check valve Q2E21V201 to isolation valves Q2E21V202 and Q2E21V203 (line no. HCB-68).
EXAMINATION REQUIREMENT:
Article IWC-i310 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that hydrostatic tests be performed on all Class 2 components.
BASIS FOR RELIEF:
Pressurization of the portions of system piping listed above cannot be assured due to system design. The check valves listed prevent flow from the test fill point to the specified boundary talves.
ALTERNATIVE EXAMINATION:
No alternative inspection is proposed for the Class 2 piping between the valves and check valves listed above.
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3.2.4 3.4.15 Relief Request COMPONENT: CODE CLASS: 2 Waste gas drain filter line to volume control tank between isolation valve Q2G22V249 and check valve Q2G22V248 (line no. HCB-92).
EXAMINATION REQUIREMENT:
Article IWC-2510 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that a hydrostatic test be performed on all Class 2 components.
BASIS FOR Rt 'EF:
Pressurization of this portion of the waste gas drain filter line would require check valve Q2G22V248 to hold the hydrostatic test pressure.
Leakage through this valve could potentially result in overpressurization and subsequent damage of the waste gas filter.
ALTERNATIVE EXAMINATION:
No alternative examination is proposed for the Class 2 piping between valve Q2G22V249 and check valve Q2G22V248.
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' '. 3.2.5 3.4.16 Relief Request COMPONENT: CODE CLASS: 2 ASME Class 2 Piping and Components EXAMINATION REQUIREMENT:
IWC-5220 of the 1974 Edition through the Summer 1975 Addenda of the ASME Code Section XI, requires that a hyd"ostatic pressure test of Class 2 systems be conducted at a temperatura not less than 100 F.
BASIS FOR RELIEF:
It is impractical for Alabama Power Company to meet the 100*F temperature requirement for the majority of the hydrostatic tests. Heating the extensive water filled piping systems to this temperature is an undue hardship, especially during the cold weather months when most outages are scheduled. Adequate levels of plant safety are assured by the application of the later NRC approved 1977 Edition through the Summer 1978 Addenda of Section XI of the ASME Code Article IWC-5230 which states:
"a) The system test temperature during a system hydrostatic test in systems containing ferritic steel components shall meet the requirements specified by fracture prevention criteria.
b) In systems containing ferritic steel components for which fracture toughness requirements were neither specified nor required in construction of the components, the system test temperature shall be determined by the owner.
c) No limit on system test temperature is required for systems constructed entirely of austenitic steel materials."
! The conditions described in paragraph (a) above are applicable only to the Class 2 portions of the Main Steam and Feedwater Systems.
The conditions described in paragraph (b) above are applicable to the remainder of the ferritic steel Class 2 piping other than Main Steam and Feedwater piping.
The conditions described in paragraph (c) above are applicable to the remainder of the Class 2 systems.
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3.2.5 3.4.16
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Relief Request (continued)
ALTERNATIVE EXAMINATION a) The Main Steam and Feedwater Systems shall be tested at temperatures which meet requirements specified by fracture prevention criteria.
b) In systems which contain ferritic steel components. for which no fracture prevention criteria can be found, hydrostatic tests will be conducted at a test temperature of 60 F or greater.
c) Systems constructed entirely of austenitic steels will be hydrostatically tested at ambient temperatures, since no limit is required.
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3.2.6 3.4.17 Relief Request COMPONENT: CODE CLASS: 2 ASME Code Class 2 components EXAMINATION REQUIREMENTS:
IWC-5220, of the ASME Code,Section XI, 1974 Edition through Summer 1975 Addenda requires that the hydrostatic test pressure for Class 2 components be at least 1.25 times the design pressure (P d).
BASIS FOR RELIEF:
This hydrostatic test requirement places undue stress on components of Class 2 systems. Adequate levels of plant safety can be assured by the application of the later NRC approved 1980 Edition through Winter 1980 Addenda of the ASME Code,Section XI, Article IWC-5222, which states that Class 2 components shall be hydrostatically tested at a pressure of "at least 1.10 times system pressure Psv for systems with Design Temperatures of 200 F or less and at least 1.25 times Psv for systems with Design Temperatures above 200"F," where Psv is "the lowest setting among the number of safety or relief valves provided for overpressure protection within the bounda ry of the system to be tested."
ALTERNATIVE EXAMINATION:
The hydrostatic test pressure for Class 2 components shall be at least 1.10 times Psv for systems with Design Temperatures of 200"F or less and at least 1.25 times Psv for systems with Design Temperatures above 200 F.
'. 3.2.7 3.4.18 Relief Request COMPONENT: CODE CLASS: 2 ASME Code Class 2 noninsulated systems or components EXAMINATION REQUIREMENTS:
IWA-5210, of the ASME Code,Section XI 1974 Edition with Addenda through Summer of 1975 Addenda requires that the hydrostatic test temperature and pressure must be maintained for at least four hours prior to the performance of the required visual examination associated with the system hydrostatic tests.
BASIS FOR RELIEF:
This requirement is an unjustified hardship due to a potential extension of outage time for required delays prior to performance of examinations.
These delays potentially increase the radiation exposure of test pe rsonnel . Examination of noninsulated piping can be adequately performed with a high level of assurance, in accordance with the later NRC approved 1977 Edition through Summer 1978 Addenda of the ASME Code,Section XI, Article IWA-5213 which requi res :
"The holding time after pressurization to test conditions, before the visual examinations commence, shall be as follows: ...(d) system hydrostatic tests - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after attaining the test pressure and temperature conditions for insulated systems, and 10 minutes for noninsulated systems or components."
