ML20096D626

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Forwards Relief Requests RI-22 & RI-23 to Support Plans to Replace RCIC Sys Steam Supply Inboard Valves 1E51-F063 & 2E51-F063 During Fifth Refueling Outage.Requests That Relief Be Extended Through Remainder of First 10 Yr Insp Interval
ML20096D626
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 05/07/1992
From: Shields J
COMMONWEALTH EDISON CO.
To: Murley T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
NUDOCS 9205180162
Download: ML20096D626 (7)


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-4 Commonwealth Edison Et 1400 Opus Place Downers Grove. Liinois "0$1b j

i May 7, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation 0.G. Nuclear Regulator / Commission Hashington, D.C.

2055 I

Attn:

Document Control Desk

Subject:

LaSalle County Station Units I and 2 In-Servico Inspection Program Submittal of ReIlof Requests RI-22 and RI-23 EUpskLNm M-313_andJiQ-314 _

Dr. Murley:

Comrnonweal th Edison (CECO) intends to replace each Unit's Reattor Cc '

Isolation Cooling (RCIC) system steam Supply inboard Isolation talve (1f.51-F061 and 2E51-F063) during each Unit's fif tu refueling outage.

'a also IM, ends to install mating flanges on the RCIC system H' tad Spray piping during the same refueling outages.

Both of those replacements require the perforn of a hydrostatic test after the replacement is performed, in accorda. ' sith the 1980 Edition, Hinter 1980 Addende of ASME Section XI.

lo support replacement.

ode relief is requested with respect to ASME Section XI Paragraphs IHA-5214 and IHB-5222(a).

The attached relief requests, RI-22 and RI-23, present CECA's proposed alternate examinations.

Relief. requests RI-22 and Ri-23 are applicable to both Units 1 and 2, and it is requested that the relief extend through the remainder of the

'first 10 year Inspection Interval, which v 11 be completed after each Unit's sixth refueling outage.

Commonwealth Edison requests approval of tnis relief request to support the upcoming Unit I refueling outage which is scheduled to hegin on September 26, 1992.

Please contact this office should further information be required.

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Respectfully, 7

t jQg JoAnn M. Shields 3o0.

Nuclear Licensing Administrator I: OO gg

Attachment:

Relief Requests RI-22 and RI-23 for LaSalle County Station 136 cc: -A. Bert Davis, Regional Administrator-RTII lJo B.L. Siegel, NPR Project Manager-LaSalle JoM D, Hilis, Senior Resident Inspector-LaSalle L5 R. A. Hent, ann, HRR Technical Staf f

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J.A. Davis, NRR Technical Staff l - o o.o

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RELIEF REQUECT NO. RI-22 FOR LA3ALLE COUNTI DTATION UN~TS I & II 90MPONENT IDENTIFICATION Code Class:

1

References:

Article IWA-5000 Article IWA-7000 Article IWB-5000 Article IWB-7000 Examination Category:

B-J Item Number: B9.11 Lescription:

Relief from ASME Section XI Hydroctatic Test Requirements after Repair / Replacement.

CODE REOUIREMENT LaSalle Station is committed to the 1980 Edition, Winter 1980 Addenda of ASME Section XI.

Articles IWA-7000 and IWB-7000 govern the replacement of the station's Reactor Core Isolation Cooling (RCIC), system Etcan Supply Inboard Isolation valves (1E51-F063 in Unit 1, and 2E51-F063 in Unit 2).

The referenced articles require the performance of a hydrostatic test after the replacement is completed. The specific H

requirements for the performance-of the hydrostatic test are provided in Paragraph IWA-5214"and Subparagraph IWB-5222(a).

IWB-5222(a) states that the system hydrostatic test shall be conducted at a test pressure 1.10 times the system nominal operating l

pressure that corresponds with 100% rated reacter power except when the test is conducted at temperatures above l

100 degrees Fahrenheit (38 C) to meet the requirements l

of IWB-5230.

L PASJ_S FOR RELIEF Due to the physical location of the replacement valve (s) in the piping system, LaSalle Station is unable to provide a practical upstrean hydrostatic test L

boundary between the replacement valve (s) and the Reactor Pressure Vessel.

The inability to provide such an isolation boundary would result in undue hardship, and difficulty in that a Hydrostatic Test of the

-Reactor Pressure Vessel would be required in order to meet the Code specified e:: amination.

The valve lineup associated with Hydrostatic test of the Reactor 1

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i Pressure vessel would require that certain Safety I

System components such as the Mainsteau Safety Relief Valves be gagged, and that other overpressura l

protection devices and instruments be defeated in order l

to prevent their actuation during the tort.

The technical basis for requestiag relief from the Code Requirement is supported by the fact that the rcplacement valve (s) will be constructad in accordance with ASME Sortion III Class 1 rules which require that the completed component be hydrostatical]y tested at the Manufacturers shop.

The weldmonts which join the new replacement valve (s) component to the connecting piping will also be required to meet ASME Section III, Class 1 standards and will therefore be subjected to both surface and Volumetric Examination.

Upon completion of the constraction phase of the Replacement, additional Volumetric Examination using the Ultrasonic method will be performed to meet the Preservice Inspection requirements of the 1980 Edition, Winter 1980 Addenda of ASME Section XI.

It is the belief of LaSalle County Station that this level of Nondestructive Examination when combined with the proposed Alternative Exanination described below, give adequate assurarce that the structural integrity of the system has been mair.tained, as well as providing the appropriate level of quality and safety.

