ML20079M028

Forwards Revised Pages to Inservice Insp Program,Attachment 1 to Class I Table & Notes 14,15 & 16 to Class II Table,Per EA Reeves 840120 Request.Encls Do Not Constitute Request for Addl Relief

ML20079M028
Person / Time
Site:	Farley
Issue date:	01/23/1984
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
TAC-49547, NUDOCS 8401270125
Download: ML20079M028 (10)

Text

Malling Address Alibima Power Comptny 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephona 205 783-6081 F. L Clayton, Jr.

Senior Vice President Fimtridge Buildirg AlabamaPower Docket No. 50-348 tre sou:svn ertmc wsrem January 23, 1984 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Vatga Joseph M. Farley Nuclear Plant - Unit 1 Clarification of ISI Program Relief Requests Gentlemen:

As requested by E. A. Reeves on January 20, 1984, Alabama Power Company herewith submits revised pages t.ir the Unit 1 ISI Program, Attachment I to the Class 1 Table and Notes 14,15 and 16 to the Class 2 Table. These pages were originally submitted to the NRC as a part of the relief requests sent by letter dated January 28, 1983.

For each of the requested reliefs listed above, no alternative examinations were proposed in the January 28, 1983 submittal. However, in each case, visual examinations of the designated portions of piping are actually performed during system leakage tests and/or hydrostatic tests.

, Fnr the purpose of clarification, the Alternative Examination descriptions for each relief have been revised to describe the extent of the examinations being conducted.

By letter dated December 12. 1979, NRC granted the relief requests submitted by Alabama Power Company on March 30, 1978. This approval included relief due to limitations to the examination of five portions of piping systems, including a portion of the Low and High Head Safety Injection Piping (these were listed in paragraph 3 of Attachment I to the Class 1 Table). The January 28, 1983 submittal revised item (iii) to include three valves which were inadvertently omitted from the original request. Items (vi), (vii) and (viii) were also omitted in the original request and were also added by the later submittal. The technical justification remains the name as the basis for the original relief granted in NRC's letter of December 12, 1979.

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Docket No. '50-348 Mr. S. A. Varga January 23, 1984 Page 2 The revised relief requests are submitted for the purpose of clarifying the reliefs submitted by letter dated January 28, 1983 and do not constitute a request for additional relief. If you have any questions or if additional clarification is required, please advise.

Yours truly,

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F. L. Clayton, J .

FLCjr/ STB:kc/D-324 Attachments cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford t

1.0 ASME CODE CLASS 1 1.1 -Attachment I to the Class 1 Table Revise the existing Seciton 3 Item as follows:

(iii) COMP,0NER CODE CLASS: 1 High llead Safety Injection to hot legs between check valves Q1E21V077A, B & C, 01E21V078A, B & C, Q1E21V079A, B & C and Low Head Safety Injection to check valves Q1E21V076A & B.

EXAMINATION REQUIREMENT:

Article IWB-5210 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that a system Icakage test be performed prior to startup following ecch reactor refueling outage.

BASIS FOR RELIEF:

Where portions of Class 1 systems are contained between two check valves or two normally closed valves and where pressure applied to the reactor coolant system will be retained at the first valve in the line, a system leakage test cannot be conducted.

A_LTERNATIVE EXAMINATI,0N_:

During performance of the RCS leakage test, the Low and High Head Safety Injection piping is pressurized up to check valves Q1E21V077A, B & C. The v.sual examination of the liigh Head Safety Injection piping is performed up to check valves Q1E21V078A, B & C and Q1E21V079A. B & C and includes the portions of piping between these valves and check valves Q1E21V077A, B & C. The visual examination of the Low Head Safety Injection piping is performed up to check valves Q1E21V076A & B, and includes the portions of Class 1 piping between these check valves and check valves Q1E21V077A, B & C. These same portions of piping are also visually examined during the Class I hydrostatic test.

1.1 Attachment I to the Class 1 Table Page 2 Add items to Section 3 as follows (vi) COMPONENT- CODE CLASS: 1 CVCS auxiliary spray to pressurizer pipine between check valve QlE21V109 and valve ole 21V245.

E_XAMIN_ATION REQUIREMENT:

Article IWB-5210 of Section XT. of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that a system leakage test be performed prior to startup following each reactor refueling outage.

BASIS FOR RELIEF:

Where portions of Class 1 systems are contained between two check valves or two normally closed valves and where pressure applied to the reactor coolant system will be retained at the first valve in the line, a system leakage test cannot be conducted.

