ML20206D523

Safety Evaluation Supporting 880309 Request for Relief from Hydrostatic Test Requirement for HPCI & Rcic,Provided That Alternative Testing Performed

ML20206D523
Person / Time
Site:	FitzPatrick
Issue date:	11/10/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20206D522	List: ML20206D517 ML20206D523
References
NUDOCS 8811170121
Download: ML20206D523 (5)

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NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 u.../

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULAT!]

REQUESTFORRELIEFFROMHYDROSTATICTESTREQUIREM1NT JAMESA.FITgPATRICKNUCLEARPOWERPLANT DOCKET NO. 50-333 L

1.0 INTRODUCTION

In a letter dated March 9, 1988, the Power Authority of the State of New York (the licensee) requested relief from the hydrostatic test requirements of ASME I Code Section XI for the High Pressure Coolant Injection (HPCI) and the Reactor

• Core Injection Cooling (RCIC) systems at James A. Fit 1 Patrick Nuclear Power Plant. The reouest for relief covered the first and second ten-year inservice inspection (ISI) intervals, i Pursuant to 10 CFR Part 50.55afg)(5), should the licensee detemine that certain j ASME Section XI Code examination requirements are impractical and requests relief, the licensee shall subtrit infomation to the Nuclear Regulatory

Commission (NRC) to support that detennination.  ;

! Pursuant to 10 CFR Part 50.55a(g)(6), the Connission will evaluate the determination that Code requir.;ments are impractical. The Comission ray <

grant relief and/or impose alternative requirements that are determined to be

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authorized by law, will not endanger life or property or the comon defense and security, and are otherwise in the public interest, giving due  ;

consideration to the burden upon the Itcensee that could result if the ,

requirements were imposed on the facility. l In a [[letter::JPN-88-048, Forwards Request for Relief from Hydrostatic Test Requirements for HPCI & RCIC Steam Supply & Exhaust Piping in Inservice Insp Program for Welds & Supports|letter dated September 9, 1988]], the licensee revised the relief request i from the hydrostatic test requirements for the HPCI and RCIC steam supply and  !

exhaust pipino to a relief request for the steam exhaust piping only. The licensee concluded that the inservice functional testing performed in August 1988 on this piping met the intent of the hydrostatic test requirements .

. of Section XI of the ASME Code. I In a letter dated September 30, 1988 additinnal details were supplied describing i the difficulty of performing the tests.  ;

r 2.0 EVALUATION

?.1 SCOPE The licensee requested relief from the requirements of IWC-5000 and [

IWD-5000 of the ASME Section XI,1974 Edition through Summer 1975 Addenda, system hydrostatic tests for the HPCI and RCIC systems for r the first ten-year interval inservice inspection program. This relief l t i GG11170121 931110 i j PDR ADOCK 05000333 r F PDC

request applies to HPCI and RCIC turbine steam exhaust piping. It does not include the turbine steam inlet, pump suction, or discharge piping which will be tested in accordance with Code requirements.

The relief request also applies to the second ten-year interval ISI

-program. The ASME Code, which governs the second ten-year interval, is the 1980 Edition through Winter 1981 Addenda. The licensee is presently within the first inspection period of the second ten-interval.

2.2 TECHNICAL BASIS FOR RELIEF l

The licensee's letter dated September 30, 1988 provided the following basis for the reovest for relief.

The FitzPatrick HPCI and RCIC turbine exhaust lines were not designed for hydrostatic testing as evidenced by the design pressure of the turbine seals (30 psig), the interferences which exist with other systems, and the difficulty of installin; temporary closures (pancakes / blind flanges, etc.). These interferences were described by the licensee, along with a series of photographs which are on file.

Interferences in the HPCI system, the estimated work effort and estimated 4

exposure are:

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- Lines 23-2"-WCP-15?-12 from the lube oil cooler and gland seal

condenser returning to HPCI booster pump suction runs directly I over the HPCI turbine exhaust flange and would have to be

! removed for access. This line is 2" schedule 80 carbon steel l pipe with socket weld connections. Cutting and rewelding would be required. Approximately 24 man-hours and 0.288 man-rem would be required.

! - Stem seal leak-off lines from the turbine control valve to the gland seal condenser also run directly over the exhaust flange and would need to be removed for access to the exhaust l flange. Approximately 24 man-hours and 0.288 man-rem would be l

required.

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- Fire protection lines run near the exhaust flange which may need to be removed for access. Approximately 24 man-hours and l 0.288 man-rem would be required.

- A unit cooler drain line (2" Sch 80) runs near the vertical run of the HPCI turbine exhaust line and would require removal by cutting and rewelding. Approximately 24 man-hours and 0.288 j man-rem would be reouired.

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- The following electrical conduits would need to be moved for access or to allow exhaust line movement for blank installation.  ;

Approximately 24 man-hours and 0.288 man-rem would be required.

ICC591BH1 to 23LS-98 1CC59185 to 23A0V-53 1CC591BR to 23LS-100

- Four temporary pipe supports and support modifications would be required to carry the weight of the exhaust line filled with water.

