ML20086H834
| ML20086H834 | |
| 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-M65482, NUDOCS 9112090453 | |
| Download: ML20086H834 (8) | |
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Docket No. 50-348 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant - Unit 1 Second Ten-Year Inservice Inspection Program
[yaluation of NRC SE/TER and Reauest for Relief Gentlemen:
By letter dated August 28, 1991, the NRC issued the Safety Evaluation /
Technical Evaluation Report (SE/TER) for the subject inservice Inspection (ISI) Program (TAC No #65482). Alabama Power Company has completed its review of the SE/TER and has determined that changes are needed for three ISI Program relief requests.
Relief 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 W Subsequent to the request for relief, Regulatory Guide 1.147, Revir M P ~ roved the use of Code Case N-461, mitigating the need for the sfore, RR-4 is herewith withdrawn and Code Case N-461 will be relit *
.t referm d ' i the 151 Program list of applicable Code Cases.
With regard to the D 0 ration block for the Volume Control Tank, a replacement calibratio.i block will be fabricated which meets the ASME Code,Section XI requirements.
Relief request RR-29 was denied on the basis that the subject portion of piping could be visually examined at its normal operating pressure which is significantly higher than the hydrostatic test pressure of the adjoining Class 3 piping.
Also, the ASME Code approved Code Case N-498 which permits visually examining 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Case is approved for use in a subsequent revision of Regulatory Guide 1.147, this relief request will be considered withdrawn and the Code Case will be added to the ISI Program list of applicable Code Cases.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 (SW), 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 includes a justification as to why the required testing is impractical.
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U. S. Nuclear Regulatory Commission Page 2 addition, several portions if the SW and CCW systems not previously identified have been detetuined to be impractical to hydrostatically test.
RR-33 has been revised-to add those portions of systems which cannot be hydrostatically tested and includes justifications as to why the required i
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 recuired justifications of impracticality.
It is requested that the revisec relief requests be granted within six months after receipt of this letter.
If there are any questions, or if additional information is needed, please-advise.
-Respectfully, hhnAd
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. Woodard JDW/ STB: map 1415 Enclosures cc:
Mr. S. D. Ebneter Mr. S. T. Hoffman
'Mr. G. F. Maxwell l
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0 ENCt.OSURE Summary of Submhta! 4 Relief Requests to the J. M. Fadey Nuclear Power Plant Unit No.1 Second Ten Year Inservice inspection Program for ASME Code Class 1,2, and 3 Components Descrintion/ Reason for Chanog 1.
Rollef Request RR-4: Deleted. Rollef no longer required duo to incorporation of Code Case N-401 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 8/28/91, para. 3.6.1.4 from E. G. Adensam, USNRC to W. G.
Hairston, SNC.
2.
Rollel Request RR 29: Revised ' Alternate Examinatinn* to incorporate the use of Code Case N 498 and allow for system pressure test at nominal operating pressure in lieu of hydrostatic test pressure.
Reference NRC SE/TER report withletter dated 8/28/91, para 3.4.2.8 from E. G. Adensam, USNRC to W. G. Hairston, SNC.
3.
Relief Request RR 33: Revised to reflect testing of the RMW System to the extent possible, to include additional SW and CCW piping sections where hydrostatle testing was found impractical, and to provide additional detail as to basis for relief. Reference NRC SE/TER report with letter dated 8/28/91, para. 3.4.3.3 from E. G. Adensam, USNRC to W. G. Hairston, SNC.
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i REUEF REQUJST ENP 1 BM2 COMPONENT OR REUEF AREA:
Hydrostatic test'ng of Class 2 boron injection recirculation pump discharge piping betwe>n valves 01E21V00GA and B,01E2tV005A and B, and the adjoining drain piping (Iln s No. CCB-02). Reference drawing D 351115, shoot 1 of 4.
REQUIREMENT FROM WHICH REUEF IG REQUESTED:
Category C H, Table IWC 25001 of ASME Section XI, requires a hydrostatic test for all Class 2 pressure retalning components once overy 10 year inspection interval, in accordance wl'.h IWC-5222.
BASIS FOR REUEF:
Performance of a hydrostatic test at 3107 psi (1.25 Pd) on the ponion of the system described above requires the use of check valves which are subject to leakage when used as a hydrostatic test boundary, These va'ves, which are welded in place, cannot be removed and replaced by blind flanges. Experience has shown that these 1. Inch Kerotest check valves have some leakage when subjected to pressures in thin range, Leakage past these valves could potentially proosurize arvi overstess the adjoining Class 3 piping which has a design pressure of 150 psl.