ALTERNATIVE EXAMINATION:

During performance of the RCS leakage test, the CVCS auxiliary spray to pressurizer piping is pressurized up to check valve QlE21V109. The visuel examination of the CVCS auxiliary spray to pressurizer piping is visually examined up to valve Q1E21V245, and includes the portion of Class 1 piping between these two valves. This same portion of piping is also visually examined during the Class I hydrostatic test.

r' 1.1 Attachment I to the Class 1 Table Page 3 (vii) COMPONENT: CODE CLASS: 1 RCS normal charging piping between check valves Q1E21V110 and Q1E21V112.

EXAMINATION REQUIREMENT:

Article IWB-5210 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that a system leakage test be performed prior to startup following each reactor refueling outage.

BASIS FOR RELIEF:

Where portions of Class 1 systems are contained between

-two check valves or two normally closed valves and where pressure applied to the reactor coolant system will be retained at the first valve in the line, a system leakage test cannot be conducted.

ALTERNATIVE EXAMINATION:

During performance of the RCS leakage test, the RCS normal charging piping is pressurized up to check valve Q1E21V110. The visual examination of the normal charging piping is performed up to check valve Q1E21V112, and includes the portion of Class 1 piping between these two valves. This same portinn nf piping is also visually examined during the Class I hydrostatic test.

e 1.1 Attachment I to the Class 1 Table Page 4 (viii) COMPONENT: CODE CLASS: 1 RCS alternate charging piping between check valves Q1E21V111 and 01E21V113.

EXAMINATION REOUIREMENT:

Article IWB-5210 of Section XI of the 1974 Edition through the Summer 1975 Addenda of the ASME Code requires that a system leakage test be performed prior to startup following each reactor refueling outage.

BASIS FOR RELIEF:

Where portions of Class 1 systems are contained between two check valves or two normally closed valves and where pressure applied to the reactor coolant system will be retained at the first valve in the line, a system leakage test cannot be conducted.

ALTERNATIVE EXAMINATION:

During performance of the RCS leakage test, the RCS alternate charging piping is pressurized up to check valve 01E21V111. The vishal examination of the alterncte charging piping isl performed up to check valve Q1E21V113, and includes the pdytion of Class 1 piping between these NJwn val vea. This dame portion of piping is also visually examined during the Class I hydrostatic test.

2.2.2 Note 14 to the Class 2 Table COMPONENT: CODE CLASS: 2 Waste gas drain filter line to volume control tank between isolation valve Q1G22V249 and check valve Q1G22V248 (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 RELIEF:

Pressurization of this portion of the waste gas drain filter line would require check valve Q1G22V248 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:

The portion of Class 2 piping between valve Q1G22V249 and check valve Q1G22V248 will be visually examined during the Class 2 hydrostatic test.

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E 2.2.3 Note 15 to the Class 2-Table COMPONENT: CODE CLASS: 2

1. Charging pump suction piping from the boric acid filter between valves QlE21V212 and QlE21V264, and check valves QlE21V211 and QlE21V210, respectively (line no. HCB-16).

2. Charging pump suction piping from the chemical mixing tank between valve QlE21V186 and check val <e QlE21V187 (line no. HCB-11).

3. Hydrogen and nitrogen supply piping to the volume control tank from check valve QlE21V201 to isolation valves QlE21V202, QlE21V583 and Q1G22V260 (line no.

HCB-68).

EXAGINATION REQUIREMENT:

Article IWC-2510 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 valves.

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n-2.2.3 Note 15 to the Class 2 Table Page 2-

.ATIfERNATIVE EXAMINATION:

1.. For the charging pump saction piping from the boric acid filter, the portions of Class 2 piping between valves Q1E21V212 and Q1E21V264 and check valves Q1E21V211 and Q1E21V210 will be visually examined during the Class 2 hydrostatic test.

2. For the charging pump suction piping from the chemical mixing tank. the portion of. Class 2 piping between valve Q1E21V186 and check valve Q1E21V187 will be visually examined during the Class 2 hydrostatic test.

3. For the-hydrogen and nitrogen supply piping to the volume control tank, the portions of Class 2 piping between check valve Q1E21V201 and isolation valves

, Q1E21V202, Q1E21V583 and Q1G22V260 will be visually examined during the Class 2 hydrostatic test.

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g 2.2.4 Note 16 to the Class 2 Table CODE CLAS1: 2 C_0MPONENT Reactor vessel flange seal leakoff line from the reactor vessel to valves Q1B13V019 and Q1B13V018 (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:

Performance of a hydrostatic test for this system is impractical because pressurization of the flange seal leakoff line could potentially result in damage to the reactor vessel flange seals.

ALTERNATIVE EXAMINATION:

For the reactor vessel flange seal leakoff line from the reactor vessel, the portion of Class 2 piping between valves Q1B13V019 and Q1B13V018 will be visually examined during the Class I hydrostatic test.

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