PEOPOSED ALTES_NhTJlL EX? MIN.]T1QM In lieu of the Code Requirement, LaSalle County Statica L. hall perform the System Leakage Test as described in Subparagraph IWA-5211(a), and Paragraph IWB-5223.

This proposed alternative pressure test shall be conducted at a test pressure not less than the nominal operating pressure associated with 100% rated reactor power.

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APEICABLE TIE PEBlM)

This relief is requer,ced for each refueling outage for LaSalle County Station Units 1 & 2, beginning with the fifth refueling outage for Unit 1 which is scheduled to i

begin September 26, 1992.

It is also requested that the relief extend through the remainder of the first 10 year Inspection Interval for each Unit (1 & 2) which will be completed after that Unit's sixth refueling outage.

The sixth refueling cutage for LaSalle County Station Unit 1 is scheduled to end in May of 1994.

the sixth refueling outage for LaSallo Co'inty Station Unit 2 is scheduled to end in May of 1995.

Extension of the relief f r these specific applications treplacement of the 1 & 2E51-F063 valves) through the end of the Inspection Interval wnuld alleviate the need to generate un additional relief roquest if installation of the subject design changes were deferred frcsm the upcoming fifth refueling outage (s) due to uncertainty in scheduling.

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O RELIEF REQUEST No. RI-23 FOR LASALLE COUNTY STATION UNITS I & II COMPONENT IDENTIFICATION Code Class:

1 Referencest Article IWA-5000 Article IWA-7000 Article IWB-5000 Article IWB-7000 E' amination Category:

B-J Item Numbert B9.11

==

Description:==

Relief from ASME Section XI Hydrostatic Test Requirements after Repair / Replacement.

CODE REOUIRKhKET LaSallo Station is comioitted to the 1980 Edition, Winter 1980 Addenda of ASME Fection XI.

ArticleF IVA-7000 and lWB-7000 govern the replacement of a portion of the Reactor Core Isolation Cooling (RCIC) system Heed Spray piping with a pe.ir of mating flenges.

Ohn flanges will be added at the highest point in the RCIC Head Spray piping (for Units 1 & 2) in the vicinity of the connection of this piping to the Reactor Pressure Vessel Head Spray Nozzle (N-7).

The referenced articles require the performancu of a hydrostatic test after the replacement is completed.

The specific requirements for the performance of the hydrostatic test are provided in Paragraph IWA-5214 and subparagraph IWB-5222(a).

IWB-5222(a)-states that the system hydrostatic test shall be conducted at a test L

pressure 1.10 times.the system nominal operating l

pressure that corresponds with 100% rated reactor power except when the test is conducted at tenperatures above 100 degrees Fahrenheit (38 C) to meet the requirements of IWB-5230.

R4Elg FOR RELIEE Due to tne physical location of the new flanges in the piping system, LaSalle Station is unable to provide a practical upstream -hydrostatic test boundary between the flange.s-and the Reactor Pressure Vessel.

The inability to provide such an isolation boundary would result in undue hardship, and difficulty in that a Hydrostatic Test of the Reactor Pressure Vessel would be required in order to meet the code specified 1

_m.._._

o examination.

The valve lineup associated with Hydrostatic test of the Reactor Pressure Vessel would i

require that certain Safety System components such as the Mainsteam Safety Relief Valves be gagged, and that I

other overpressure protection devices and instruments be defeated in order to prevent their actuation during the test.

The technical basis for requesting relief from the Code Requirement is supported by the fact that the new flanges and the weldments which join them to the connecting piping will be constructed in accordance with ASME Section III Olass 1 rules.

These rules require that the completed flanges be subjected to Surface Examination by the manufacturer, and that the completed welds be subjected to both surface and Volumetric Examination.

Upon completion of the construction phase of the Replacement, additional Volumetric Examination using the Ultrasottic method will be perforned to meet the Preservice Inspection requirements of the 1980 Edition, Winter 1980 Addenda of ASME Section XI.

It is the belief of LaSalle County Station that this level of Nondestructive Examination when combined with the Proposed Alternative Examination aescribed below, give adequate assurance that the ctructural integrity of the system has been maintained, as wall as providing the appropriate level of quality and safety.

PROPOSED _ ALTERNATE EXAMINATIOZ In lieu of the Code Requirement, LaSalle County Station shall perform the System Leakage Test as described in Subparagraph IWA-5211(a), and Paragraph IWB-5221.

This proposed alternative pressure test shall be conducted at a test pressure not less than the nominal operating pressure associated with 100% rated reactor power.

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,s hPLICABLETIHgPERIOD This relief la requested for each refueling outage for LaSallo County Station Units 1 & 2, beginning with the fifth refueling outage for Unit I which is scheduled to begin September 26, 1992.

It is also requested that.

the relief extend through the remainder of the first 10 year Inspecticn Interval for each Unit (1 & 2) which will be completed after that Unit's sixth refueling outage.

The sixth refueling outage for LaSallo County Station Unit 1 is schedulcd to end in May of 1994.

The sixth refueling outage for LaSalle County Station Unit 2 is scheduled to and in May of 1995.

Extension of the relief for these specific applications (addition of RCIC head spray flanges) through the und of the Inspection Interval would alleviate the need to generate an additional relief request if installation of the subject design changes were deferred from the upconing fifth refueling outage (s) due to uncertainty in scheduling.

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