B11710, Requests That Recirculation Spray Sys Embedded Piping & Encapsulation Be Exempt from ASME Iii,Class 2 Requirements for Radiography.Justification for Request Provided in Encl Engineering Evaluation Rept

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Requests That Recirculation Spray Sys Embedded Piping & Encapsulation Be Exempt from ASME Iii,Class 2 Requirements for Radiography.Justification for Request Provided in Encl Engineering Evaluation Rept
ML20132B571
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/18/1985
From: Fee W, Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Youngblood B
Office of Nuclear Reactor Regulation
Shared Package
ML20132B576 List:
References
B11710, NUDOCS 8509260234
Download: ML20132B571 (2)


Text

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(203) 665-5000 September 13,1985 Docket No. 50-423 Bil710 Director of Nuclear Reactor Regulation Attn:

Mr. B. 3. Youngblood, Chief Licensing Branch No. I Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20535

Dear Sir:

Millstone Nuclear Power Station, Unit No. 3 Request for Exemption from ASME Code Requirements for Radiographic Inspections Reviews conducted by Northeast Nuclear Energy Company (NNECO) and the NRC of radiographs supplied by TUBECO, specifically those supplied for sections of the Containment Recirculation Spray System (RSS) which are embedded in the containment floor, have resulted in several concerns relative to radiograph quality and possible indications.

To resolve these concerns, NNECO has undertaken the following actions:

1.)

Conducted an exhaustive document search to investigate the materials of construction, fabrication methods employed, and tests and inspections performed; 2.)

Performed a piping stress analysis on the embedded sections using faulted conditions; 3.)

Characterized all suspect indications and poor quality radiographs by visually inspecting the inner surface of the embedded pipe, reviewing the radiographs, and having discussions between the NNECO and Stone &

Webster NDE Level 111 personnel; 4.)

Performed a fracture mechanics evaluation of the embedded portion of pipe to assess the effect of potential flaws on the system operability; and 5.)

Performed additional radiography and ultrasonic examinations of the suspect encapsulation welds.

Details on each of the above actions are provided in the attached engineering evaluation report. Based on this evaluation, NNECO concludes that the RSS embedded piping meets the intent of Section 111 of the ASME Code for Class 2 piping and will function as originally designed.

However, due to the i

noncompilances identified, (i.e. poor quality and missing radiographs) the ASME

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N-5 certification cannot be issued. Therefore, pursuant to 10CFR50.55a (a)(3),

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0 we request that the RSS embedded piping and encapsulation be exempt from the ASME 111, Class 2 requirements for radiography.

The justification for this request is provided in the attached engineering evaluation report.

Due to our need to resolve this matter prior to the November 1,1985 fuel load date, we request that you review and approve this submittal by October 1,1985.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY et. al.

BY NORHTEAST NUCLEAR ENERGY COMPANY Their Agent s

3.95/Opeka f

Senior Vice President

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a By: W. F. Fee Executive Vice President STATE OF CONNECTICUT

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) ss. Berlin COUNTY OF HARTFORD

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Then personally appeared before me W. F. Fee, who being duly sworn, did state that he is Executive Vice President of Northeast Nuclear Energy Company, an Applicant herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Applicants herein and that the statements contained in said information are true and correct to the best of his knowledge and belief, s

sA

. otary Public IJy Commhsic~nixpres thrdi 3I.1983

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