Also, it would be difficult to rig the removal of the che spool piece above rupture disc 23Z-7 to allow for installation of a blind flange at this location. Approximately 120 man-hours and 1.44 man-rem would t,a required.

- The disconnection of an exhaust flange, movement of the exhaust line, installation of a blank insert and closure of an exnaust flange would be required to provide a test boundary at the exhaust flange.

Restoration to normal after the hydrotest would also be required.

Approximately 32 man-hours and 0.384 man-rem would be required.

Interferences in the RCIC system are the following:

- The RCIC tur~ine o covernor control box is directly over the turbine exhaust flange and would need to be removed for 4

temporary closure (blank) installation. Approximately 120 man-hours and 1.44 man-rem wuuld be reouired, t

- Pipe Supports PFSK-1914 and PFSK-1968 would require partial L disassembly to allow exhaust line movement for blank  :

4 installation. This would require cutting / grinding welds and i rewelding to restore. Approximately 24 m n-hours and 0.288 man-ren would be required.

- Instrument lines and supports from root valves RCIC-800 and RCIC-801 to pressure switches 13PS-72A and 13PS-72R would require relocation (cut and reweld) to allow exhaust line movement. Approximately 12 man-hours and 0.144 man-rem would be required.

l - The disconnection of an exhaust flance, movement of the exhaust line, 4

installation of a blank insert and closure of an exhaust flange J would be required to provide a test boundary at the exhaust flange.  ;

Restoration to normal after the hydrotest wculd also be required.

Approximately 16 man-hours and 0.192 man-rem would be required.

, The interference indicated above are shown on the file photographs. The photographs and discussion provide evidence of the impracticability of the l hydrostatic test of the HPCI and RCIC exhaust lines from the turbine exhaust  !

< flange to the first isolation valve. The exhaust flanges are not designed for disconnection for routine maintenance. This is shown by the fact that the ,

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exhaust nozzle is on the lower turbine casing shell so that disconnection is not required for access to the rotor. The lack of accessibility discussed previously reinforces this fact. The installation of temporary closures .

would create additional local stresses which are-likely to result in local yielding at elbows and flanged connections. The possibility that other safety-related components could become damaged or improperly reinstalled is increased.

2.3 PROPOSED ALTERNATIVE EXAMINATION I

The licensee proposed that the system inservice test perfomed in August t 1988 be accepted in lieu of hydrostatic testing. This test was performed in accordance with IWA-5211 of the ASME Section XI Code. The intervice test included portions of the system (i.e., turbine and turbine xhaust to the torus) that would not be tested during a hydrostatic test examination. A VT-2 examination was conducted during the inservice test.

The licensee considers an inservice test superior to a system hydrostatic test for the following reasons:

- The inservice test included the complete ISI system boundary includir.g exempt components, the RCIC and HPCI turbines and steam exhaust piping. ,

1 - The inservice test was perfomed at the system's operating pressure i and teniperature, and, thus, is as effective as a hydrostatic test i for leakage detection during a VT-2 examination. The system l s

hydrostatic test would not effectively test the structural integrity '

of the system as intended.

- The inservice test will avoid the anticipated radiation exposure of  !

approximately 11.994 man-ren, t j

- During the installation of temporary supports and blank flanges, t there is a possibility of damage to the piping or other ad.iacent )

, components. l t

3.0

SUMMARY

4 We conclude that the ASME Section XI Code hydrostatic test requirements 4 for the steam exhaust piping are impractical to perform in the High Pressure Coolant In,iection and the Reactor Core Isolation Cooling systems i at the James A. FitzPatrick Nuclear Power Plant and would result in a  !

2 burden on the licensee. In lieu of the hydrostatic test requirement, a  !

system inservice test performed in accordance with Subsection lWA-5211 of l Section XI of the ASME Code, will satisfy the hydrostatic test requirement 4

i in the HPCI and RCIC systems steam exhaust piping during the first and second ten-year ISI interval.  !

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4.0 CONCLUSION

The licensee has provided sufficient technical information to justify the detern.ination that the hydrostatic test requirement of Section XI of the ASME Code for the steam exhaust piping in the High Pressure Coolant Injection and the Reactor Core Isolation Cooling Systems is impractical to conduct at the James A. FitzPatrick Nuclear Power Plant. In lieu of the hydrostatic test requirement, an inservice test )erformed in accordance to Subsection IWA-5211 of Section XI of t1e ASME Code may be used to assure structural integrity of the steam exhaust piping. The Inservice Test perforr,ed in August 1988 satisfies this requirement for the first 10 year interval. An additional Inservice Test must be performed during the second ten year interval.

Pursuant to 10 CFR 50.55a(g)(6)(1), relief is granted as requested by the licensee in their letters dated March 9, 1988, September 9, 1988, and September 30, 1988, provided the alternative testing is performed. This relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden that could result if the code requiremencs were imposed.

Date:

PRINCIPAL CONTRIBUTOR:

F. Litton l

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