ALTERNATE EXAMINATION:
Code Case N 498, Afternato Rules for 10 Year Hydrostatic PreSWJre Testing for Class 1 and 2 Sptems Sect 5n XI, Division 1 will be incorporated for use on the above lines. They will be visually examined during a system pressure test at nominal operating pressure.
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RELIEF REQUEST Eti?1 2 03 COMPONENT OR RELIEF AREA:
Hydrostatic testing of portions of Class 3 piping and components in the folicMng systems:
Reactor rnakeup. toforence drawing D 351113, shoot 1.
1.
Portion of piping (3/4 in. HCC 230) off main line (16 In. HCC-230) from RMWST to Cation ConductMty Instrument, located on non-codo side of valvo 01P12V537 (Basis Note).
Service water reference drawings D 351120, shoot 1. D 351130, sheets 1,2, and 3 of i t, and D 351104, shoots 1,2, and 3.
1.
Portion of piping upstream of valves 01P16V540 and 01P16V541 (Basis Note 1).
2.
Portion of piping downstream of valves OlP16V516 and 01P16V517 (Basis Note 1).
3 Portion of piping downstream of valves 01P16V545 and V540 to valvos OtPl6V549 and V550 (Basis Note 2).
4.
Portion of piping downstream of valves 01P16V538 and V539 to the SW pond wet pit (Basis Note 3).
5.
Portion oi piping between valves 01P16V520 V529 and 01P16V521, V528 and D.G. 2C (Basis Note 4).
Portion of piping between valvos 01P16V523, V531 and 01P16V522, V530 and D.G.1B (Basis Nots 4).
Portion of piping betwoon valves 01P16V592, V593 and D.G.
2B (Basis Note 4).
Portion of piping between valvos 01P16V624 V532 and 01P16V525, V533 and D.G.1C (Basis Note 4).
Portion of piping betwoon valves 01Pf 6VS26, V534 and 01P16V527, V535 and D.G. 2A (Basis Note 4).
Component cooling water referenco drawing D351103, shoots 1,2, and 3.
1.
Cornponent Cooling Water Surge Tank (Basis Noto 2).
2.
Portion of piping from CCW Surge Tank to valves 01P17V117A, 01P17V1178, 01P17V121A, 01P17V1218, 01P17V110A, 01P17V1108, 01P17V110E, 01P17V110F, 01P17V109A, 01P17V1090, 01P17V278A, Q1P17V2788, 01P17V278C, 01P17V144A, 01P17V1440, 01P17V017A, 01P17V0178 (Basis No1e 2).
3.
Piping between valves 01P17V287 AND V288 (Basis Note 5).
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Chemical and volume control. reference drawings D 351116, sheet 3, and D 351115, sheet 1.
1.
Portion of piping from valve 01E21V019 to discharge of Boron injection Recirculation Pumps valves 01E21V00GA and 01E21V000B (Basis Note 2).
Spent fuel pool cooling reference drawing D-351120, shoot 1, 1.
Portion of piping downstream of valves 01G31V003A and 01G31V003B Casis. Note 2).
2.
Portion of piping downstream of valve 01G31V005 (Basis -
Note 2).
3.
Portion of piping upstream of valves 01031V001A and 01G31V001B (Basis. Note 2).
REQUIREMfiNT FROM WHICH REUEF IS REQUESTED:
Para 0raph IWD-2510 and Table IWD-25001 of ASM5 Section XI require that all Class 3 pressure retalning components De subjected to visual examination (VT 2) in conjunction with the system pressure tests of IWD-5000.
BASIS FOR REUEF:
Mattor makeuo:
The maximum operating pressure of this 2 foot section of instrument piping is 10 psi while the applicable hydrostatic test pressure would be 165 psl.
Testing this small section of 3/4 in. Instrument line is not warranted
'onsidering the possibility of over-pressurizing the Cation ConductMty instrument.
RJJamalnina systems (gg.pgled):
(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 flume retum inoperable.
(4) With the exception of the 28 D'esel Generator, there are no connections (vents and drains) within these boundaries which facilitate l
attachment of hydrostatic test pumps. Even if/where connections were/are available,6' and 8' butterfly valves would have to provide PageS 1
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positke pressure boundary for hydrostatic testing using test pumps.
To hydro test the subject piping utillzing the SW pumps would require a system valve line up which renders a!! diesel generators associated with thJ Service Water train being tested inoperable.
(5) This portion of Class 3 piping cannot be isolated for hydrostatic testing by any means other than check velve 01P17V288 in the primary chemistry sample room.
ALTERNATE EXAMINATION:
The subject p! ping wil! be visually inspected for leakage (VT 2) during performance of a system inservice test (IWA 5211(c)) once each inspection period.
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