ML20086H824
| ML20086H824 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/02/1991 |
| From: | Woodard J ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M71578, NUDOCS 9112090432 | |
| Download: ML20086H824 (8) | |
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- IN7i, Ibecher 2,1991 t r... n er Docket No. 50-364 U. S. Nuclear Regulatory Commission A11N: Document Control Desk Washington, DC 20555 Joseph H. Farley Nuclear Plant - Unit 2 Updated Ten-Year Inservice Inspection Program Evaluation of HRC SI/IER and Request for Relief Gentlemt.n:
By letter dated August 29, 1991, the NRC issued the Safety Evaluation /
Technical Evaluation Report (SE/TER) for the subject inservice Inspection (ISI) Program (TAC No.0 1578). Alabama Power h mpany has completed its review of the SE/1ER and has determined that changes are needed for three ISI Program relief requests.
Reltef request RR-4 addressed the use of several calibration blocks under the requirements of Code Case N-461.
The NRC granted the relief with the exception of the calibration block to be used for examination of the Volume Control Tank.
Subsequent to the,equest for relief, Regulatory Guide 1.147, Revision 8 approved the use of Code Case N-461, mitigating the need for the relief.
Therefore, RR-4 is herewith withdrawn and Code Case N-461 will be referenced in the ISI Program list of applicable Code Cases.
With regard to the calibration block for the Volume Control Tank, a replacement calibration block will be fabricated which meets the ASME Code,Section XI requirements.
Relief request RR-29 was denie; on the basis that the subject portion of piping could be visually exam'ned at its normal operating pressure which is significantly higher than the hydrostatic test pressure of the adjoining Clats 3 piping.
Also, the ASMt: Code approved Code Case N-498 which permits visually exsmining components during a system pressure test at nominal operating pressure in lieu of a system hydrostatic test.
RR-29 has been revised to incorporate the use of Code Case N-498 in performing the system leakage test at normal operating pressure.
If this Code Case is approved for use in a subsequent revision of Regulatory Guide 1.147, this relief request will be considered withdrawn and the Code Case will be added to the ISI Program list of applicable Code Cases.
Relief request RR 33 granted relief from hydrostatically testing certain portions of the Service Water JW), Component Cooling Water (CCW), Chemical and Volume Control and Spent fuel Pool Cooling systems, but denied relief
-for the Reactor Make-up Water (RMW) system due to insufficient basis for determining impracticality. Alabama Power Company has determined that most of the RMW system can be hydrostatically tested.
RR-33 has been revised to list the specific portion of the RMW system which cannot be tested and
'l includes a justification as to why the required testing is impractical.
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l U. S. Nuclear Regulatory Commission Fage 2 addition, several portions of the SW and CCW systems not previously identif-M have been determined to be impractical to hydrostatically test.
RR.33 han oeen revised to add those portions of systems which cannot be bydrostatically tested and includes justifications as to why the required testing is impractical.
Enclosed herewith for use in evaluating the relief requested is a summary description of the reasons for change and revised relief requests providing the required justifications of impracticality.
It is requested that the revised relief requests be granted nr. later than March 6, 1992, as several of the requested reliefs are required for completion of examinations during the Unit 2 eighth refueling outage tentatively scheduled to begin on that date. These examinations are required to be performed during an outage and are required to complete the first ten-year interval scope of work prior to expiration of the ASM: Jode allowed twelve-month grace period, which ends on July 30, 1992.
If there are any questions, or if additional information is needed, please advise.
Respectfully, k O n de-k
'A A Woodard JDW/ STB: map 1425 Enclosures cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell 5
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ENCLOSURE Summary of S'abmittal 2 Rollef Requests to the J. M. Fariey Nuclear Power Plant Unit No. 2 becond Ten Year Inservice inspection Program for ASME Code Class 1,2. and 3 Components Deserlotion/ Reason for Chance 1.
Rollef Request RR 4: Do!eted. Rollef no longer required due to incorporation of Code Case N 461 Into Reg. Guide 1.147. A new calibration block will be fabricated for use on the VCT Reference NRC SE/TER report with letter dated 8/29/91, para. 3.5.1.4 from E. G. Adensam. USNRC to W. G.
Hairston, SNC.
2.
Rollef Request RR 29: Revised ' Alternate Examination
- to incorporate the use of Code Case N 490 and allow for system pressure test at nominal operating pressure in lieu of hydrostatic test pressure.
Reference NRC SE/TER report withletter dated 8/29/01, para. 3.4.2.8 from E. G. Adensam USNRC to W. G. Hairston. SNC.
3.
Rollef Request RR 33: Revised to reflect testing of the RMW System to the extent possible, to include additional SW and CCW piping sections where hydrostatic testing was found impractical, and to provide additional detall as to basis for tellef. Reference NRC SE/TER report with letter dated 8/29/91, para. 3.4.3.3 from E. G. Adensam. USNRC to W. G. Hairston, SNC.
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i REUEF REQUESTS IHP._2 BM i
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REUEF REQUESTS fhE;2 EE:29 COMPONENT OR RELIEF AREA:
Hydrostatic testing of Class 2 boron injection recirculation pump dischargo piping between valves 02E21V00GA and B, O2E21V005A and B, and the adjoining draln piping (Inne No.
CCB42). Reference drawing D 35G355, sheet 1 of 4.