ALTERNATIVE EXAMINATION:
a) The Main Steam and Feedwater Systems shall be tested at temperatures which meet requirements specified by fracture prevention criteria.
b) In systems which contain ferritic steel components for which no fracture prevention criteria can be found, hydrostatic tests will be conducted at a test temperature of 60 F or greater.
c) Systems constructed entirely of austenitic steels will be hydrostatically tested at ambient temperatures, since no limit is required,
- 3.2.7 3.4.18 Relief Request (continued)
After the hydrostatic test pressure and temperature have been maintained for a minimum time of 10 minutes, a visual examination will be performed.
The required pressure and temperature will be maintained for the' duration of-the visual examination of all portions of system components which are being subjected to the hydrostatic test.
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. 3.2.8 3.4.19 Relief Request COMPONENT: CODE CLASS: 2 Boron injection recirculation pump -discharge piping between valves Q2E21V005A & B and check valves Q2E21V006A & B and the adjoining drain piping (line no. CCB-62).
EXAMINATION REQUIREMENT:
2 Article IWC-2510 of Section XI of the ASME Code 1974 Edition through the i Summer 1975 Addenda requires that hydrostatic tests be performed on all Class 2 components.
i BASIS FOR RELIEF:
Performance of a hydrostatic test on the portion of the system described above requires the use of check valves which are subject to leakage when used as a hydrostatic test boundary. Leakage past these valves could potentially pressurize and overstress the adjoining Class 3 piping.
ALTERNATIVE EXAMINATION:
These lines will be visually examined during operation as a part of the adjoining Class 3 system in accordance with IWD-2410(c).
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4.0 ASME CODE CLASS 3 4.1 Add paragraph 4.1 as shown Note: Relief requests 4.2.1 through 4.2.11 were previously submitted as relief requests 4.1.1 through 4.1.11 and thus are not included in this submittal. Additional relief requests 4.2.12, 4.2.13 and 4.2.14 are included in this submittal.
4.1 System Pressure Test CODE CLASS: 3 System pressure tests shall be performed in accordance with IWD-5000 of the 1974 Edition through Summer 1975 Addenda of the ASME Code,Section XI except as identified in Relief Requests 4.2.12 and 4.2.13. Exception is taken to the performance of system pressure testing on those portions of Class 3 systems identifed in Relief Requests 4.2.1, 4.2.2, 4.2.3, 4.2.4, 4.2.5, 4.2.6, 4.2.7, 4.2.8, 4.2.9, 4.2.10, 4.2.11 and 4.2.14.
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. 4.2 Relief Requests 4.2.1 4.2.12 Relief Request COMP 0NENT: CODE CLASS: 3 ASME Code Class 3 components EXAMINATION REQUIREMENTS:
IWD-5200 of the ASME Code,Section XI 1974 Edition through Summer 1975 Addenda requires that the hydrostatic test pressure for Class 3 components be at least 1.10 times the design pressure (P d ).
BASIS FOR RELIEF:
This requirement places undue stress on components of Class 3 systems.
Adequate levels of plant safety can be assured by the application of the later NRC approved 1980 Edition through Winter 1980 Addenda of the ASME Code,Section XI, Article IWD-5223 which states that Class 3 components shall be hydrostatically tested at a pressure of "at least 1.10 times system pressure (Psv) for systems with Design Temperatures of 200 F or less and at least 1.25 times Psv for systems with Design Temperatures above 200 F," where Psv is "the lowest setting among the number of safety or relief valves provided for overpressure protection within the boundary of the system to be tested."
ALTERNATIVE EXAMINATION:
The hydrostatic test pressure for Class 3 components shall be at least 1.10 times Psv for systems with Design Temperatures of 200 F or less and at least 1.25 times Psv for systems with Design Temperatures above 200'F.
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.' 4.2.2 4.2.13 Relief Request COMP 0NENT: CODE CLASS: 3 ASME Code Class 3 noninsulated systems or components EXAMINATION REQUIREMENTS:
IWA-5210, of the ASME Code,Section XI 1974 Edition with Addenda through Summer of 1975 Addenda requires that the hydrostatic test temperature and pressure must be maintained for at least four hours prior to the performance of the required visual examination associated with the system hydrostatic tests.
BASIS FOR RELIEF:
This requirement is an unjustified hardship due to a potential extension of outage time for required delays prior to performance of examinations.
These delays potentially increase the radiation exposure of test personnel. Examination of noninsulated piping can be adequately performed with a high level of assurance, in accordance with the later NRC approved 1977 Edition through Summer 1978 Addenda of the ASME Code,Section XI, Article IWA-5213 which requi res :
"The holding time after pressurization to test conditions, before the visual examinations commence, shall be as follows: ...(d) system hydrostatic tests - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after attaining the test pressure and temperature conditions for insulated systems, and 10 minutes for noninsulated systems or components."
ALTERNATIVE EXAMINATION:
After the hydrostatic test pressure (normal operating pressure) and temperature (normal operating temperature) have been maintained for a minimum time of 10 minutes, a visual examination will be performed. The required pressure and temperature will be maintained for the duration of the visual examination for a period of time sufficient to complete the visual examination of all portions of system components which are being subjected to the hydrostatic test.
a 4.2.3 4.2.14 Relief Request COMPONENT: CODE CLASS: 3 Auxiliary feedwater pump minimum flow piping between flow orifices Q2N23F03214A & B and Q2N23F03219 and valves Q2N23V019A & B, and Q2N23FV010.
EXAMINATION REQUIREMENT:
Article IWD-2410 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that hydrostatic tests be performed on Class 3 components.
BASIS FOR RELIEF:
Performance of a hydrostatic test on the portions of the piping system listed above could overpressurize the lower pressure, non-code piping downstream of these flow orifices.
ALTERNATIVE EXAMINATION:
These lines will receive a visual examination during normal operation at system operating temperature and pressure.
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