REQUIREMENT FROM WHICH REUEF IS REQUESTED:
Category C-H, Table IWC 25001 of ASME Soction XI, reg arcs a hydrostatic test for all Class 2 pressure rctaining components once every 10 year inspection interval, in accordance with IWC-5222.
BASIS FOR REUEF:
Performance of a hydrostatic test at 3107 psi (1.25 Pd) on the portion of the systom described above requires the use of check valves which are subject to leakage when usod as a hydrostatic tos' boundary. These valves, which are we'dod in place, cannot be removed and replaced by b!Ind flanges.
Experience has shown that those 1 inch Korotest check valvos have soine leakage when subjected to pressures in thh rango. l.eakago pa l these valves could potentially pressurize and overstress the adjoining Class 3 piping which has a design pressure of 150 psl.
ALTERNATE EXAMINATION:
Codo Case N 490, A!tornate Rufos for 10 Year Hydrostatic Pressuto Testing for Class 1 and 2 Systems Soction XI, DMslon 1 will be incorporated for use on the above lines.
They will be visually examinod during a system pressure test at nominal operating pressuro.
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REUEF REQUESTS FNP2 B}l23 COMPONENT OR REUEF AREA:
Hydrostatic testing of portions of Class 3 piping arxf components in the following systems:
e Reactor rnakeup. reference drawing D 35G353, sheet 1.
1.
Portion of piping (3/4 In. HCC.230) off main line (16 in. HCC-236) from RMWST to Cation ConductMty Instrument, located on non code side of valve 02P12V537 (Batis. Note).
Service water. reference drawings D 356308, sheet 1, D 35G370, sheets 1,2,3, and 8 of 9, and D 350344, sheets 1,2,3, and 4.
1.
Portica of piping upstream of valves 02P16V540 and 02P16V541 (Basis Note 1).
2.
Portion of piping downstream of valves 02P16V516 and 02P10V517 (Basis Note 1).
3.
Portion of piping downstream of valves 02P16V545 and V540 to valves 02P16V549 and V550 (Basis Note 2),
4.
Portion of piping downstream of valves 02P16V538 and V539 to the SW pond wet pit (Basis Note 3).
5.
Portion of piping between valves 02P16V592, V593 and D.G.
2B (Basis Note 4).
Component cooling water. reference drawing D 35G343, shoots 1,2, and 3.
1, Component Cooling Weter Surge Tank (Basis Note 2).
2.
Portion of piping from CCW Surge Tank to valves 02P17V117A 02P17V1178, 02P17V121A, 02P17V1218, 02P17V110A, 02P17V1108, 02P17V110E, 02P17V110F, 02P17V109A, 02P17V1090, 02P17V278A, 02P17V278B, 02P17V2780, 02P17V144A, 02P17V1440, 02P17V017A, 02P17V0178 (Basis. Note 2).
3.
Piping between valves 02P17V287 AND V288 (Basis Note 5),
Chemical and volume control reference drawings D 35G356, sheet 3, and D-351115, sheet 1.
1, Portion of piping from valve 02E21V019 to discharge of Boron injection Recirculation Pumps valves 02E21V006A and 02E21V006B (Basis Note 2),
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Spent fuel pool cooling referei.ce drawing D 35G300, sheet 1.
1.
Portion of piping downstream of valves 02G31V003A and 02G31V903B (Basis Note 2).
2.
Portion of piping downstream of valve 02G31V005 (Basis.
Note 2).
3.
Portion of piping upstream of valves 02G31V001A and 02G31V001B (Basis Note 2).
REQUIREMENT FROM WHICH REUEF IS REQUESTED:
Paragraph LWD 2510 and Table FWD 25001 of ASME Section XI require that all Class 3 pressure retalning components be subjected to visual examination (VT.2) in conjunction with the system pressure tests of IWD-
$000.
BASIS FOR RELIEF ReadpLrnM.0W The maximum operating prassure of this 2 foot section of instrument piping
!s 10 psi wh!!e the app!Iceb!e hydrostatic test pressure would be 165 psi.
Testing this small section of 3/4 Irt instrument line is not warranted considering the possibt'lty of over-pressurlzing the Cetbn ConductMty Instrument.
hjlj.emalo!ng.systemsfas noted):
(1) These portions of Class 3 piping are unisolable from non safety related piping providing service water supply to and from the turbine building.
(2) These portions of Class 3 piping and components cannot be isolated for hydrostatic test since removal from service for testing would render the entire system inoperable.
(3) These portions of Class 3 piping and components cannot be isolated for hydrostatic test since removal from service would render both Units 1 and 2 SW recirculation capabilities to the wet pit and storage pond fiume return inoperable, (4) With the exception of the 2B Diesel Generator, there are no connections (vents an't dralns) within these boundarles which f acilitate attachment of hydrostatic test pumps. Even if/where conr.ections were/are available, G' and 8' butterfly valves would have to provide positive pressure boundary for hydrostatic testing using test pumps.
To hydro test the subject piping utiltzing the SW pumps would Iequire a system valve line-up which renders all diesel generators associated with the Service Water train being tested inoperable.
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o (5) Tiils portion of Class 3 piping cannot be isolated for hydrostatic testing by any means other than check valve 0?P17V288 in the i
primary chemistry sample room.
ALTERNAiE EXAMINATION:
The subject piping wul be visually inspected for leakage (VT 2) during s
perfonnance of a system inservice test (IWA 5211(c)) once cach inspection period.
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